United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01 -91/059
September 1991
&EPA Superfund
Record of Decision:
Savage Municipal Water
-------
150272.101
REPORT DOCUMENTATION T1. REPORTNO. I ~ 8. A8cIpIent8 "-eIon No.
PAGE EPA/ROD/ROl-9l/059
4. 1118... IkM1I8 So Report D818
SUPERFUND RECORD OF DECISION 09/27/91
Savage Municipal Water Supply, NH
8.
First Remedial Action - Final
7. Aulhor(8) 8. P8rfonnIng CJrg8nJzatIon Rapt. No.
8. P8rformIng 0rg8InIz81I0n NIm8 ... Add-. 10. Proj8ctIT88II/Wortt UnIt No.
11. ~C)orGr8nl(G)No.
(C)
(0)
1~ Spon8orIng Org8nIDIIon NIm8 ... Addr888 18. Type of R8por1& P8riod Cowred
U.S. Environmental Protection Agency 8001000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SUppl8mlnlary No-
18. Ab81r8ct (Umlt: 200 _rd8)
The Savage Municipal Water Supply site is located in Milford, New Hampshire. The
site and surrounding properties encompass the Savage Municipal Well, four major
industrial facilities, and two fish hatcheries. Land use includes residential,
agricultural, heavy and light industrial, and commercial areas. The site is located
within the 100-year floodplain of the Souhegan River, which is the principal stream
flowing through the site. From the 1940's to the 1980's, process and waste waters
from the industrial facilities were released untreated to the ground water or to the
surface waters flowing through the site. In 1983, the State identified
concentrations of several VOCs that were above drinking water standards in water from
the Savage Municipal Well and water drawn from the well supplying a nearby trailer
park. At the State's request, EPA conducted a removal action in 1983. This included
temporarily supplying bottled water to affected residences in the trailer park, and
connecting the residences to the existing municipal water supply system. This
remedial action addresses potential risks to future use of the aquifer caused by
ground water contamination at the site, within a 6,000- by 2,500-foot contaminated
ground water plume. This ground water plume was divided into two zones: the
(See Attached Page)
17. Doc:unent An8Iy8I8 & D88c:rtplOl'I
Record of Decision - Savage Municipal Water Supply, NH
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, TCA, TCE), metals (arsenic, chromium, lead)
b. Id8ntIfI8r8/Op8 T8nn8
C. COBA TI Fl8lcl/Grcql
18. AvIIIl8bl1Ity 9I8I8m8IIt 18. SecI81ty CI888 (Th18 R8por1) 21. No. of P8888
None 308
20. SecI81ty CI... (1bI8 1'888) ~ PrIce
Non",
21Z(4-n)
(S88 ANSl-Z38.18)
SHI".II'UCti- on Re-
(FOI'III8fIy NTlS-35)
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EPA/ROD/ROl-91/059
Savage Municipal Water Supply, NH
First Remedial Action - Final
Abstract (Continued)
concentrated plume, which contains the highest concentrations of contaminants;
extended plume, which has the remainder of the contaminated ground water. The
contaminants of concern affecting the ground water are VOCs including benzene,
and TCE; and metals including arsenic, chromium, and lead.
and the
primary
PCE, TCA,
The selected remedial action for this site includes onsite pumping and treatment of the
concentrated and extended plume areas using air stripping and ultraviolet oxidation;
discharging the treated ground water onsite; use of natural attenuation to aid in
contaminated ground water remediation until clean-up levels are met; implementing ground
water, surface water, and sediment monitoring programs during remediation; and
implementing institutional controls including deed and ground water use restrictions.
The estimated present worth cost for this remedial action is $15,500,000, which includes
an annual O&M cost of $1,400,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Interim ground water clean-up levels for carcinogenic
compounds have been set at the more stringent of MCLs, non-zero MCLGs, or an excess
cancer risk of 10-6. Clean-up levels for non-carcinogenic compounds have been set at
the non-zero MCLG or an HI=l. Ground water clean-up levels include benzene 5 ug/l
(MCL), PCE 5 ug/l (MCL), TCE 5 ug/l (MCL), arsenic 50 ug/l (MCL), chromium 100 ug/l
(MCL), and lead 15 ug/l (action). Final protective clean-up levels will be developed
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.;/'\110 n_..,."
i A \
i,,-l
"'.( /WJIt.c,'
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02203-2211
,..", .
DECLARATION FOR THE RECORD OF DECISION
Savage Municipal water Supply Superfund Site
Milford, New Hampshire
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for the Savage Municipal Water Supply Superfund Site in Milford,
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, and to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP), 40
CFR Part 300 et sea., as amended. The Region I Administrator has
been delegated the authority to approve this Record Of Decision.
The State of New Hampshire has not commented on nor concurred
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 Wadleigh Memorial
Library in Milford, New Hampshire and at the Region I Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Records Index (Appendix E to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare or to the
environment. .
PRINTED ON RECYCLED PAPER
8t.5.r.o'l~
, .
" ..
~ '"
" ~
~ q,
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DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for Savaqe Municipal
Water Supply Site, which addresses manaqement of miqration to
meet cleanup qoals. The selected remedy is a comprehensive
remedy since no source control component is necessary. This
remedy addresses the potential risks to the future uses of the
aquifer caused by the qroundwater contamination at the site.
The remedial measures to address the qroundwater contamination
include:
Installation of a qroundwater extraction and treatment
system at the concentrated plume area. The system will
contain and remove hiqhly contaminated qroundwater for
treatment usinq air strippinq and ultraviolet
oxidation.
.
Installation of'a qroundwater and treatment system
within the extended plume area. The system will remove
contaminated qroundwater from two locations near the
middle of the plume and two locations near the end of
the plume for treatment usinq ultraviolet oxidation.
Reliance on natural attenuation of contaminated
qroundwater to lower contaminant concentrations throuqh
physical, chemical and bioloqical processes until
qroundwater cleanup levels are met.
.
utilization of institutional controls to reduce the
risk to public health from consumption of the
qroundwater. Institutional controls may include deed
restrictions and zoninq ordinances to restrict the use
of contaminated qroundwater. Institutional controls
shall be imposed in the area where the" risk to public
health is outside EPA'sacceptable risk ranqe
Implementation of an environmental monitorinq proqram
initiated durinq remedial desiqn and continuinq for
three years after attaininq qroundwater cleanup levels
to assess the effectiveness of remediation and to
confirm that contaminant concentrations in the
groundwater have attained cleanup levels. The program
will include monitorinq of qroundwater, surface water,
sediments, and existing households obtaining drinkinq
water from the aquifer. .
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3
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effective. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce toxicity, mObility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions and alternative treatment technoloqies to the maximum
extent practicable.
A review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~.")'7 Iff!
. Date I
ulie Belaqa
Reqional Administrator
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SAVAGB IfD1I1:CIPAI, n~ 8uPPLY 8trPBUuJm 8Ift
DCORD 01' DBCI8IO. 811111n1tY
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RECORD OF DECISION
SAVAGE MUNICIPAL WATER SUPPLY
Contents
Number
TABLE OF CONTENTS
I.
SITE
A.
B.
C.
NAME, LOCATION AND DESCRIPTION. . . . . . .
General Description. . . . . . . . . . . . . . . .
Hydrology and Geology of the Site . . . . . .
Aquifer Use. . . . . . . . . . . . . . . . .
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . .
A. Land Use and Response History. . . . . . . . . . .
B. Enforcement History. ... . . . . . . . . . . . . .
III. COMMUNITY PARTICIPATION
. . . . .
. . . . .
. . . . . .
IV.. SCOPE AND ROLE OF RESPONSE ACTION
...........
V.
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . .
A. 8011 . . . . . . . . . . . . . . . . . . . .
B. Groundwater. . . . . . . . . . . . . . . . .
C. Surface Water. . . . . . . . . . . . . . . . . . .
D . Ai r . . . . . . . . . . . . . . . . . . . . . . . .
E. Sediment..... . . . . . . . . . .
VI.
SUMMARY OF SITE RISKS
.......
.......
VII. DEVELOPMEHT AND SCREENING OF ALTERNATIVES. . .
A. Statutory Requirements/Response Objectives
B. Technology and Alternative Development and
Screeninq . . . . . . . . . . . . . . ..' .
. . . .
. . . .
. . . .
VIII. DESCRIPTION OF ALTERNATIVES. . . . . . . . . .
A. Source Control (SC) Alternatives Analyzed. . . .
B. Manaqement of Miqration (MM) Alternatives
Analyzed. . . . .. . . . . . . . . . . . . .
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
X.
THE SBLECTED REMEDY. . . . . . . . . . . . . .
A. Interim Groundwater Cleanup Levels
B. Description of Remedial Components
. . . . .
. . . . .
. . . . .
XI.
STATUTORY DETERMINATIONS ...............
A. The Selected Remedy is Protective of Human Health
and the Environment. . . . . . . . . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . . .
The Selected Remedial Action is Cost-Effective
B.
C.
Paae
.~
1
1
1
4
5
5
6
6
7
8
8
9
12
13
13
14
20
20
20
21
21
21
42
49
49
52
58
58
59
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D.
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
TechDoloqies to the Maximum Extent Practicable
The Selected Remedy Satisties the Preterence tor
Treatment Which Permanently and Signiticantly
Reduces the Toxicity, Mobility or Volume ot the
Hazardous SUbstances as a Principal Element.
E.
XIII. STATE ROLE
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
. . . . .
APPENDICES
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E:
......................
Fiqures
Tables
ARARs Chart
Responsive summary
Index to the Administrative
Record
66
68
68
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1
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
ROD DECISION SUMMARY
SEPTEMBER 27, 1991
I.
SITE NAME, LOCATION AND DESCRIPTION
A.
General Description
The Savage Municipal Water Supply Superfund Site (Savage Well
site or Site) is located in the Town of Milford, New Hampshire
about two miles west of the center of town. See Figure 1.
The site includes a groundwater plume that extends from the
intersection of Route 101 and Elm Street eastward approximately
6,000 feet. It is roughly bounded on the north and east by the
Souhegan River and on the south by Elm Street and Tucker Brook.
The Savage Well Site lies within the floodplain of the Souhegan
River. The floodplain is a relatively flat land surface
extending through most of the area of the site. The Souhegan
River flows from west to east for the length of the site area.
At the eastern edge of the Site, the River takes a pronounced
southward bend before resuming its generally west to east
orientation. See Figure 2.
Residential, agricultural, heavy and light industrial, and
commercial land uses are found within the site. Residences are
located along Elm Street and Old wilton Road. A trailer park is
located to the north of Elm Street. Agricultural uses including
"a cornfield and a former sod farm dominate the central and
western portions of the site between Elm Street and the Souhegan
River. The heavy industrial uses are located between Elm Street
and Old Wilton Road east of Route 101. Light industrial and
commercial uses are generally found along Elm street.
. "
" .
The land use north of the Souhegan River (extending to North
River Road) is predominantly agricultural (corn and hay fields)
or forested. The forested areas are within the boundary of the
State's Milford Fish Hatchery. The Milford Fish Hatchery
provides trout for stocking New Hampshire ponds, lakes, and
rivers, and Atlantic salmon for Atlantic salmon restoration
efforts. Salmon raised in Milford are transported to the coast
for release. A private fish hatchery located at the eastern edge
of the Site raises trout. Residences are scattered along North
River Road.
B.
Bydroloqy and Geoloqy of the site
Three principal streams flow through the Site: 1) the largest
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2
northern portion of the Site: 2} Tucker Brook which flows from
the southwest corner of the Site through several wetland areas,
and eventually discharges to the Souhegan River at the eastern
end of the site: and 3} the unnamed stream which originates at
the Hitchiner and Hendrix facilities (and into which Hitchiner-
Hendrix process water has been discharged) and flows northeast
across the central portion of the site to the.Souhegan River.
Several smaller streams and Purgatory Brook are located north of
the Souhegan River. They flow south and discharge into the
River.
The unconsolidated overburden materials include thick (up to 130
feet) glacial outwash deposits. Locally those are overlain by
surficial alluvium and stream terrace deposits along the Souhegan
River and thin (less than 5 feet) layers of organic rich loam.
The glacial outwash deposits consist primarily of noncohesive
stratified fine to coarse sands and gravels. Lenses of silt and
fine sand have been observed at some locations but are not
common.
A very dense glacial till consisting of a poorly sorted"mixture
of fine to medium sand, gravel, silt, clay, and angular rock
fragments underlies the stratified sands and gravels. The till
layer varies in thickness from 2 to 15 feet and is present as an
aerially extensive layer or as isolated lenses along the bedrock
surface.. In the westernmost portion of the Site the till appears
to be thicker (up to 33 .feet) and can be subdivided into two
distinct types. A coarser, less compact gray to brown
discontinuous till layer directly overlies a characteristically
olive-green dense lower till. .
The stratified sands and gravels containing a minimal amount of
fine materials comprise a high yield and highly permeable
aquifer. By contrast the dense glacial till is a much less
permeable and transmissive stratum because of its compactness and
higher percentage of silt and other fine materials.
The bedrock aquifer underlying .the glacial outwash deposits is a
medium to coarse grained granite and diorite gneiss. The degree
of weatherinq and fracturinq in bedrock varies considerably
throughout the Site. At locations in the eastern portion of the
Site, little weathering and fracturing has been observed. For
the most part, weathering is typically less than 10 feet in
thickness and the intensity of fracturing appears to decrease
with depth. In the westernmost portion of the Site, the
weathered and fractured zone is approximately 30 to 40 feet
thick. .
Two significant features of the bedrock surface beneath the site
are (see Figure 3): 1) a narrow bedrock trough trending from the
vicinity of OK Tool eastward and ending in a broad basin
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3
and 20; and 2) a large broad depression northwest of the Site
situated between the Souhegan River and North River Road. East.
of the trough and basin feature, the bedrock surface is
relatively flat, dipping only slightly to the east. The bedrock
surface rises steeply toward the south-southeast of the Site
where.bedrock crops out. Bedrock is also found at or near the
land surface northwest and northeast of the Site.
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c.
4
Aquifer US.
The aquifer is a high yield aquifer. Past and present
groundwater usage indicates that large quantities of water will
be available from the aquifer in the future.
Seven large capacity production wells are currently withdrawing
or in the past have withdrawn groundwater from the aquifer. The
usage in gallons per day (qpm) is shown below unless otherwise
indicated:
WELL
Savage Well
Hendrix Well
Hitchiner Well
Granite State
Concrete
NHF&G Well # 4
NHF&G We:U # 5
Souhegan Valley
Aquiculture
Chemserve
RATE OF PRODUCTION(GPD)
(PERIOD OF USE)
180.000-240.000
1960-1983
WATER US~
Municipal Water
150,000-225,000
1000 aDd Dresent use
1974-1990
Industrial
360.000-400.00Q
1965-present
Variable
UD to 400aDm
1967-present
Industrial
Commercial seasonal
1. 152 . 000
1988-present
(pumped 720,000
1970-1988)
Fish Hatchery
1. 152 . OOQ
1988-present
pumped 720,000
1970-1988
Fish Hatchery
200.000
1989-present
Fish Hatchery
7.000 aal/month
1988-present-
potential yield is
17,000 gpd
Commercial
(Original purpose
was for purified
water production
Currently, the total groundwater use is approximately 2,900,000
gallons per day.
Other smaller capacity drinking water-wells are also located at
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5
provide water during the summer. This is the only well presently
used to SUpply drinking water within the Site area. The Milford
Mobile Home Park at one time obtained its drinking water from its
own Supply well. Its Use was discontinued in 1983 due to
contamination. Homes north of the SOuhegan River on North River
Road obtain their drinking water from dug wells or bedrock wells
located on their property. No estimates of total household use
for the area north of the River have been made.
A more complete description of the Site can be found in the
Remedial Investigation (RI) Report at pages 1-1 through 1-18 and
3-1 through 3-61.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
The Site and surrounding properties encompass four major. .
industrial facilities, the Savage Municipal Well, and two fish
hatcheries. Land Use varies from agricultural use to heavy
industrial use interspersed by residential and commercial
development.
Four major industrial plants are situated to the west of the
Savage Well: Hendrix Wire and Cable Corporation, Hitchiner
Manufacturing Company, OK Tool Company, and New England Steel
Fabricators, Inc. From the 1940s until the 1980s, process waters
and wastes from the four industrial facilities were released
untreated to the ground or to the surface waters flowing through
the Site.
In February, 1983, as part of the first routine sampling of water
supplies for organic compounds, the New Hampshire Water SUPply
and Pollution Control Commission (NHWS&PCC) found several
volatile organic compounds (VOCS) above drinking water standards
in water from the Savage Well. The VOCs found were: 1,1,1
Trichloroethane (TCA), Trichloroethylene (TCE), Trans-1,2
dichloroethylene (trans-1,2 DC~), TetrachloroethYlene (PCE), and
1,1 Dichloroethane (DCA). VOCs were also found in the water
drawn from the well Supplying the nearby Milford Mobile Home
Trailer Park. The VOCs found at the Mobile Home Park well were:
Tetrachloroethylene and Trans-1,2 dichloroethYlene. The State of
New Hampshire ordered the Town to cease use of the Savage Well in
February, 1983.
In March, 1983,. at the request of the State, EPA conducted an
emergency removal action to SUPply uncontaminated water to
residences of the Milford Mobile Home Trailer Park. EPA's
actions included SuPPlying bottled water to residents as an
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6
Trailer Park's water distribution system was connected to the
eXisting municipal water supply system.
The Site was proposed for inclusion on the EPA National
Priorities List (NPL) on September 1, 1983. The Site was
included on the final NPL on September 1, 1984.
B.
Enrorcam.nt History
On June 18, 1985, EPA notified four companies that either owned
or operated a 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. Negotiations commenced in July, 1985,
with those potentially responsible parties (PRPs) regarding the
performance of a Remedial.Investigation/Feasibility Study (RI/FS)
at the Site.
The PRPs formed a steering committee and substantial neg9tiations
occurred. A draft workplan for the Remedial Investigation/
Feasibility Study was completed by EPA and presented to the PRPs
and to the community. After receiving numerous comments from
federal and state agencies and the PRPs, the workplan was revised
by EPA to incorporate those comments and to conform with the NCP,
as amended in November, 1985. In January, 1987, EPA offered the
PRPs a final. opportunity to conduct the RI/FS in accordance with
the revised workplan. A draft Consent Order was sent to the PRPs
and the State in February, 1987. Following negotiations, the
PRPs signed an Administrative Order by Consent on June 10, 1987,
to perform the RI/FS.
The PRPs have been active in the remedy selection process for
this Site. The PRPs performed the RI/FS and were mailed a copy
of the Proposed Plan in July, 1991. Technical comments presented
by the PRPs as well as comments submitted by the public during
the p~lic comment period have been included in the
Administrative Record. A summary of those comments as well as
EPA's responses to them are included in the Responsiveness
Summary which is Appendix D of this document.
III. COKIDBITY PARTICIPATION
Throughout the Site's history, community concern and i~volvement
have been high. EPA has kept the community and other interested
parties apprised of the. Site activities through informational
meetings, fact sheets, press releases, and public meetings.
From 1983 to 1985, most of EPA's activity in the Town of Milford
related to the emergency action and to the search for and the
subsequent determination of the potentially responsible parties
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7
interaction at that time occurred among EPA, the state, and the
fouT. PRPs.
A public meeting was held in Milford on July 29, 1985. The
purpose of the meeting was to explain the RI process. At that
time the RI was to be a "fund lead" since the PRPs had not agreed
to perform the RI/FS. The study was interrupted due to the
Superfund reauthorization process and further negotiations with
th~ PRPs to perform the RI/FS. After lengthy negotiations the
PRPs signed an Administrative Order by Consent to perform the
RI/FS in June, 1987. The Order became effective in August, 1987.
During October, 1988, EPA released a community relations plan
which outlined a program to address community concerns and keep
citizens informed about and involved in the process. A Fact
Sheet was sent out to all interested parties in December, 1988,
which provided information on the RI/FS process and the status of
the site. On August 8, 1990, EPA held an informational meeting
in Milford at the Town Hall to discuss the results of the
Remedial Investigation.
On July 3, 1991, EPA distributed the Proposed Plan to all
interested parties. On July 12, 1991, EPA made the
Administrative Record available for public review at EPA's
offices in Boston and at the Wadleigh Memorial Library in
Milford. EPA published a notice and brief analysis of the
Proposed Plan in The Milford Cabine~ on July 10, 1991, and
the plan available to the public at the Wadleigh Memorial
Library.
known
made
On July 11, 1991, EPA held an informational meeting in Milford to
discuss the results of the cleanup alternatives presented in the
Feasibility Study and to present the Agency's Proposed Plan.
Also during this meeting, the Agency answered questions from the
public. From July 12 to August 10, 1991, the Agency held a
thirty day public comment period to accept public comment on the
alternatives presented in the Feasibility Study and the Proposed
Plan and on any other documents previously released to the
public.. On July 29, 1991, the Agency held a pUblic meeting in
Milford to discuss the Proposed Plan and to accept any oral
comments. A transcript of that meeting, the comments, and the
Agency's response to those comments are included in the attached
responsiveness summary.
IV.
SCOPE AND ROLE O~ RESPONSE ACTION
In summary, the remedy provides for the following: extraction
and treatment of contaminated groundwater from the aquifer, .
natural attenuation of contaminated groundwater located at the
downgradient area of the plume, and implementation of
institutional controls to prevent the use of contaminated
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8
remedial action will address the following threats to human
health and the environment posed by contamination at the Site:
1) the overall threat resulting from contamination of a potential
drinking water supply and 2) the threat of continued migration of
contaminated groundwater to other areas of the aquifer.
v.
SUMMARY OP SITE CHARACTERISTICS
Chapter 1 and Section 2.2.1 of Chapter 2 of the Feasibility
Study contain an overview of the Remedial Investigation. The
significant findings of the RI are summarized below.
A.
Soil
VOC contamination was found in soils at ten of thirteen suspected
source areas throughout the Site. The highest concentrations of
contamination were found between OK Tool Company and the Souhegan
River. Acetone was found at a maximum concentration of 310 parts
per billion (ppb) and tetrachloroethylene (PCE) at a maximum
concentration of 440 ppb. During the Feasibility Study (FS)
additional sampling was performed and VOC contamination continued
to be found in soils underneath the OK Tool, Hitchiner, and
Hendrix buildings. The levels of PCE beneath OK Tool ranged from
83 ppb to 2,400 ppb. Acetone was detected under the Hitchiner
facility at 22 ppb. Sampling of soils beneath and within the
Hendrix building indicated levels of 100 ppb. Based on modelling
it was determined that none of those soils contained levels of
VOCs high enough to pose a threat to groundwater quality if the
contamination leached from the soils to the groundwater. Chapter
2 and Appendix IX of the FS detail the modeling used to address
the threat of VOC contamination in the soils to the groundwater.
Very low levels of semi-volatile organic compounds (SVOCs) were
also detected.
Metal debris is present in soils at depths of one to five feet
below the ground surface between the northeast corner of the OK
Tool building and the Souhegan River. Analysis of the soils
indicates comparativ.ly elevated levels of a number of metals:
arsenic, 204 ppml total chromium, 15,100 ppml and lead, 610 ppm.
A second area of metal debris was found along the north side of a
nearby state owned lot adjacent to the SOuheqan River. The
levels of arsenic, total chromium, and lead are 42 ppm, 14,000
ppm, and 43 ppm respectively. Additional sampling conducted
during the FS and documented separately in the Administrative
Record shows that less than 10 ppm of the total chromium is
present in the more toxic hexavalent state.
Polychlorinated biphenyls (PCBs) were detected near the OK Tool
building (with~n the area of elevated metals discussed above) at
levels of 0.633 and 3.48 ppm. PCBs were also detected in one
sample location adjacent to the Hendrix facility at a
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9
B.
Groundwater
The VOC contaminated groundwater plume is shown in Figure 4. VOCs
are the most prevalent contaminants found in groundwater samples
from the site. The highest concentrations found are:
tetrachloroethylene (PCE) - 19,000 ppb; 1,1,1-trichloroethane
(TCA) - 1300 ppb; trichloroethylene (TCE) - 2,300 ppb; and 1,2-
dichloroethylene (1,2-DCE) - 1,500 ppb. Other VOCs detected less
frequently and at lower concentration are: l;l-dichloroethylene
(l,l-DCE) - 46 ppb; l,l-dichloroethane (1, I-DCA) - 110 ppb; and
methyl-t-butyl ether (MTBE) - 60 ppb. Table 1 presents a
statistical summary of analytical data for VOCs in the
groundwater.
Metals concentrations were found to be in excess of
respective MCLs at three locations. The locations,
concentrations of concern are as follows (locations
wells are shown in Figure 4):
their
metals, and
of monitoring
Monitoring Field
Location ~ Metal ConcentrationlDDb) MCLCDDb)
OK Tool M.I-24 Antimony 40 3 *
MI-25 Beryllium 32 1 *
Lead 160 15
Hitchiner MW-6A Arsenic 200 50
Beryllium 82 1 *
Chromium 141 100
Lead 110 15
Nickel 165 100
Hendrix MW-8A Antimony 20 3 *
Beryllium 27 1 *
Lead 75 15
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10
Beryllium was also found to exceed its MCL (proposed) at the
followinq locations:
~
Concentration (eeb)
1C
4A
6B
9C
10
16
lSA
19A
19B
20B
22
9
12
4
14
2
S
12
7
2
7
14
The observed VOC plume is approximately 6,000 feet lonq and 2,500
feet wide. The plume extends from the vicinity of OK Tool and
Hitchiner Manufacturinq in the west to the Souheqan River in the
east and from Old Wilton Road in the south to just north of the
Souheqan River in the north. PCE is the most widespread
contaminant and has the hiqhest concentrations of any of the VOCs
detected in qroundwater. Its distribution and extent mimics that
of total VOCs (see Fiqure 5). The distribution of TCA, also a
widespread contaminant present in hiqh concentrations, is shown
in Fiqure 6.
In qeneral, the qroundwater flows west to east at OK Tool and
then northeasterly in the eastern portion of the Site. The
currentconfiquration of the contaminant plume is the result of a
number of manmade influences in addition to natural qroundwater
flow patterns. Manmade influences include historical pumpinq at
the Hitchiner, Hendrix, and Savaqe wells. Based on hydraulic
and chemical data, it also appears that contaminated qroundwater
at the leadinq edqe of the plume flows beneath the Souheqan River
to the north side of the river. This may be due in part. to
qroundwater withdrawals at the Souheqan Valley Aquiculture .
Hatchery. Production wells at the State Fish Hatchery do not
appear to influence qroundwater flow south of the River but do
induce infiltration from the river and groundwater flow north of
the river. Analysis of the surface water-groundwater
relationship shows that some sections of all of the streams
within the Site lose water to the aquifer while other sections
qain water from the aquifer. Contaminated qroundwater is
discharqinq to the Souheqan River at the eastern portion of the
Site. The lenqth of the discharqe zone alonq the river varies
with the season of year and the amount of rainfall durinq each
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11
Groundwater sampling results indicate that PCE concentrations.
increase with depth in the unconsolidated aquifer. The highest
concentrations at multiple well cluster sites have been
consistently observed in wells screened at or near the bedrock
surface. In the central portion of the contaminant plume within
the bedrock channel, PCE contamination shows a twenty fold
increase in concentration with depth. The coincidental location
of the relatively narrow plume of concentrated VOCs with the
location of the bedrock channel suggests that the bedrock channel
may influence the migration of contaminants in a lateral
direction.
,
The FS divided the plume into two zones: the concentrated plume
and the extended plume. The concentrated plume includes the
areas near the OK Tool and Hitchiner facilities that contain the
highest concentrations of contaminants. VOC levels in those
areas are presently as high as 22,100 Ppb. The extended plume
includes the remainder of the contaminated groundwater which has
concentrations of contamination ranging from trace levels to
about 10,000 ppb. Contamination found to date has been dissolved
in the groundwater. However, high levels of VOCs found in the
concentrated plume suggest the presence of undissolved liquid
chemicals referred to as dense non-aqueous phase liquids
(DNAPLs).
Contamination was detected at several locations in the bedrock
aquifer. The shallow bedrock at the upper zone is weathered and
fractured. The fracturing becomes more intermittent and isolated
with increasing depth. Groundwater can readily move into and out
of the unconsolidated sediments above. Contaminant
concentrations in the bedrock aquifer are significantly lower
than those detected in the overlying overburden aquifer. MW-16R,
located in the bedrock channel, had the highest concentrations at
3,810 ppb of VOCs. The adjacent deep overburden well (See Figure
7 for the location of total VOCs in the bedrock), MW-16C, had VOC
concentrations of 6,400 ppb. The results of sampling at MW-31,
located north of the river approximately 4,800 feet downgradient
at the leading edge of the overburden plume, suggest that a
highly transmissive fracture zone may exist. The sampling
indicates that 13 ppb of TCE is present. At MW-30, located north
of the river at the western part of the Site, PCE was found in
concentrations from 80 ppb to 26 ppb. Because the overburden
aquifer is not contaminated at that location, the results appear
to indicate contaminant migration in low yield fractures that
intersect the open bedrock interval. .
Residences located on North River Road use bedrock and overburden
wells for drinking water purposes. Water quality data. from those
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'c.
Surface Water
VOCs were detected in surface water within the study area only in
samples collected from the NPDES-permitted Hitchiner-Hendrix
discharge stream. The single exception was the detection of low
levels of PCE, TCE, and 1,2-DCE in the surface water body
directly southwest of the Savage Well referred to herein as
Savage Pond. The VOCs detected in Savage Pond are likely derived
from the groundwater contaminant plume.
The highest total VOC concentrations, in excess of 400 ppb, were
found in samples collected from permitted outfalls at the
Hitchiner facility (SW-5, which discharges to the ponded area at
the upstream end of the stream) and the Hendrix facility (SW-19).
The most prevalent contaminants detected in surface water along
the Hitchiner-Hendrix discharge stream are acetone, TCA, and PCE
which were detected at maximum concentrations of 300 ppb, 260
ppb,and 29 ppb, respectively. VOC concentrations decrease
rapidly downstream from the outfalls, in large part due to
volatilization and dilution. .
The 1985 New Hampshire Water Supply and Pollution Control
Commission (NHWSPCC) Hydrogeological Investigation sampling
performed at Hitchiner outfalls (including the ponded area) in
1983 and 1984 indicated the presence of acetone at concentrations
up to 2,010 ppb, TCA at concentrations up to 1,800 ppb, and PCE
at concentrations up to 56 ppb. Other VOCs previously detected
include ~,l-DCA, 1,1-DCE, 1,2-DCE, TCE, methyl ethyl ketone,
methyl isobutyl ketone, toluene, and benzene. The outfall
locations are shown on Figure 8.
Concentrations of individual VOCs were at various times higher or
lower in discharge stream samples than in the Hitchiner .
production well. variatlons in reported concentrations may be
due to a number of factors including variations in sampling
methodologies and locations, variations in pumping rates, and
variations in discharge rates., ,
During the RI, acetone and TCA were detected in the upper portion
of the discharge stream (south of Elm Street) and in the lower
portion of the discharge stream (stations SW-8 and SW-9).
PCE has been detected downstream of the Hendrix outfalls and
throughout the length of the lower discharge stream at
concentrations less than 20 ppb. Other VOCs detected in the
Hendrix outfalls included TCA, toluene,'benzene, acetone,
styrene, acrolein, and MTBE. Permitted discharges from the
Hendrix facility ceased in March, 1990, when Hendrix installed a
process water recycling system. PCE concentrations detected
during the RI at MW-8 (10 to 74 ppb), located immediately.
upgradient of the Hendrix production well, were comparable and in
,some cases higher than concentrations in the Hendrixoutfalls (up
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13
by NHWSPCC prior to the RI also indicates higher PCE
concentrations in the production well than in the Hendrix outfall
or in the discharge stream downstream of Hendrix. other VOCs
were in some instances higher in the outfall and the discharge
stream and in some instances lower.
D.
Air
Ambient air monitoring detected low levels of acetone,. TCA,
methylene chloride, and PCE at the site. The detected values are
substantially below the Acceptable Ambient Air Levels (AALs), as
obtained from the New Hampshire Air Resources Agency.
E.
Sediment
VOCs were detected in stream sediments primarily at locations
adjacent to or immediately downstream of NPDES-permitted process
water outfalls from the Hitchiner facility. The principal VOC
contaminants detected in sediments were acetone, TCA, and
I,l-DCA. All are likely derived from process water discharges
from the Hitchiner facility as discussed above in regard to
surface water contaminants. Toluene and chloroethane were also
detected in sediments near the Hitchiner outfalls. Levels of
VOCs in sediments drop off rapidly further downstream from the
Hitchiner out falls. Acetone, PCE, and 1,2-DCE were also detected
in low levels in sediments at the Savage Pond, located
approximately 100 feet southwest of the Savage Well. TCE and
1,2-DCE detected at that location are likely derived from
groundwater recharge to the pond.
Several semi-volatile compounds (ABNs) were detected in sediments
along the upper portion of the discharge stream, with elevated
levels limited to sediments immediately downstream from the
Hitchiner outfalls. Fluoranthene and bis(2-ethylhexyl)phthalate
were the most commonly detected compounds and appear to be
derived from discharges from the Hitchiner facility.
A number of ABNs were also detected in sediments at the upstream
end of the Souhegan River. The source of those contaminants has
not been determined, but is clearly located upstream from the
study area.
During the sampling of surface water systems,
only in sediments immediately adjacent to the
at concentrations up to
6.5 mg/kg.
PCBs were detected
Hitchiner outfalls
A complete discussion of site characteristics can be found in the
Remedial Irivestigation Report at Pages 4-1 to 4-72 and 5-1 to
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14
VI.
SUKHARY OF SITE RISKS
A Risk Assessment(RA} 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
results of the public health risk assessment for the Savage
Municipal Well Site are discussed below followed by the
conclusions of the environmental risk assessment. .
Twenty-two contaminants of concern, listed in 'Tables 3 through 13
found in Appendix B of the ROD were selected for evaluation in
the risk assessment. Those contaminants constitute a
representative subset of the more than thirty contaminants
identified at the Site during the Remedial Investigation. The
twenty-two contaminants of concern were selected to represent,
potential site related hazards based on toxicity, concentration,
frequency of detection, and mObility and persistence in the
environment. A summary of the health effects of each of the
contaminants of concern can be found in Section 2.0 of the
Baseline Health Risk Assessment (the RA).
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypothetical exposure pathways. Those
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potenti~l future
uses, and location ot the Site. '
Excosure Pathw~vs
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of the following hypothetical exposure pathways:
- Future potential use of groundwater (household use and
drinking water)
- Future potential use of groundwater for irrigation
- Incidental ingestion and dermal contact with surface water
and sediment while wading in the trailer park brook and
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15
- Incidental ingestion and dermal contact with soils at the
OK Tool and Hitchiner/Hendrix properties
- Inhalation of contaminants monitored in ambient air
Exposure via ingestion of groundwater at the Milford Drive-In was
not evaluated because only one contaminant was detected at a very
low concentration and the exposure frequency is very low.
Those 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 more
thorough description can be found in Section 3.0 of the RA.
For each pathway evaluated, an average and a reasonable maximum
exposure (RME) estimate was generated corresponding to the
average and the maximum. concentration detected and estimated
exposure in that particular medium.
Future Residential Use of Groundwater
Since groundwater at the site is not being used currently as a
residential drinking water supply, only a future use scenario was
evaluated. Ingestion of 2 liters per day over a 70-year lifetime
was assumed for both average and RME estimates. Inhalation of
volatile contaminants during household use of water such as
showering was estimated as well.
Future Use of Groundwater for Irrigation
Volatile contaminants would be released to the ambient air if the
groundwater were used for irrigation of a proposed golf course.
Modeling was used to conservatively estimate ambient air
contaminant concentrations that would result and health risks
were estimated for a worker exposed 4 hours per day, 120 days per
year for 30 years. Only a RME scenario was considered as a
screening step.
Surface Water and Sediment
Trailer Park Brook
Children may be exposed to surface water while wading and to
sediment via incidental ingestion and dermal contact. Both
current and future risks were estimated assuming exposure
occurred 3 days per week for 6 months for 15 years (ages 2
through 16).
Hitchiner/Hendrix Discharge Stream
Risks to workers exposed to surface water and sediment were
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16
and a duration of 30 years. Future potential risks were
estimated for children using the same assumptions as for the
trailer park.
80i1s at OK Tool
Risks to children aged 2 through 16 who may trespass on the OK
Tool property under current use conditions were estimated.
Potential exposure via dermal contact was assumed to occur 30
days per year over the 15-year exposure period.
Risks for a future potential residential. use were estimated by
assuming that exposure would occur 160 days per year over a 70
year lifetime.
80i1s at Bitchiner/B8ndrix Properties
Potential risks to workers under t~e current industrial use
scenario were estimated. Exposure via dermal contact and.
incidental ingestion was assumed to occur 30 days per year
years.
for 40
Risks under a future potential residential scenario were
estimated assuming an exposure frequency of 100 days over a 70
year lifetime. .
Ambient Air
Exposure to ambient air contaminants under current conditions was
estimated. Exposure to measured ambient air concentrations was
assumed to occur 24 hours per day over a 70-year lifetime.
The Baseline Risk Assessment
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 carcinoqenic compounds. That is, the true risk is
very unlikely to be greater than the risk predicted. The
resulting risk estimates are expressed in scientific notation as
a probability (e.g. 1 x 10'6 for 1/1,000,000) and indicate (using
this example), that an. individual is not likely to have greater
than a one in a.million chance of developing cancer over 70 years
as a result. of site-related exposure as defined to the compound
at the stated concentration. Current EPA practice considers
carcinogenic risks to be additive when assessing exposure to a
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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 single 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 approximately one
third of an 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 produc~ liver damage should not be
added to a second whose toxic endpoint is kidney damage).
Tables 3-13 found in Appendix B depict the carcinogenic and non-
carcinogenic risk summary for the contaminants of concern for the
above pathways.
Results of Baseline Risk Assessment
ResideD~ial Use of GrouDdwa~er
The average and reasonable maximum exposure (RME) case carcinogenic
risks associated with the potential future household use and
consumption of groundwater were approximately 2 cancer cases in 1000
(2 x 10.3) and 2 cases in 10 (2 X 10'1) , respectively.
Tetrachloroethylene, arsenic, and beryllium comprised the majority of
the risk for both the average and RME scenarios. Tetrachloroethylene
comprised over 85% of the RME case risk. other chemicals which
contributed a risk of greater than one in a million were benzene: 1,1
dichlorethylene; 1,2 dichloroethane; methylene chloride: and
trichloroethylene.
The average and RME case Hazard Indices were 7.4 and 1400,
respectively. Tetrachloroethylene, lead and arsenic comprised the
majority of the Hazard Index (HI). Ingestion of those compounds may
cause damage to the liver, central nervous system, and skin,
respectively. Tetrachloroethylene comprised more than 90% of the HI
for the RME scenario.
Use of Groundwater for Irriqation
The RME case carcinoqenic risk associated with the potential future
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18
(9 X 10.7)" and the RME case HI for noncarcinoqenic compounds was less
than one.
Surface Water and Sediment at Trailer Park Brook
The average and RME case carcinogenic risks associated with exposure
via wadinq in surface water and incidental inqestion and dermal
contact with sediment under both current and future use of the
trailer park were aPJ?roximately one in a million (1 x 10'6) and 5 in
one million (5 x 10'). The Hazard Indices for both exposures were
well below one.
Surface Water and Sediment at the Hitchiner/Hendriz property
The averaqe and RME case carcinoqenic risks associated with current
use (worker exposure) to surface water and sediment were "
approximately one in a million (1 x 10.6) and four in one million
(4 x 10'6), respectively. The Hazard Indices for both exposures were
below one.
The averaqe and RME case carcinoqenic risks associated with future
residential use of the Hitchiner/Hendrix property were approximately
four in one million (4 x 10"6) and 1. 4 in 100,000 (1,4 X 10'5).
Arsenic and PCBs comprised the majority of the risk. The Hazard
Indices were below one for both exposures. "
soils at OK Tool Property - CUrrent Use
The averaqe and RME case carcinoqenic risks associated with current
use of the OK Tool Property (trespassinq) were approximately 8 in one
million (8 x 10-6) and 3 in 100,000 (3 x 10-5). Arsenic and PCBs
comprised the majority of the risk.
The averaqe and RME Hazard Indices were well below one.
soils at OK Tool Property - Future Use
The averaqe and RME case carcinoqenic risks associated with future
residential use of the OK Tool property were approximately 3 in
100,000 (3 x 10.5) and 2 in 10,000 (2 x 10-4), respectively. Arsenic
and PCBs comprised the majority of the risk.
The average Hazard Index for the future residential use was well
below one. The RME Hazard Index for arsenic slightly exceeded one
(1) for the toxic endpoint of keratosis (skin discoloration).
soils at the Hitchiner/Hendriz Property - CUrrent Industrial Use
The averaqe and RME case carcinoqenic risks associated with current
industrial use o"f the site were approximately one in a million (1 x
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19
Soils at the Bitchiner/Bendrix Property - Future Use
The average and RME case Hazard Indices were well below one.
The average and RME case carcinogenic risks associated with future
residential use of the Site were approximately one in 100,000 (1 x
10.5) and one in 10,000 (1 X 10."), respectively. PCBs comprised 85%
of the RME case risk.
The average and RME case Hazard Indices were both below one.
Ambient Air - Current Scenario
The average and RME case carcinogenic risks associated with exposure
to volatile compounds in the ambient air were approximately severt in
a billion (7 x 10.9) and seven in a million (7 x 10.6), respectively.
The Hazard Indices were well below one.
SummarY of Baseline Risk Assessment
The Baseline Risk Assessment showed that the average and RME case
carcinogenic risks associated with future potential residential use
of groundwater are outside EPA' s risk range of1 x 10-" to 1 X 10-6.
The chance of getting cancer from ingestion and household use of the
contaminated water over a 70 year lifetime ranges from an average of
2 in 100 (2 x 10.2) to 2 in 10 (2 x 10.'). This means that an
individual is not likely to have a greater than a 2 in 1000 to 2 in
1,00 risk of developing cancer as a result of exposure to groundwater
contaminants under the scenario defined above.
The Baseline Risk Assessment also indicated the potential for
adverse health effects other than cancer from lifetime exposure to
the contaminated groundwater. The HI for each of the following
chemicals exceeded one: tetrachloroethYlene, lead, and arsenic. This
means that contaminant levels exceed those levels that are likely to
be without an appreciable risk of an adverse health effect.
Tetrachloroethylene, lead and arsenic may affect the liver, central
nervous system, and skin, respectively.
Risks from exposure to other media were within EPA's risk range (10."
to 10-6) for carcinogenic compounds and met the hazard index goal of
one for compounds with noncarcinogenic effects. Lead levels in soil
are within EPA'sinterim guidelines for soil lead cleanup levels at
Superfund sites. Therefore no remedial actions are warranted with
respect to those other media.
Actual or threatened releases of hazardous substances from the Site
may present an imminent and substantial endangerment to public
health, welfare, or the environment if not addressed by implementing
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20
and substantial potential threat to public health could result from
drinking groundwater.
VII.
DEVELOPMENT AND SCREENING OP 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 which permanently and significantly
reduces the volume, toxicity or mobility of the hazardous substances
is a principal element over remedies not involving such treatment.
Response alternatives were developed to be consistent with these
congression~l mandates.
Based on preliminary information relating to types of contami-
nants, environmental media of concern, and potential exposure
pathways, remedial action objectives were developed to aid in the
development and screening of alternatives. Those remedial action
objectives were developed to mitigate existing and future potential
threats to public health and the environment. The response
objectives were:
Prevent ingestion of contaminated groundwater that would pose an
unacceptable risk to human health;
Restore groundwater quality to meet federal and state ARARs.
B.
TeOhnology and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial actions
are evaluated and selected. In accordance with those requirements, a
range of alternatives was developed for the Site. Those alternatives
are set forth in the Feasibility Study and the Addendum to the
Feasibility Study.
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. The FS Addendum evaluated three alternatives using a
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As discussed in Chapter 2 of the Feasibility Study, the RI/FS
identified, assessed, and screened technologies based on imple-
mentability, effectiveness, and cost. Those technologies were
combined into management of migration (MM) alternatives. Chapter 3
of the Feasibility Study and Section 3 of the Feasibility Study
Addendum presented the remedial alternatives developed by COmbining
the technologies identified in the previous screening process in the
categories identified in Section 300.430(e) (3) of the NCP. The
purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then evaluated
and screened in Chapter 3 of the FS and Section 3 of the FS Addendum.
In summary, of the seventeen remedial alternatives screened for
groundwater cleanup, ten were retained for detailed analysis. Three
alternatives were screened out and four alternatives entailed.
management strategies sUfficiently similar to other alternatives that
a separate analysis was not warranted. The three alternatives
evaluated in the FS Addendum have the same well location and pumping
rates as three of the alternatives in the FS. They differ only in
the treatment technology used, ultraviolet oxidation, which was not
evaluated in detail in the FS. Table 2 in Appendix B identifies the
10 alternatives that were retained through the screening process, as
well as those alternatives that were eliminated from further
consideration.
VIII.
DESCRIPTION OP ALTERNATIVES
This Section provides a narrative summary of each alternative
evaluated.
A.
Source Control
(SC) Alternatives Analyzed
The risks from exposure to potential contaminant source areas were
evaluated for carcinogenic compounds and non-carcinogenic compounds.
The risks-were found to be within EPA's risk range (10.4 to 10.6) for
carcinogenic compounds and also met the Hazard Index goal of one for
compounds with non-carcinogenic effects. In addition, contaminants
were not found at sufficiently high concentrations to contribute to
the overall groundwater contamination.
No source control actions are warranted for this Site.
B~
Management of Miqration (MM).Alternatives Analyzed
The development of the management of migration alternatives was done
using the available information, historical knowledge of the Site
area, and generally applied scientific approaches to solving
hydrogeologic issues. Extraction well locations and pumping rates
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22
time frames for cleanup of the aquifer reflects low and high
contaminant retardation factors used in modelling the aquifer. It is
not possible to determine precisely rates of contaminant movement
within the groundwater. The lower end of the range reflects
estimates of contaminant movement based on soil flushing tests
performed on soils from the Site. The upper end of the range is
based on published scientific studies. Portions of the aquifer where
concentrations are low may achieve MCLs in much less time than 30
years after treatment begins. .
Design studies will be performed prior to cleanup to determine the
number, pumping rate, and placement of extraction wells that will
most effectively capture, recover, and treat the contaminants.
Consideration of hydrodynamic controls which may be beneficial to
speeding the cleanup or directing the contaminant plume will also be
part of those studies. Hydrodynamic controls include but are not
limited to: recharge wells or ponds, withdrawal wells, sheet piling,
and slurry walls. Those studies would adjust the final design of the
extraction and treatment system to account for changes in location
and concentration of the plume that are likely to occur between now
and the beginning of treatment. Similarly, the exact location and
method of discharge for treated water may be altered if. n~gative
impacts on wetlands or agriculture in the area are predicted through
the design studies or become apparent after the cleanup has started.
An aspect of the design studies that will be further investigated is
the existence of DNAPLs within the concentrated plume area. The
presence of DNAPLs may alter cleanup time estimates of less than 30
years for the concentrated plume to an unknown length of time. Even
if DNAPLs are determined to be present, this remedy will initially
contain that portion of the plume containing DNAPLs so that the
remainder of the contaminated aquifer can be restored to beneficial
use. EPA may perform periodic reviews of advances in groundwater
cleanup technology to determine if new techniques have been developed
to effectively remediate DNAPL conditions. Consistent with CERCLA
and the NCP, EPA will determine whether any modifications to the
remedy are appropriate. .
Managementot migration alternatives address contaminants that have
migratedtrom the original source of contamination. At the Savage
Municipal Water Supply Site, contaminants have migrated from the west
to the east. Contamination that has miqrated to the upper bedrock
will be withdrawn using wells placed to remove the groundwater at
that zone. Contamination in the less fractured zone of bedrock is
expected to diminish as groundwater remediation progresses in the
shallow bedrock and overburden. Water quality in this deeper zone
will be monitored, and if it appears to be deteriorating, EPA will
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The Management of Migration alternatives evaluated for the site that
underwent detailed analysis in the FS and FS Addendum include:
MM-l
MM-2
MM-3
MM-7, 7A
MM-9, 9A
MM-10
MM-ll,llA
MK=.l
NO-ACTION
No-Action.
Limited Action, natural attenuation with institutional
controls, and long term groundwater monitoring.
Extraction and treatment of concentrated groundwater
plume at 400 gpm, natural attenuation of extended plume
with institutional controls.
Extraction and treatment of concentrated groundwater
plume at 400 gpm, extraction and treatment of a middle
portion of extended plume at 825 gpm, natural attenuation
with institutional controls.
Extraction and treatment of concentrated groundwater
plume at 400 gpm, extraction and treatment of a middle
portion of extended plume at 750 gpm, natural attenuation
with institutional controls.
Extraction and treatment of concentrated groundwater
plume at 400 gpm, maximum extraction and treatment of the
extended plume at 2,575 gpm, natural attenuation with
institutional controls.
Extraction and treatment of concentrated groundwater
plume at 400 gpm, extraction and treatment of extended
groundwater plume at middle portion at 600 qpm and at
end of plume at 100 gpm, natural attenuation with
institutional controls.
Management of Migration Alternative MM-l, No Action, consists of a
minimal comprehensive sampling and analysis program. Quarterly
sampling events are proposed to address groundwater, surface water,
and sediment. The sampling program would also include the periodic
sampling (annually at a minimum) of bedrock household drinking water
supplies north of the Soubegan River which are identified as possible
receptors of contaminated groundwater. site reviews would be
performed at five-year intervals to decide whether the program should
be expanded, reduced, or discontinued.
voc concentrations throughout the extended plume would increase as
more contaminants were released into the aquifer from the
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24
not known, EPA expects that the sampling and analysis program would
continue for more than 100 years.
The No Action alternative provides for continued monitoring only. It
has been retained and evaluated in detail to establish a baseline to
which all other alternatives are to be compared as required by the
NCP. This alternative will not meet ARARs in the foreseeable future.
It is not protective of human health or the environment.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present worth):
CONSTRUCTION: 0
Greater than
$ 0
$ 81,000
$ 763,579*
$ 763,579*
100 years
*
Based on 30 year present worth analysis.
KII::Z.
LIMITBD ACTION I NATURAL ATTBNUATION I INSTITUTIONAL CONTROLS I
LONG TBRM MONITORING
The Limited Action Alternative MM-2 provides for the entire plume to
naturally attenuate. No removal, containment, or treatment of the
groundwater would be performed. The alternative includes
institutional controls which provide for controlled and appropriate
restrictions on the use of the groundwater. Restriction and
management of the continued use of the contaminated portion of the
aquifer would be achieved through institutional controls, such as
deed restrictions, in the plume area in which the concentrations of
the compounds of concern are greater than the clean-up goals. VOC
concentrations throughout the extended plume would increase as more
contaminants were released into the aquifer from the concentrated
plume. As the contaminated plume would continue to migrate,
additional. areas would require institutional controls in the future.
The controls would remain in place until the groundwater cleanup
goals are met, which would be at least 100 years for this
alternative. The alternative would be protective as long as the
institutional controls are implemented and maintained. ARARs would
not be met in the foreseeable future.
The long-term monitoring program would determine groundwater
contaminant concentrations and the a~ount of contaminant migration.
Additional monitoring wells may be needed if the contamination
migrates beyond the current study area. The groundwater, surface
water, and sediments would be sampled and analyzed on a quarterly
basis for the presence of the following contaminants: VOCs, SVOCs,
metals, and Hazardous Substance List compounds. Reports assessing
the status of the Site would be done after every sampling event.
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25
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth) :
ESTIMATED TOTAL COST (Present worth) :
CONSTRUCTION: 0
Greater than
$ 0
$ 126,000
$ 1,183,642*
$ 1,183,642*
100 years
*
Based on 30 year present worth analysis.
MM-3
EXTRACTION AND TREATMENT OP CONCENTRATED PLUME AT 400 GPM / NATURAL
ATTENUATION OP EXTENDED PLUME / INSTITUTIONAL CONTROLS /
ENVIRONMENTAL MONITORING
Alternative MM-3 includes the following key components:
Concentrated Plume
Groundwater recovery from welles) pumping at approximately 250
gallons per minute (gpm) at O.K. Tool.
Groundwater recovery from welles) pumping at approximately 150 gpm
at Hitchiner.
Groundwater treatment: metals removal/air stripping/vapor phase
carbon.
Discharge to the Souhegan River and/or discharge to Hitchiner-
Hendrix discharge stream.
Institutional controls to restrict groundwater use.
Extended Plume
Natural attenuation of extended plume.
Institutional controls to restrict groundwater use.
Environmental Monitorina
Periodic monitoring of air, surface water, groundwater, and
sediments to ensure that public health and the environment are
being protected.
Operational monitoring of treatment plant air emissions, water
effluent, and residual wastes.
Alternative MM-3 consists of groundwater extraction and treatment at
the most highly concentrated areas of the aquifer. Two treatment
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26 .
located at OK Tool and the other plant will be located at Hitchiner.
Recovery wells, one to be sited at Hitchiner with an expected yield
of 150 qpm and the other at O.K. Tool with an expected yield of 250
qpm, will be designed to capture, contain, and remediate contaminants
migrating from areas of concentrated contamination at depth in the
aquifer within each of those areas (see Figure 9).
The precise number, pumping rate, and placement of extraction wells
so that the wells will most effectively capture and recover the
contaminated groundwater will be determined during the remedial
design phase. .
The extracted groundwater will be treated in plants located at OK
Tool and Hitchiner Manufacturing. Air stripping is the technology
that would be used in those plants. to treat the groundwater. Air
stripping removes VOCs by pumping contaminated groundwater to the top
of an air stripping tower and forcing air upward through the tower as
the water cascades down. VOCs evaporate into the moving air and'
clean water exits at the bottom of tne tower. The VOC-contaminated
air is then passed through activated carbon to remove the VOCs before
the air is released to the atmosphere. The contaminated carbon is
taken off site for regeneration in which the contaminants are
destroyed and the carbon recycled. .
Alternative MM-3 includes no active remediation efforts in the
extended plume. Instead, natural attenuation is employed.
Figure 10 illustrates the portions of the concentrated plume which
are recovered and treated and the portion of the extended plume which
is not recovered but is above the MCL for PCE and is allowed to
undergo natural attenuation. The same institutional controls
described in Alternative MM-2 will be implemented throughout the
aquifer where clean-up levels and/or MCLs are exceeded. Those
controls will remain in place until the groundwate~ cleanup goals are
met.
Discharge options for Alternative MM-3 include discharge to the
SOuheganRiver and/or discharge to the Hitchiner-Hendrix discharge
stream. In addition, a provision for hydrodynamic controls in the
o aquifer will be examined during design studies for the purposes of
decreasing the time of remediation and increasing protection for
environmental and agricultural uses within the Site area.
Alternative MM-3 will include construction of a discharge pipe or
structure either at the Souhegan River or at the existing Hitchiner-
Hendrix discharge stream which will have a short-term impact on a
minimum amount of wetland vegetation at the bank of the river or the
stream. Erosion control techniques and restoration of the stream or
river bank will minimize long-term impacts. No impacts to the
floodplain should be caused by the treatment structures because the
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27
The environmental monitoring program will determine contaminant
concentrations and the amount of contaminant migration in several
media. The monitoring plan will evaluate the effectiveness of the
remediation measures in the aquifer. Additional monitoring wells may
be needed. The groundwater will be sampled on a quarterly basis for
VOCs. Surface water and sediments may be sampled for contamination
on a less frequent basis. All media will be analyzed either annually
or semi-annually for the presence of SVOCs, metals, and Hazardous
Substance List compounds. The frequency of the sampling will be
determined during the remedial design phase. Household wells located
north of the Souhegan River which are used for drinking water
purposes will be sampled for VOCs annually at a minimum.
The effluent from the treatment plant will be sampled and analyzed as
necessary to ensure that ARARs are met. Air monitoring will be
performed to ensure that any discharge to the atmosphere by the
groundwater treatment plant meets ARARs. In addition, no treatment
residuals will be disposed of until those residuals are analyzed for
compliance with ARARs.
Reports assessing the status of the site will be done after every
sampling event. site conditions and the monitoring plan-will be re-
evaluated every five years.
The estimated time for restoration of the aquifer .in the concentrated
plume based on current data is 30 years (this assumes DNAPLs are not
present). For the extended plume which will undergo natural
attenuation, the aquifer should meet cleanup goals in 25 to 90 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 Years
ESTIMATED TIME FOR OPERATION: 25 to 90 Years
ESTIMATED CAPITAL COST: $ 1,100,000
ESTIMATED ANNUAL 0 &M $ 1,400,000
ESTIMATED 0 & M (Present Worth): $ 12,900,000*
ESTIMATED TOTAL COST (Present worth): $ 14,000,000*
*
Based on 30 year present worth analysis.
MM-7 AND MM-7A
EXTRACTION AND TREATMENT OF CONCENTRATED PLUME AT 400 GPM /
EXTRACTION AND TREATMENT OF EXTENDED PLUME AT 825 GPM / NATURAL
ATTENUATION OF EXTENDED PLUME / INSTITUTIONAL CONTROLS /
ENVIRONMENTAL MONITORING
Alternative MM-7 and MM-7A include the following key components:
Concentrated Plume
Groundwater recovery from welles) pumping at approximately 250 gpm
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28
Groundwater recovery from welles) pumpinq at approximately 150 qpm
at Hitchiner.
Groundwater treatment
For MM-7 - All treatment would be metals removal/air
strippinq/vapor phase carbon.
For MM-7A - Treatment at Hitchiner would be metals removal/air
strippinq/vapor phase carbon treatment. Treatment at OK Tool
would be metals removal/ultraviolet oxidation.
Discharqe to the SoUheqan River and/or discharqe to Hitchiner-
Hendrix discharqe stream.
Institutional controls to restrict qroundwater use.
Extended Plume
Groundwater recovery from four wells pumpinq at approximately 825
qpm.
Groundwater treatment
For MM-7 - Treatment would be metals removal/air
strippinq/vapor phase carbon. .
For MM-7A - Treatment would be metals removal/ultraviolet
oxidation.
Discharqe to the SoUheqan River.
Natural attenuation of portions of the extended plume not extracted
by the pumpinq scheme.
Institutional controls to restrict qroundwater use.
Environmental Monitoring
Periodic monitorinq Of air, surface water, qroundwater, and
sediments to ensure that public health and the environment are
beinq protected.
Operational monitorinq of treatment plant air emissions, water
effluent, and residual wastes.
Alternatives MM-7 and MM-7A provide for recovery of contaminated
qroundwater from the concentrated plume area, subsequent treatment of
that qroundwater, and discharqe to the Souheqan River or to the
Hitchiner-Hendrix discharqe stream. Two treatment plants will be
used to treat the concentrated. One plant will be located at OK Tool
and the other plant will be located at Hitchiner. Two recovery
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29
and the other sited at OK Tool with an expected yield of 250 qpm will
be designed to capture, contain, and remediate contaminants migrating
from areas of concentrated contamination at depth within the aquifer.
Alternative MM-7 uses air stripping as a technology at both treatment
plant locations while MM-7A uses ultraviolet oxidation in place of
air stripping at the OK Tool location.
Air stripping removes VOCs by pumping contaminated groundwater to the
top of an air stripping tower and forcing air upwards through the
tower as the water cascades down. VOCs evaporate into the moving air
and clean water exits the bottom of the tower. The VOC-contaminated
air is then passed through activated carbon to remove the VOCs before
the air is released to the atmosphere. The contaminated carbon is
taken off site for regeneration in which the contaminants are
destroyed and the carbon recycled.
Ultraviolet (UV) oxidation destroys the contamination in the
extracted groundwater by breaking down the VOCs into carbon dioxide,
water, and small amounts of chloride salts~ There are no air
emissions because the breakdown products remain dissolved in the
water.
Alternatives MM-7 and MM-7A provide for groundwater recovery at four
locations in the extended plume. Two wells would be located near the
edge of the 1,000 ppb plume and would pump at 'rates of approximately
200 gpm and 160 gpm. Additionally, the Savaqe Well would be used to
recover groundwater at 240 qpm and a fourth well would be located
northwest of the Savage Well with a yield of 225 qpm (see Figure 11)
for a combined pumpage of, 825 qpm. When that combined pumpage is
added to recovery of the concentrated plume, the resulting total
pumpage is 1,225 qpm. The location of the treatment plant treating
the contaminated groundwater from the extended plum~ is at the Savage
Well. Alternative MM-7 would use air stripping as a technology to
treat the contaminated qroundwater from the extended plume while
Alternative MM-7A would use UV oxidation.
The precise number, pumping rate, and placement of extraction wells
that will most effectively capture and recover the contaminated'
groundwater will be determined during the remedial design phase.
Figure 12 illustrates the capture zones superimposed on a total VOC
contour map and also illustrates the portions of the concentrated
plume which are recovered and treated, the portion of the extended
plume which is recovered and treated, and the portion of the extended
plume which is not recovered but is above the MCL for PCE and is
allowed to undergo natural attenuation. Institutional controls as
described in Alternative MM-2 will be implemented throughout the
aquifer where cleanup levels and/or MCLs are exceeded. The controls
will remain in place until the groundwater cleanup goals are met.
Discharge options for Alternatives MM-7 and MM-7A include discharge
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30
discharge stream. In addition a provision for hydrodynamic controls,
as discussed earlier, in the aquifer will be examined during design
studies for the purposes of decreasing the time of remediation and
for providing increased protection for environmental and agricultural
uses within the site area.
The environmental monitoring program will determine contaminant
concentrations and the amount of contaminant migration in several
media. The monitoring plan will evaluate the effectiveness of the
remediation measures in the aquifer. Additional monitoring wells may
be needed. The groundwater will be sampled on a quarterly basis for
VOCs. Surface water and sediments ~ay be sampled for contamination
on a less frequent basis. All media will be analyzed either annually
or semi-annually for the presence of SVOCs, metals, and Hazardous
Substance List compounds. The frequency of the sampling will be
determined during the remedial design phase. Household wells located
north of the Souhegan River which are used for drinking water.
purposes will be sampled for VOCs annually at a minimum.
The effluent from the treatment plant will be sampled and analyzed as
necessary to ensure that ARARs are met. Air monitoring will be
performed to ensure that any discharge to the atmosphere by the
groundwater treatment plant meets ARARs. In addition, no treatment
residuals will be disposed of until those residuals are analyzed for
compliance with ARARs.
Reports assessing the status of the Site will be done after every
sampling. event. Site conditions and the monitoring plan will be re-
evaluated every five years.
The estimated time for
plume based on current
are not present). For
groundwater extraction
the aquifer would meet
restoration of the aquifer in the concentrated
data is within 30 years (th~s assumes DNAPLs
the extended plume which will undergo
and treatment as well as natural attenuation,
cleanup goals in 15 to 65 years.
. These alternatives include construction of a discharge pipe or
structure at the Souhegan River and/or at the Hitchiner-Hendrix
discharge stream which will have a short-term impact on a minimum
amount of wetland vegetation. Erosion control techniques and
restoration of the river or stream bank will minimize long-term
impacts. The construction of wells and pipelines may impact wetlands
but that impact would be short term. The pumping of the extended
plume may impact wetland areas due to a .lowering of the groundwater
table. Since final well locations and withdrawal rates will be
determined during the design phase, a provision for the evaluation of
that possibility with protective measures such as recharge is
included. Although extraction wells and pipelines will be located
within the lOO-year floodplain, all construction within the
floodplain will meet the requirements of the pertinent ARARs. No
impacts to the floodplain should be caused by the treatment
-------
floodplain. ShoUld the necessity for structure relocation within the
floOdplain OCCUr during design, the structures will be constructed to
meet the require~ents of Executive Order 11988.
Alternative MM-7
31
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
Based on 30 year present Worth analysis.
2 Years
15 to 65
$ 2,500,000
.$ 2,000,000
$ 18,900,000*
$ 21,400,000*
Years
*
Alternative MM-7A
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present worth):
Based on 30 year present Worth analysis.
2 Years
15 to 65
$ 2,500,000
$ 1,500,000
$ 13,900,000*
$ 16,400,000*
Years
*
MH-9 and MH-9A
"REA" EN'1' OP CONCE RAn PL!!JI>: A" ... Gp "A.....",." OP ErrEIIDED
PL~ AT 750 GPM T~L ATTENUATION OP EXTENDED PL~
INSTITUTIONAL CONTROLS / ENVIRONMENTAL MONITORING
Alternative MM-g and MM-9A Include the fOllowing key components:
Concentrated Plu~
Groundwater recovery from welles) pumping at approximately 250 gpm
to remov~ contaminants and Contain migration from the concentrated
plume area at O.K. Tool.
Groundwater recovery from welles) pumping at approximately 150 gpm
to remove contaminants and contain migration from the concentrated
plume area at Hitchiner.
Groundwater treat~ent
For MM-g All treat~ent would be ~etals re~oval/air
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32
'For MM-9A Treatment at Hitchiner would be metals removal/air
stripping/vapor phase carbon. Treatment at OK Tool would be
metals removal and ultraviolet oxidation.
Discharge to the Souhegan River and/or discharge to
Hitchiner-Hendrix discharge stream.
~
Institutional controls to restrict groundwater use.
Extended Plume
Groundwater recovery from six wells at the downgradient end of the
extended plume with a total pumpage of approximately 750 gpm to
capture the width of the contaminant plume. .
Groundwater treatment
For MM-9 Treatment would be metals removal/air
stripping/vapor phase carbon.
For MM-9A
oxidation.
Treatment would be metals removal/ult~aviolet
Discharge t~ the Souhegan River.
Natural attenuation of portions of the extended plume not extracted
by the pumping schemes.
Institutional controls t9 restrict groundwater use.
Environmental Monitoring
Periodic monitoring of air, surface water, groundwater, and
sediments to ensure that public health and the environment are
being protected.
Operational monitoring of treatment plant air emissions, water
effluent, and residual wastes.
Alternatives MM-9 and MM-9A provide for recovery of contaminated
groundwater from the concentrated plume area, subsequent treatment of
that groundwater, and discharge to the Souheqan River or to the
Hitchiner-Hendrix discharge stream. Two treatment plants will be
used to treat the concentrated. One plant will be located at OK Tool
and the other plant will be located at Hitchiner. Two recovery
wells, one to be sited at Hitchiner with an expected yield of 150 gpm
and the other sited at OK Tool with an expected yield of 250 qpm will
be designed to capture, contain, and remediate contaminants migrating
from areas of concentrated contamination at depth within the aquifer.
Alternative MM-9 uses air stripping as a technology at both treatment
plant locations while MM-9A uses ultraviolet oxidation in place of
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33
stripping and UV oxidation are briefly described in Alternatives MM-7
and MM-7A.
Alternatives MM-9 and MM-9A provide for groundwater recovery at six
locations in the extended plume (see Figure 13). The wells are
intended to capture the entire width of the contaminant plume on the
south side of the river and are located parallel to the river. There
is no pumping of contaminated groundwater in the middle of the plume.
The recovery welles) in the extended plume pump at a total rate of
approximately 750 gpm. This combined with the recovery of the
concentrated plume, the total pump age is 1,150 gpm. The location of
the treatment plant treating the contaminated groundwater from the
extended plume is at the Savage Well. Alternative MM-9 uses air
stripping as a technology to treat the contaminated groundwater from
the extended plume while MM-9A uses UV oxidation.
The precise number, pumping rate, and placement of extraction wells
that will most effectively capture and recover the contaminated
groundwater will be determined during the remedial design phase.
Figure 14 illustrates the capture zones superimposed on a map of the
contaminant plume and also illustrates the portions of the
concentrated plume which are recovered and treated, the portion of
the extended plume which is recovered and treated, and the portion of
the extended plume which is not recovered but is above the MCL for
PCE and is allowed to undergo natural attenuation. Institutional
controls as described in Alternative MM-2 will be implemented
throughout the aquifer where cleanup levels and/or MCLs are exceeded.
The controls will remain in place until the groundwater cleanup goals
are met.
Discharge options for Alternatives MM-9 and MM-9A include discharge
to the Souhegan River and/or discharge to the Hitchiner-Hendrix
discharge stream. In addition a provision for hydrodynamic controls,
. as discussed earlier, in the aquifer will be examined during design
studies for ~he purposes of decreasing the time of remediation and
for providing increased protection for environmental and agricultural
uses within the site area. .
Alternatives MM-9 and MM-9A include construction of a discharge pipe
or structure at the Souhegan River and/or at the Hitchiner-Hendrix
discharge stream which will have a short-term impact on a minimum
amount of wetland vegetation. Erosion control techniques and
restoration of the river or stream bank will minimize long-term
impacts. The construction of wells and pipelines may impact
wetlands; however, that impact would be short term. The pumping of
the extended plume may impact wetland areas due to a lowering of the
groundwater table. Since final well locations and withdrawal rates
are to be determined in design, each alternative includes a provision
for evaluation of that possibility with protective measures such as
recharge included. Although extraction wells and pipelines will be
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34
floodplain will meet the requirements of the pertinent ARARs. No
impacts to the floodplain should be caused by the treatment
structures because the structures are not located within the
floodplain. Should the necessity for structure relocation within the
floodplain occur during design, the structures would be constructed
to meet the requirements of Executive Order 11988.
The environmental monitoring program will determine contaminant
concentrations and the amount of contaminant migration in several
media. The monitoring plan will evaluate the effectiveness of the
remediation measures in the aquifer. Additional monitoring wells may
be needed. The groundwater will be sampled on a qua~erly basis for
VOCs. Surface water and sediments may be sampled for contamination
on a less frequent basis. All media will be analyzed either annually
or semi-annually for the presence of SVOCs, metals, and Hazardous
Substance List compounds. The frequency of the sampling will be
determined during the remedial design phase. Household wells located
north of the Souhegan River which are used for drinking water
pUrposes will be sampled for VOCs annually at a minimum.
The effluent from the treatment plant will be sampled and analyzed as
necessary to ensure that ARARs are met. Air monitoring will be
performed to ensure that any discharge to the atmosphere by the
groundwater treatment plant meets ARARs. In addition, no treatment
residuals will be disposed of until those residuals are analyzed for
compliance with ARARs.
Reports assessing the status of the Site will be done after every
sampling event. Site conditions and the monitoring plan will be re-
evaluated every five years.
The estimated time for
plUme based on current
. are not present). For
groundwater extraction
the aquifer would meet
Alternative MM-9
restoration of the aquifer in the concentrated
data is within 30 years (this assumes DNAPLs
the extended plume which will undergo
and treatment as well as natural attenuation,
cleanup levels in 20 to 85 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 , M
ESTIMATED 0 , M (Present Worth):
ESTIMATED TOTAL COST (Present wort~):
2 Years
20 to 85 Years
$ 2,500,000
$ 2,000,000
$ 18,500,000*
$ 21,000,000*
*
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35
Alternative MM-9A
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR DESIGN AND CONSTRUCTION:
TIME FOR OPERATION:
CAPITAL COST:
ANNUAL 0 & M
o & M (Present Worth):
TOTAL COST (Present worth):
2 Years
20 to 85 Years
$ 2,600,000
$ 1,500,000
$ 13,700,000*
$ 16,300,000*
*
Based on 30 year present worth analysis.
MM-l0
EXTRACTION AND TREATMENT OF CONCENTRATED PLUME AT 400 GPM I
EXTRACTION AND TREATMENT OF EXTENDED PLUME AT 2575 GPM I NATURAL
ATTENUATION OF EXTENDED PLUME I INSTITUTIONAL CONTROLS I
ENVIRONMENTAL MONITORING.
Alternative MM-10 includes the following key components:
Concentrated Plume
Groundwater recovery from welles) pumping at approximately 250 gpm
O.K. Tool.
Groundwater recovery from welles) pumping at approximately 150 gpm
at Hitchiner.
Groundwater treatment (metals removal/air stripping/vapor phase
carbon) .
Discharge to the Souhegan River and/or discharge to Hitchiner-
Hendrix discharge stream.
Institutional controls to restrict groundwater use.
Extended .Plume
Groundwater recovery from 13 wells throughout the extended plume
pumping at approximately 2575 gpm.
Groundwater treatment: metals removal/air stripping/vapor phase
carbon.
Discharge to the Souhegan River.
Natural attenuation of portions of the extended plume not extracted
by the pumping scheme.
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36
Environmental Monitoring
Periodic monitorinq of air, surface water, qroundwater, and
sediments to ensure that public health and the environment are
beinqprotected.
Operational monitorinq of treatment plant air emissions, water
effluent, and residual wastes.
" ~
See. Alternative KK-3 for a full description and evaluation of the
components of Alternative KK-IO which capture the concentrated Plume
at the OK Tool and Hitchiner locations. Two treatment plants will be
used to treat the concentrated. One plant will be located at OK Tool
and the other plant will be located at Hitchiner.
Alternative KK-IO also provides for highly aggressive treatment of
the extended Plume (see Figure 15). The addition of thirteen wells
located throughout the extended plume captures the majority of the
extended plume and results in a reduction of contaminant
concentrations to cleanup levels in the rapid time frame of less than
30 years for the entire plume (this assumes DNAPLs are not present),
The thirteen wells in the extended plume have a cOmbined pumping rate
of 2,575 qpm. That.rate in cOmbination with the MH-3 wells results
in a total pumpage of 2,975 qpm. The greater number of wells and the
larger pumping volume are intended to decrease the time required to
reduce contaminants to cleanup levels.
The precise number, pumping rate, and placement of extracticn wells
that will most effectively capture and recover the contaminated
qroundwater will be determined durinq the remedial desiqn phase.
Figure 16 illustrates the capture zones superimposed on a map of the
contaminant plume. The figure also illustrates the portions of the
concentrated plume which are recovered and treated, the portion of
the extended plume which is recovered and treated, and the portion of
the extended Plume which is not recovered but is above the MCL for
PeE and is allowed to undergo natural attenuation. No extraction and
' treatment of contaminated qroundwater will be done north of the
SOuheganRiver. This alternative results in the capture of the plume
of contaminants greater than cleanup levels on the south side of the
river. Institutional controls as described in MH-2 will be
implemented throughout the aquifer where cleanup levels and/or MCLs
are exceeded. The controls will remain in place until the
qroundwater cleanup qoals are met.
Discharge options for Alternative MH-10 include discharge to the
Souhegan River and/or discharge to the Hitchiner-Hendrix discharge
stream. In addition a provision for hydrodynamic controls, as
discussed earlier, in the aquifer will be examined during design
studies for the purposes of decreasing the time of remediation and
for providing increased protection for environmental and agricultural
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37
Alternative MM-10 increases the treatment system at O.K. Tool to an
1,800 gpm system to handle additional flow from a portion of the
wells in the extended plume. The Hitchiner treatment system is the
same treatment system described in Alternative MM-3. The remaining
portion of groundwater flow from the extended plume, 1,175 gpm, is
treated at a treatment plant located at the Savage Well. The O.K.
Tool system is increased in size in order to accommodate the
additional flows (2,575 GPM) generated by this alternative. The O.K.
Tool system consists of two moderately sized systems rather than a
single larger system. The proximity of the wells to the O.K. Tool
facility makes that a more feasible alternative. All treatment
plants for Alternative MM-10 use air stripping as a technology to
remove contamination from the groundwater. The air stripping
technology is briefly described in Alternative MM-3.
This alternative includes construction of a discharge pipe or
structure at the Souhegan River and/or at the Hitchiner-Hendrix .
discharge stream which will have a short-term impact on a minimum
amount of wetland vegetation. Erosion control techniques and
restoration of the river or stream bank will minimize long-term
impacts. The construction of wells and pipelines may impact wetlands
but that impact will be short-term. The pumping of the extended
plume may impact wetland areas due to a lowering of the groundwater
table. Since final well and pipeline locations and withdrawal rates
are to be determined in design, a provision for an evaluation of the
possible impacts with protective measures such as recharge is
included. Although extraction wells and pipelines will be located
within the IOO-year floodplain, all construction within the
floodplain will meet the requirements of the pertinent ARARs. No
impacts to the floodplain should be caused by the treatment
structures because the structures are not located within the
floodplain. Should the necessity for structure relocation within the
floodplain occur during design, the structures would be constructed
to meet the requirements of Executive Order 11988..
The environmental monitoring program will determine contaminant
concentrations and the amount of contaminant migration in several
media. The monitoring plan will evaluate the effectiveness of the
remediation measures in the aquifer. Additional monitoring wells may
be needed. The groundwater will be sampled on a quarterly basis for
VOCs. Surface water and sediments may be sampled for contamination
on a less frequent. basis. All media will be analyzed either annually
or semi-annually for the presence of SVOCs, metals, and Hazardous
Substance List compounds. The frequency of the sampling will be
determined during the remedial design phase. Household wells located
north of the Souhegan River which are used for drinking water
purposes will be sampled for VOCs annually at a minimum.
The effluent from the treatment plant will be sampled and analyzed as
necessary to ensure that ARARs are met. Air monitoring will be
performed to ensure that any discharge to the atmosphere by the
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38
residuals will be disposed of until those residuals are analyzed for
compliance with ARARs.
Reports assessing the status of the Site will be done after every
sampling event. Site conditions and the monitoring plan will be re-
evaluated every five years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION: Less Than
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present worth):
2 Years
30 Years
$ 5,100,000
$ 4,200,000
$ 39,200,000*
$ 44,300,000*
*
Based on 30 year present worth analysis.
MM-ll AND MM-IIA
E=~~= :: g::J:r- ~L:C:;:"1~~:t~ .:: :~ ~~~~
::~:=:A~P M~:TORI~G PL / IN TITUT ON L CONTRO S I
Alternatives MM-ll and MM-llA include the following key components:
Concentrated Plum,
Groundwater recovery from welles) pumping at approximately 250 gpm
to contain migration from the source area at O.K. Tool.
Groundwater recovery from welles) pumping at approximately 150 gpm
to contain migration from the source area at Hitchiner.
Groundwater treatment
For MM-ll All treatment would be metals removal/air
stripping/vapor phase carbon.
For MH-l1A Treatment at Hitchiner would be metals removal/air
stripping/vapor phase carbon. Treatment at OK Tool would be
metals reaoval and ultraviolet oxidation.
Discharge to the Souhegan River and/or discharge to Hitchiner-
Hendrix discharge stream.
Institutional controls to restrict groundwater use.
Extended Plum,
Groundwater recovery from two wells pumping at approximately 300
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39
Groundwater recovery from two wells pumping at approximately 50 gpm
at the end of the extended plume to the north of the Souhegan
River.
Groundwater treatment
For MM-11 All treatment would be metals removal/air
stripping/vapor phase carbon.
For MM-11A
oxidation.
All treatment would be metals removal/ultraviolet
Discharge to the Souhegan River.
Natural attenuation of portions of the extended plume not extracted
by the pumping scheme.
Institutional controls to restrict groundwater use.
Environmental Monitorina
periodic monitoring of air, surface water, groundwater, and
sediments to ensure that public health and the environment are
being protected.
Operational monitoring of treatment plant air emissions, water
effluent, and residual wastes.
Alternatives MM-11 and MM-11A provide for recovery of contaminated
groundwater from the concentrated plume, subsequent treatment of that
groundwater, and discharge to the Souhegan River and/or to the
Hitchiner-Hendrix discharge stream. Two treatment plants will be
used to treat the concentrated. One plant will be located at OK Tool
and the other plant will be located at Hitchiner. Recovery wells,
one to be sited at Hitchiner with an expected yield of 150 gpm and
the other sited at OK Tool with an expected yield of 250 gpm will be
designed to capture, contain, and remediate contaminants migrating
from areas of concentrated contamination at depth within the aquifer.
Alternative MM-1l uses air stripping as a technology at both plant
locations while MM-11A uses ultraviolet oxidation in place of air
stripping at the OK Tool location. The two technologies of air
stripping and UV oxidation are briefly described in Alternatives MM-7
and MM-7A.
Alternatives MM-11 and.MM-11A provide for recovery and treatment of
the extended plume through: 1) two recovery wells pumping at 300 gpm
each in the central portion of the extended plume to recover the
entire width of the plume at that point (one of those wells is
located at the. location of the Savage Well); and 2) two recovery
wells located on the north side of the Souhegan River pumping at
approximately 50 gpm each to recover and prevent further migration of
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40
plant treating 'contaminated groundwater from the extended plume is at
the Savage Well. Alternative MM-11 uses air stripping as a
technology to treat the contaminated groundwater from the extended
plume while Alternative MM-11A uses ultraviolet oxidation.
The recovery welles) in the extended plume pump at a total of
approximately 700 qpm which in combination with the wells in the
concentrated plume results in a total pumpage of 1,100 qpm.
The precise number, pumping rate, and placement of extraction wells
that will most effectively capture and recover the contaminated
groundwater will be determined during the remedial design phase.
Figure 18 illustrates the capture zones superimposed on a map of the
contaminant plume. The figure also illustrates the portion of the
concentrated plume which is recovered and treated, the portion of the
extended plume which is recovered and treated, and the portion of the
extended plume which is not recovered but is above the MCL for PCE
and is allowed to undergo natural attenuation. Institutional
controls as described in Alternative MM-2 will be imple~ented
throughout the aquifer where cleanup levels and/or MCLs are exceeded.
The controls will remain in place until the groundwater cleanup goals
are met.
Discharge options for Alternatives MM-11 and MM-llA include discharge
to the Souhegan 'River and/or discharge to the Hitchiner-Hendrix
discharge, stream. In addition a provision for hydrodynamic controls,
as discussed earlier, in the aquifer will be examined during design
studies for the purposes of decreasing the time of remediation and
for providing increased protection for environmental and agricultural
uses within the site area.
These alternatives also retain the possibility of adding a vertical
barrier, which could consist of sheet piling, a slurry wall, or
recovery/injection wells. The barrier would be located along Elm
,street to the east of the Hendrix facility (see Figure l8)~ The
intent of the barrier would be to minimize the capture of cleaner
water to the south of Elm Street by the recovery well located at the
Savage Well. The vertical barrier is not included in the cost
estimate but is retained as a potential future option.
These alternatives include construction of a discharge pipe or
structure at the Souhegan River and/or at the Hitchiner-Hendrix
discharge stream which will have a short-term impact on a minimum
amount of wetland vegetation. Erosion control techniques and
restoration of the river or stream bank will minimize long-term
impacts. The construction of wells and pipelines may impact wetlands
but that impact will be short-term. The pumping of the extended
plume may impact wetland areas due to a lowering of the groundwater
table. since final well locations and withdrawal rates are to be
determined in design, a provision for an evaluation of that
-------
Although extraction wells and Pipelines will be located within the
lOO-year floodplain, all construction within the floodplain will meet
the requirements of the pertinent ARARs. No impacts to the
floodplain should be caused by the treatment structures because the
structures are not located within the floodplain. ShoUld the.
necessity for structure relocation within the floodplain OCCUr during
design, the structures would be constructed to meet the requirements
of Executive Order 11988.
41
The environmental monitoring program will determine contaminant
concentrations and the amount of contaminant migration in several
media. The monitoring plan will evaluate the effectiveness of the
remediation measures in the aquifer. Additional monitoring wells may
be needed. The groundwater will be sampled on a quarterly basis for
VOCs. Surface water and sediments may be sampled for contamination
on a less frequent basis. All media will be analyzed either annually
or semi-annually for the presence of SVOCs, metals, and Hazardous
Substance List compounds. The frequency of the sampling will be
determined during the remedial design phase. HOUSehold wells located
north of the SOUbegan River which are Used for drinking Water
purposes will be sampled for VOCs annually at a minimum..
The effluent from the treatment piant will be sampled and analyzed as
necessary to ensure that ARARs are met. Air monitoring will be
performed to ensure that any disCharge to the atmosphere by the
groundwater treatment plant meets ARARs. In addition, no treatment
residuals will be disposed of until those residuals are analyzed for
compliance with ARARs.
Reports assessing the status of the Site will be done after every
sampling "event. Site conditions and the monitoring Plan will be re-
evaluated every five years.
The estimated time for
plume based on current
are not present). For
groundwater extraction
the aquifer. would meet
restoration of the aquifer in the concentrated
d~ta is within 30 years (this assumes DNAPLs
the extended plume which will undergo
and treatment as well as natural attenuation,
cleanup goals in 15 to 60 years.
Alternative HK-11
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNuAL 0 & H
ESTIMATED.O & H (Present Worth):
ESTIMATED TOTAL COST (Present worth):
Based on 30 year present Worth analysis.
CONSTRUCTION: 2 Years
15 to 60 Years
$ 2,200,000
$. 1,900,000
.$ 18,000,000*
$ 20,200,000*
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42
Alternative MM-11A
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED ANNUAL 0 & M
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present worth):
CONSTRUCTION: 2 Years
15 to 60 Years
$ 2,400,000
$ 1,400,000
$ 13,100,000*
$ 15,500,000*
*
Based on 30 year present worth analysis.
IX.
SUMKARY 01' '1'BB COMPARATIVE ANALYSIS 01' ALTERNATIVES
Section l2l(b) (1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. Building upon those 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: .
Threshold Criteria
The two threshold criteria described below must be met in order for
the alternatives to be eligible for selection in accordance with
the NCP.
1.
Overall protection of human health and the environment
addresses whether or not a remedy provides adequate.
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled ~hrough
treatment, engineering controls, or institutional
controls.
2.
Coapliance with Applicable or relevant and appropriate
r.quir...nts (ARAR8) addresses whether or not a remedy
will meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking a
waiver.
primarY Balancina Criteria
The following five criteria are utilized to compare and evaluate
the elements of one alternative to another that meet the threshold
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43
3.
Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for the
long-term effectiveness and permanence they afford, along
with the degree of certainty that they will prove
successful.
4.
Reduction of toxicity, mo~ility, or volume through
treatment addresses the degree to'which alternatives
employ recycling or treatment that reduces toxicity,
mobility, or volume, including how treatment is used to
address the principal threats posed by the site.
5.
Short term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be poseddurinq
the construction and implementation period, until cleanup
goals are achieved.
6.
Implement~ility addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option.
Cost includes estimated capital and operation Maintenance
(O&M) costs, as well as present-worth costs.
7.
Modifvina criteria
The modifying criteria are used in the final evaluation of remedial
alternatives generally after EPA has received public comment on the
RI/FS and Proposed Plan.
8.
State acceptance addresses the state's position and key
. concerns related to the preferred alternative and other
alternatives, and the state's comments on ARARs or the
'proposed use of waivers.
comaunity acceptance addresses the public's general
response to the alternatives described in the Proposed
Plan and RI/FS report. .
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
alternative against the nine criteria, was conducted.
9.
The section below presents the nine'criteria and a brief narrative
summary of the alternatives and the strengths and weaknesses
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44
1.
Overall Drotection of human health and the environment
As discussed in the Summary of Site Risks above, the potential
future risks posed to human health from future exposure to
contaminated groundwater are outside of EPA's acceptable risk
range. With the exception of Alternative MM-1, the site-wide
alternatives evaluated in Section 4.0 of the FS Report are
considered protective of human health and .the environment.
Alternative MM-1, No Action, does not utilize adequate controls to
prevent exposure to the contaminated groundwater during the
restoration time period, which is estimated to be greater than 100
years.
Alternative MM-2, Limited Action, attains a threshold level of
protection because institutional controls prevent future use of the
contaminated groundwater. The use of institutional controls
prevents use of the groundwater until cleanup levels are met, which
is estimated to be greater than 100 years. Because the plume will
continue to migrate and contaminate new portions of the aquifer, it
will be necessary to place institutional controls on additional
pieces of property.
.~
The remaining alternatives provide protectiveness through capture
and treatment of the contaminated groundwater and institutional
controls restricting the use of the contaminated groundwater.
2.
ComDliance with ARARs
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific, and location-specific ARARs.
The ARARs are presented in Table XX in Appendix x. All
alternatives, with the exception of Alternative MM-1, NO-Action,
and Alternative MM-2, Limited Action, comply with ARARs. With the
exception of Alternatives MM-1 and MM-2, all of the alternatives
attain cleanup levels in groundwater based upon protective
chemical-specific ARARs and to-be-considered standards (TBCs).
Alternative 10 meets ARARs in the least amount of time, less than
30 years. Alternative MM-3 takes the longest of the active
remediation alternatives with a range of 25 to 90 years.
Alternatives MM-7, MM-7A, MM-9, MM-9A, MM-ll, and MM-IIA meet ARARs
in a time' frame ranging from 15 to 85 years.
Alternatives MM-1 and MM-2 do not comply in the short term with
MCLs and MCLGs este~lished in the,Safe Drinking Water Act, MCLs
established in RCR;,. and the NH MCLs established in the NH
Administrative Code Part WS 315-319. Both alternatives eventually
would meet ARARs but it would take more than 100 years.
Mitigation and restoration measures will be required to limit
potential impacts in disturbed wetland areas and to meet wetlands
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45
the least impact on the wetlands during construction and subsequent
operation because that alternative requires the least amount of
construction activity and the lowest volume of groundwater
withdrawal.
Construction activities and pumping volumes associated with
Alternatives MM-9, MM-9A and MM-10 have the greatest potential
impact on the wetlands because they require the greatest number of
wells, pipes, and volumes of groundwater withdrawal.
3.
Lona Term Effectiveness and Permanence.
All of the alternatives are effective in aChieving long term
protection of the groundwater after the groundwater is restored to
interim cleanup levels by either natural attenuation and/or
treatment. No residual risk will remain at the Site.
All of the active treatment alternatives provide for capture and
treatment of the concentrated plume; Thus, the reduction in
mobility of contamination in the concentrated plume depends on the
reliability of the extraction system being implemented. Those
systems (extraction and hydrodynamic controls) are generally
reliable and effective for the required operations. Alternatives
MM-7 through MM-1LA provide various levels of long term
effectiveness greater than Alternatives MM-l, MM-2, or MM-3 based
on the rapidity of the cleanup time. Alternative MM-lO provides
the most rapid cleanup, less than thirty years. Alternatives MM-7,
MM-7A, MM-9, and MM-9A take longer than Alternatives MM-10, MM-11,
and MM-lLA.
. All of the alternatives have a component of restoration which
relies on natural attenuation. Alternatives MM-1 and MM-2 rely
exclusively on natural attenuation processes such as
volatilization, dispersion, and biodegradation. Those processes
require the greatest amount of time, over 100 years, to attain
clean~ levels and to reduce potential future risks to within an
acceptable range. In addition, the degree of certainty associated
with the estimate of the time needed to attain those levels is
lowest. Neither alternative provides a means for limiting
continued migration of the contaminants from the concentrated plume
to the extended plume, or continued expansion of the extended
plume. Those two alternatives rank lowest among the alternatives
in terms of long-term effectiveness.
The treatment technologies used in the alternatives utilizing
treatment achieve a high degree of permanence in remediating the
groundwater. Both air stripping with carbon filtration and UV
oxidation permanently destroy the contaminants removed from the
groundwater. The alternatives designated using "A" use UV
oxidation to treat a portion of the groundwater: that technology
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46
stripping destroy the contaminant when the activated carbon is
regenerated.
4.
Reduction of toxicitv. mobilitv. or volume throuah treatment
The alternatives other than MM-1 and MM-2 actively
aquifer through groundwater capture and treatment.
reduction of the toxicity, mobility, or volume are
to the amount of the plume that is captured by the
wells.
restore the
The degree of
directly related
extraction
Alternative MM-10 captures the greatest areal extent of the plume
and allows the least amount of natural attenuation treating an
estimated 13,000 Ibs of VOCs in the first year of operation.
Alternatives MM-7 and MM-7A capture contaminated groundwater in the
middle of the extended plume and reduce the toxicity, mobility, and
volume of contaminants greater than 1,000 ppb. The estimated
amount of contamination treated is 2,290 Ibs in the first year of
operation. There is no reduction of toxicity, mobility, or volume
through treatment in the portion of' the plume that is not captured.
Alternatives MM-9 and MM-9A capture and treat almost the entire
width of the extended plume south of the river. There is no
capture of contaminated groundwater in the middle of the plume.
The estimated amount of contamination treated during the first year
is 2,000 lbs per year.
Alternatives MM-11 and MM-11A capture contaminated groundwater in
the middle of the plume and at the end of the plume north of the
river with concentrations above 500 ppb. The estimated amount of
VOCs to be treated during the first year of operation is 2,220 Ibs.
The areal extent of contamination captured is more than is captured
in Alternatives MM-7 and MM-7A but less than that captured in
Alternatives MM-9, MM-9A, and MM-10. The estimated amount of
contamination treated is greater than that treated in Alternatives
MM-3, MM-9 and MM-9A, less than that treated in Alternative MM-10,
and about the same as that treated in Alternatives MM-7 and MM-7A.
Of all of the treatment alternatives, Alternative MM-3 captures the
least amount of the areal extent of the plume, captures the most
concentrated portion of the plume, and allows the greatest amount
of the plume to underqo natural attenuation. The estimated amount
of VOCs treated during the first year of operation is 1,920 Ibs.
Alternative MM-3 does not provide treatment for the extended plume.
Alternatives MM-l and MM-2 provide no reduction through treatment
in voc toxicity, mobility, or volume. However, the level of
toxicity will decrease over time through the natural attenuation
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47
5.
Sbort Term Effectiveness
For all alternatives, the short term risks to the community include
the risks posed from residential use of the groundwater during
restoration. Since Alternative MM-l does not achieve protection of
human health or the environment, it is also not effective in the
short term. Alternative MM-2 provides no controls on the spread of
contamination into portions of the aquifer that are used currently
for drinking water. Therefore, Alternative MM-2 poses short-term
risks to the community. However, since Alternative MM-2 requires
no construction, it poses no short-term risks to human health or to
the environment from construction.
None of the alternatives are e~pected to significantly
health during construction. The treatment methods are
to have any adverse impact on the local community, nor
trained workers.
affect human
not expected
on properly
Although wetlands and floodplains will be disturbed by the
construction of pipes and wells, the impact will be minimized.
Alternative MM-3 has the least impact during construction.
Construction activities for Alternatives MM-9, MM-9A, and MM-IO
have the greatest impact on the wetlands because they require the
largest number of wells. Any adverse impacts on groundwater flow
to the wetlands or local agriculture will be minimized by altering
the method of discharge from the treatment plants.
All of the treatment alternatives meet cleanup objectives in the
extended plume but in different time frames. Alternative MM-IO
requires the shortest period of time to meet the cleanup
objectives. Alternatives MM-3, MM-9, and MM-9Atake longer than
Alternatives MM-7 and MM-7A which take longer than Alternatives
MM-IO, MM-ll, and MM-llA. All of the treatment alternatives
achieve the cleanup objectives in the concentrated plume in less
than 30 years if DNAPLs are not present.
6.
ImDlementability
Alternative MM-l raises no issues regarding implementability
because no action is taken. Alternative MM-2 raises no issues
regarding technical feasibility since institutional controls are
the only action taken. However, the administrative feasibility of
the institutional controls must be considered. Alternative MM-2
requires the most wide-spread and lengthy program of institutional
controls. If contaminants were to spread to wells currently in
use, additional institutional controls would be needed. In
addition, the reliability of institutional controls may decrease
over long periods of time because enforcement is difficult. The
use of institutional controls is less extensive and of shorter
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48
Significant limitations in implementability were generally not
identified for the treatment alternatives. The technologies are
proven, reliable, and readily implementable. Although there is
increasing engineering and operational complexity as the number of
wells and total pumping rates increase, the degree of change is
well within normal engineering management practice.
7.
Cost
'. .
A comparison of the present worth value of each alternative is
presented below:
Capital 0 & M Costs
Alternative Costs Present Worth*
Alternative 1 $ 0 $ 764,000
Alternative 2 0 1,200,000
Alternative 3 1,100,000 12,900,000
Alternative 7 2,500,000 18,900,000
Alternative 7A 2,500,000 13,900,000
Alternative 9 2,500,000 18,500,000
Alternative 9A 2,600,000 13,700,000
Alternative 10 5,100,000 39,200,000
Alternative 11 2,200,000 18,000,000
Alternative 1lA 2,400,000 13,100,000
*
Based on 30 year present worth analysis.
8.
. State AcceDtance
Total
Present Worth*
$ 764,000
1,200,000
14,000,000
21,400,000
16,400,000
21,000,000
16,300,000
44,300,000
20,200,000
15,500,000
The New Hampshire Department of Environmental Services (NHDES) has
been involved with the Site from the time of the discovery of
contamination. Throuqh a Cooperative Aqreement, the NHDES performed
oversight of field activities and provided laboratory services for
split samples. The State has also reviewed and provided comments on
the interim reports during the RI/FS as well as the final Remedial
Investigation, the Risk Assessment, and the Feasibility Study. NHDES
also provided a listing,of state ARARs for use in the development of
the alternatives for the Feasibility Study. NHDES has not commented
on nor concurred with this Record of Decision.
r'
During the public comment period, the New Hampshire Department of
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49
farm land within the site. The state has bought the development
rights to insure through a protective easement that about 69 acres of
land within the site remains in agricultural use. The state's
concern is that the selected remedy include provisions to address the
goal that the land remain suitable for agricultural use.
9.
Communitv AcceDtance
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. The informational meeting for the
Proposed Plan was attended by over 200 people. Thirty-six persons
provided oral comments at the public hearing which was attended by
more than 200 persons. Forty-one sets of written comments were
received during the comment period.
There have been opinions expressed both in favor of and against the
remedy. The Town of Milford has stated that there is no future risk
associated with the contaminated groundwater because nobody will be
using the water in the future. The Town believes that they. have an
adequate water supply for the foreseeable future so that there is no,
need for a rapid and expensive cleanup. The Town also believes
that the best use of the aquifer is for industrial and commercial
uses and not for drinking water.
In general, the community is concerned that any solution be balanced
and have no unfavorable economic impact on the Town. In particular,
the community prefers a remedy that causes no harm to the Town, its
taxpayers, or its tax base. .
x.
THE SBLECTBD RBKBDY
EPA has selected Alternative ll-A as the remedy for the Savage
Municipal Water Supply Site. That alternative encompasses extraction
and treatment with natural attenuation for the contaminated
~roundwater as well as institutional controls for groundwater use.
It is a comprehensive remedy since no source control component is
necessary. . .
A.
Interia GroUD4vater Cleanup Levels
Interim cleanup levels have been established in groundwater for
contaminants of concern identified in the baseline risk assessment
and found to pose an unacceptable risk to either public health or
the environment. Interim cleanup levels have been set based on
either the pertinent.ARARs (e.g. drinking water MCLGs and MCLs) or
other suitable criteria described below. EPA will make periodic
assessments of the protection afforded by the remedial action as
the remedy is being implemented and at the completion of the
remedial action. At the time that all groundwater ARARs identified
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50
call into question the protectiveness of the remedy have been
achieved, a risk assessment shall be performed on all 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. These final protective cleanup levels shall be
performance standards for the ROD.
1.
Groundwater
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
because the MCLGs for those compounds are zero. Interim cleanup
levels for the Class C compounds (possible carcinogens) have been
set at the non-zero MCLG. In the absence of an MCLG, or an MCL, or
a proposed drinking water standard, or other suitable criteria to
be considered (i.e. health advisory, state standard), a clean~
level has been derived for carcinogenic effects based on a 10.
excess can~er risk level considering the ingestion of ground water.
Interim cleanup levels for compounds in groundwater exhibiting non-
carcinogenic effects have been set at the non-zero MCLG. In the
absence of an MCLG, cleanup levels for non-carcinogenic effects
have been set at a level thought to be without appreciable risk of
an adverse effect when exposure occurs over a lif~time (hazard
quotient = 1).
Table I below summarizes the cleanup levels for carcinogenic and
non-carcinoqenic contaminants' of concern identified in the
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51
TABLE I: INTERIM GROUNDWATER CLEANUP LEVELS
/
carcinogenic
contaminants of Cleanup Basis Level of
Concern (Class) Level (DDb) Risk
Arsenic (A) 508 MCLb 2.0 X 10-4 c
Beryllium (B2) 18 pMCLd 1.2 X 10-4
Benzene (A) 5 MCL 4 . 1 x 10-6
1,1 dichloro- 1.2 x 10-4
ethylene (C) 7 MCL
Methylene 1.1 x 10-7
Chloride (B2) 5 pMCL
Tetrachloro-.
ethylene (B2) 5 MCL 7.3 X 10-6
Trichloro-
ethylene (B2) 5 MCL 1. 6 x 10-6
TOTAL 5.0 X 10-4
Non-carcinogenic Target
contaminants Cleanup Basis Endpoint. Hazard
Concern Level (DDb) of Toxicitv Index
Chromium 1008 MCL 0.2
Lead 158 Action Central N/A
Level Nervous System
Nickel 1008 pMCL body weight 0.2
1,1 Dichloro-
ethane (C) 3500 RfDe skin 1.0
t-1,2 Dichloro-
ethylene 100 MCL blood 0~2
1,1,1 Trichloro-
ethane 200 MCL liver 0.6
Antimony 3 pMCLG8 blood 0.2
a - Arsenic, beryllium, chromium, lead, antimony, and nickel'
may be naturally occurring elements in the Savage Well
aquifer. The target clean-up levels are those listed in the
above table or background, whichever is higher. Background
concentrations will be determined during the pre-design
studies.
b - Maximum contaminant Level,. Safe Drinking Water Act
c - The cleanup level for arsenic has been set at the MCL of
50 ppb. The carcinogenic risk posed by arsenic at 50 ppb in
groundwater will approximate 2 in 1,000. However, in light of
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52
oral exposure to arsenic are non-lethal and in light of the
possibility that the dose-response curve for the skin cancers
may be sublinear (in which case the cancer potency factor used
to generate risk estimates will be overstated), it is Agency
policy to manage those risks downward by as much as a factor
of ten. As a result, the carcinogenic risk for arsenic at
this Site has been managed as if it were 2 in 10,000. (See
EPA memorandum, "Recommended Agency Policy on the Carcinogenic
Risk Associated with the Ingestion of Inorganic Arsenic" dated
June 21, 1988.) .
d - Proposed Maximum Contaminant Level
e - Reference Dose
All groundwater ARARs identified in the ROD and newly promulgated
AHARs and modified ARARs which call into question the protectiveness
of the remedy and the cleanup levels prescribed by the above
described risk assessment must be met throughout the plume at the
completion of the remedial action. EPA has estimated that those
levels will be obtained within a range of 15 to 60 years. The
finding of DNAPLs may alter the cleanup time of less than 30 years
for the concentrated portion of the plume to an unknown length of
time~
While the Interim cleanup levels are consistent with ARARs (and
suitable TBC criteria) for groundwater, a cumulative risk that could
be posed by those levels may exceed EPA's goals for remedial action.
Consequently, those levels are considered to be interim cleanup
levels for groundwater. When all groundwater ARARs identified in the
ROD and newly promulgated AHARs and modified ARARs which question the
protectiveness of the remedy have been attained, a risk assessment
will be performed on residual groundwater contamination to determine
whether the remedial action is protective. Remedial action shall
continue until protective concentrations of residual contamination
have been achieved or until the remedy is otherwise deemed
protective. Those 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.
Description of Remedial Components
The selected remedy, Alternative MM-IIA, restores the groundwater in
the aquifer and has the following five components: . extraction and
treatment of the concentrated plume; extraction and treatment of a
portion of the extended plume; natural attenuation; environmental
monitoring; and institutional controls. Each component is described
below.
,
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53
1.
Extraction and treatment of the concentrated plume
A groundwater extraction and treatment system will be installed
near the OK Tool and Hitchiner plants to capture and treat the
groundwater from the concentrated plume. The wells will be located.
to extract an estimated 400 gallons per minute of the heavily
contaminated groundwater to prevent movement of those contaminants
into remaining portions of the aquifer. The groundwater will be
treated by two separate treatment processes. Ultraviolet oxidation
will be used to treat water from the OK Tool well. Air stripping
will be used to treat water from the Hitchiner well.
The removal of metals from the groundwater is dependent upon both
the determination of discharge limitations and the treatment
process design requirements. If the discharged treated water is
used for groundwater recharge (which may include recharge to the
Hitchiner-Hendrix discharge stream because the stream recharges the
aquifer), MCLs will be the proper ARAR to be met and discharge.
limitations will be set appropriately.
If ~he water is discharged to a surface water body which does not
recharge the groundwater, the discharge must meet the NPDES
discharge requirements (which may be based on Ambient Water Quality
criteria if aquatic life is affected) and the appropriately set
discharge limitations. If the treatment processes require metals
to be removed for treatment efficiency, the discharge limitations
described above still apply. The two treatment trains are
necessary due to the relative locations of the wells and the nature
of the contaminants identified at each location.
The well locations and pumping rates for all extraction points 'are
subject to change during design studies. Additional changes may
also be needed in the remediation phase based on field data
obtained during system operation.
Ultraviolet (UV) oxidation is a technology that has proven to be
effective in destroying chlorinated solvent contaminants of the
kind found to be predominant within the plume, e.g. PCE. Volatile
.organic contaminants dissolved in groundwater are brought into
contact with a proportional amount of hydrogen peroxide solution in
the presence of ultraviolet radiation. The ultraviolet radiation
breaks the hydrogen peroxide solution into hydroxyl radicals while
simultaneously exciting the bond structure of the organics so that
they become susceptible to oxidation. The end products of the
reaction are carbon dioxide, water and a chloride ion.
Air stripping with metals pretreatment coupled with vapor phase
carbon treatment is the treatment process for the contamination at
Hitchiner due to the presence of 1,1,1-TCA. Air stripping is more
efficient and thus more cost effective than ultraviolet oxidation
in treating saturated organics such as 1,1,1-TCA which is located
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54
groundwater is passed through a packed column countercurrent to an
air flow which volatilizes the compounds from the liquid stream.
The contaminant laden air stream is then treated using carbon to
remove the contaminants. The carbon is regenerated off site and
the contaminant is destroyed during that process.
The investigation of the concentrated plume suggests the presence
of DNAPLs. Even if DNAPLs are determined to be present, this
remedy will initially contain that portion of the plume where
DNAPLs are found so that the remainder of the contaminated aquifer
can be restored to beneficial use. EPA will periodically review
advances in groundwater cleanup technology to determine if new
techniques have been developed to effectively remediate DNAPL
conditions. Consistent with CERCLA and the NCP, EPA will determine
whether any modifications to the remedy are appropriate.
2.
Extraction and treatment of extended plume
A groundwater extraction system will be installed at two locations
in the extended plume. This component of the alternative will pump
and treat approximately 700 gallons per minute using UV oxidation.
Two wells will withdraw groundwater at a rate of approximately 300
gpm each from the middle of the plume. One well would be located
between the Souhegan River and the Savage Well. The other well is
the Savage Well. Lower volume wells located north of the Souhegan
River and will pump approximately 50 gpm each to capture the
portion of the plume with high concentrations of contaminants that
has migrated under the river. The treatment plant is located at or
near the Savage Well.
3.
Natural attenuation
The portions of the plume not in the capture zones will undergo
natural attenuation. Natural attenuation is the reduction of
contamination levels in the groundwater through dispersion,
dilution, transformation (natural chemical breakdown), sorption
(bonding of the contaminants to particles in the soil), and
biodegradation (the action of naturally occurring microorganisms
that break down the contaminant). After initiation of the active
remedial measures at each of the extraction locations, no further
contamination will be added to the extended plume. The
contaminants not captured will continue to flow north and east..
Those contaminants will either be diluted in the clean portions of
the aquifer or discharged into the river where much of the
contamination is expected to evaporate. Natural attenuation is
expected to meet cleanup levels in those areas in 10 to 35 years.
(-
4.
Environmental monitoring
EPA will develop a Site monitoring program to monitor the operation
of the treatment system and to address all media which may be
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55
media expected to be impacted are air, groundwater (overburden and
bedrock), surface water, and sediments.
Groundwater quality will be monitored until cleanup levels are met.
The monitoring program will include periodic sampling, annually at
a minimum, of household wells used for drinking water north of the
Souhegan River. Surface water and sediment sampling will be
included in the monitoring program to ensure that as contaminants
continue to discharge to surface waters there will be no adverse
environmental impact.
The groundwater monitoring program will be developed for the
following purposes:
to evaluate the effectiveness of the pump and treat active
remediation measures in the concentrated and the extended
plume areas: and
to monitor the reduction of contaminant concentrations over
time in order to ensure that the groundwater cleanup levels
are achieved in the predicted time frames: and
to monitor the natural attenuation of contamination in areas
where active restoration of the aquifer will not be
implemented. Additional monitoring wells may be needed to
accomplish this objective.
The groundwater will be monitored quarterly for the first five
years. At that time, the sampling frequency will be reviewed and
evaluated. . Surface water and sediments will be sampled at a
frequency established during the remedial design phase, but no less
frequently than annually. The media will be analyzed for the
presence of the following contaminants: VOCs, SVOCs, metals, and
Hazardous Substance List Compounds. VOC sampling will be done on a
quarterly basis (VOCs are the most prevalent contaminant at the
Site). The frequency of sampling for the remaining compounds will
be decided during the remedial design phase but it is probable that
the sampling will be done less frequently than that for VOCs. The
. frequency of sampling and analysis may be changed by EPA based upon
evaluation of the annual and/or five year reviews.
The effluent from treatment plants will be monitored as necessary
to ensure compliance with ARARs.
Air monitoring will be done at the treatment plants as necessary to
ensure that air emissions are in compliance with ARARs.
The details of the monitoring program will be developed during
remedial design and will be tailored to the specifics of the
design. Additional monitoring wells may be needed to evaluate the
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56
Selected bedrock and overburden wells will be monitored upon
initiation of remedial design until completion of remedial action.
Reports assessing the results of the sampling and analysis event
will be done after every sampling event.
All monitoring data will be reviewed and evaluated during the
implementation of the remedial action to ensure that response
objectives are achieved. Modifications to the remedial action,
including the evaluation and possible implementation of advances in
groundwater cleanup technology may also require changes in
monitoring locations or techniques.
\ .
Institutional controls
5.
Institutional controls will be implemented to restrict the use of
contaminated groundwater and to 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 either affect implementation of the
selected remedy or cause exposures to hazardous substances.
Examples of acceptable institutional controls include use of
restrictions imposed through deeds and zoning ordinances.
6.
Remedial Desiqn Issues
Both the location of the extraction wells and the pumping rates for
those wells are approximate. Design studies will be performed to
determine the precise number, location, and pumping rates of the
extraction wells that contain, recover, and treat contaminants in
the most effective and efficient manner. Studies will also
determine any changes in the location and concentration of the
plume (especially at the leading edge of the plume) that may have
occurred.
In addition, studies will be conducted to determine whether the
remedy will result in a lowering of the water table at the Site. A
lowered water table could have a negative effect on agricultural
land use or on environmentally-sensitive areas within the site.
Similarly, both the specific location for the discharge of treated
water and the method of discharge for the treated water will be
examined during the design phase for other possible negative
impacts on either wetlands or areas currently being used for
agriculture. If the design studies indicate that negative impacts
may occur in those areas or if negative impacts do occur in those
areas after the cleanup has begun, appropriate mitigation efforts
will be made. The use of groundwater recharge or structural or
hydrogeologic barriers may also be considered to speed or to
redirect the contaminant movement and thus to speed the clean-up.
Chemical data from the concentrated plume area suggest that DNAPLs
. may be present in the overburden aquifer. Studies to further
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57
investigate ,that possibility will be undertaken in the remedial
design stage. If DNAPLs are determined to be present, the remedy
initially would be to contain that portion of the plume so that the
remainder of the contaminated aquifer can be restored to beneficial
use.
Design studies will also include monitoring the leading edge of the
plume through the examination of chemical concentrations along the
zones of preferential contaminant movement and discharges to the
river system. The monitoring system at the leading edge of the
plume will be observed to ensure that adequate information is
available to monitor the natural attenuation processes that are
part of the remedy. As a result of both the design studies and
information gathered after initiation of extraction and treatment
operations, it may be necessary to adjust the monitoring system.
The design studies will include treatability studies which will
'evaluate the proposed groundwater treatment technologies for the
entire plume.
Periodic review of the operation and effectiveness of the groundwater
extraction and treatment system will be necessary. Performance of
the system will be evaluated annually, or more frequently, to
determine if EPA's acceptable risk range and standards for the design
criteria are being met. If not, adjustment or modification may be
necessary. These adjustments or modifications may include relocating
or adding extraction wells or alternating pumping rates. switching
from continuous pumping to pulsed pumping may improve the efficiency
of contaminant recovery and should be evaluated. Necessary
modifications should be undertaken. If new information exists
regarding the extraction and treatment technology, it will be
evaluated and applied as appropriate.
After the interim cleanup levels have been met, 'a risk assessment
will be performed. If the remedy is determined to be protective, the
groundwater extraction and treatment system will be shut down. A
groundwater monitoring system will then be utilized to collect
, information each quarter for three consecutive years to ensure that
those cleanup levels have been met and that the remedy is protective.
If those levels are maintained for three consecutive years and the'
remedy is determined to be protective, a long term monitoring program
for the site will be implemented in accordance with RCRA and the New
Hampshire Hazardous Waste Rules. If the risk assessment indicates
that the remedy has not been effective, the performance standards
and/or the remedy will be re-evaluated.
To the extent required by law, if any. hazardous substances,
pollutants, or contaminants remain at the site after the initiation
of the remedial action, EPA will review the site at least once every
five years to assure that the remedial action continues to protect
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XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Savage
Municipal Water Supply Superfund Site is consistent with CERCLA and,
to the extent practicable, the NCP. The selected remedy is
protective of human health and the environment, attains ARARs or
invokes an appropriate waiver and is cost effective. The selected
remedy also satisfies the statutory preference for treatment which
permanently and significantly reduces tpe 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
p~man health and the environment by eliminating, reducing or
controlling exposures to human and environmental receptors through
removal, treatment, engineering controls, and institutional controls.
More specifically, the risks at this Site will be eliminated or
reduced through the collection and treatment of the contaminated
groundwater. Contaminated groundwater will be extracted, treated at
seveTal locations, and either discharged to the Souhegan River or
recharged back to the wetlands. A long term monitoring program will
ensure that the remedy remains protective of human health and the
environment.
Assuming the contaminants within the concentrated plume are dissolved
(not DNAPLS), it is estimated that contaminant levels within those
areas will be reduced to MCL's and/or cleanup levels in approximately
30 years of pumping and treating. Even if DNAPLs are found to exist,
at a minimum, the contaminated groundwater in the concentrated plume
will be contained so that continued migration of the contaminants to
the downgradient extended plume will be eliminated or reduced to the
extent technically practicable. This will be accomplished by
locating several wells within and/or at the extremities of the
concentrated plume. New information relative to the presence of
DNAPLs in the concentrated plume will be evaluated to determine.
whether any modifications to the response actions are needed. The
operation of a pump and treat system which captures and contains
contaminated groundwater in the concentrated plume will provide
protectiveness for the remaining portion of the aquifer which
encompasses the extended plume.
The contaminated groundwater in the extended plume will be either
extracted and treated or allowed to naturally attenuate until MCL's
and/or cleanup levels are met throughout the plume. The operation of
a pump and treat system in the extended plume will capture and
contain contaminated groundwater and will provide protectiveness for
downstream receptors. It is estimated that cleanup levels will be
attained in 15 to 60 years.
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Institutional controls such as deed restrictions regarding water use
will be implemented and maintained until the groundwater cleanup
levels are met and the remedy is deemed protective of human health
and the environment. A long term monitoring program will be
instituted to ensure that the remedy remains protective of human
health and the environment. The pump and treat systems to be
implemented within the contaminated groundwater plume will provide
protectiveness to public health and the environment by capturing
contamination and eliminating the threat of continued contaminant
migration. The institutional controls will provide protectiveness
throughout the contaminant plume (including the areas of the plume
that will n~turally attenuate) through use restrictions.
After all interim cleanup levels have been met, a risk assessment
will be performed on residual groundwater contamination to determine
the final groundwater cleanup levels. If the resulting cumulative
risk is not wi thin the 10-' to 10-6 incremental risk range and the
cumulative hazard index for similar target endpoints is not below the
specified level of concern, remedial actions must continue until the
prote~tive levels are attained.
.
And finally, implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts. The
technologies are proven and will be field tested to reduce
operational risks. In addition, special engineering precautions will
be used to minimize the potential for air releases of contaminants.
B.
The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and.
appropriate federal and state requirements that apply to the site.
Substantive portions of environmental laws identified as ARARs and
those to be considered for the selected remedial action include,
among others:
Chemical Specific
Safe Drinking Water Act - Maximum contaminant Levels (MCLs)
Resource Conservation and Recovery Act, Groundwater Protection
National Ambient Air Quality Standards (NAAQS)
Clean Water Act Ambient Water Quality criteria (AWQC's)
MCLs
New Hampshire
New Hampshire
New Hampshire
New Hampshire
Surface Water Quality Standards
Drinking Water Standards
Ambient Air Quality Standards
Toxic Air Pollutant Regulations
Location Specific
Clean Water Act (CWA) (Protection of Waters & Wetlands)
Executive Order 11990 (Protection of Wetlands)
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Fish and Wildlife Coordination Act
New Hampshire Wetlands Regulations
New Hampshire Hazardous Waste Regulations (Facility siting standards)
Action Specific
. .
Clean Air Act (NAAQS and NESHAP)
.CWA (NPDES and Pretreatment Standards)
New Hampshire Air Regulations for VOCs
New Hampshire Rules for Transportation of Hazardous Materials
New Hampshire Regulations for Fugitive Dust Control
To Be Considered
EPA Risk Reference Doses
EPA Carcinogen Assessment Group Potency Factors
NOAA Technical Memorandum NOSDMA52
Federal Groundwater Protection Strategy & Classification Guidelines
New Hampshire Protection of Groundwater - New Hampshire Groundwater
Quality Criteria
New Hampshire Wellhead Protection Program
Appendix C of this ROD lists all of the ARARs identified for the
and whether they are applicable, relevant and appropriate, or to
considered. A brief synopsis of the requirements and the action
be taken to meet those requirements is presented in the table.
Appendix VII of the FS, Volume 2, lists all of the ARARs identified
for each of the alternatives presented for remediation of the Site.
Site
be
to
~.
Chemical Specific
a.
Federal and State Drinkinq Water Standards
In the past, the groundwater at various locations throughout the Site
has been used as a public and private drinking water source. For
example, the Savage Municipal Water Supply Well once provided about
45% of the Town of Milford's water supply (180,000 to 200,000 gallons
per day) and a separate well currently provides for the seasonal use
at the Milford Drive-In Theater. The Savage Well was taken out of
service in 1983 when contamination was discovered. The Town has
since developed a replacement well and has a contract for the supply
of drinking water with the Pennichuck Water District. As previously
stated, the aquifer is large and has a large potential yield. If the
aquifer were of drinking wat~r quality, it would likely be an
important public and private water supply source for the area. While
Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals
(MCLGs) promulgated under the Safe Drinking Water Act are not
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61
groundwater cleanup whenever groundwater may be used as a drinking
water source. In addition, the NCP requires that usable groundwater
be restored to its beneficial uses whenever practicable. See 40 CFR
300.430(a) (iii) (F).
New Hampshire's Protection of Groundwater regulations (Ws 410) do not
establish groundwater quality standards, but do establish groundwater
criteria. On~ of those criteria is the requirement that no person
shall cause the groundwater to contain a substance at a level that
the state determines may be potentially harmful to human health or to
the environment. Because New Hampshire's regulations do not contain
a standard level of control as required by CERCLA ~ 121(d) (2) (A) (ii),
they will not be an ARAR. However, the regulations are to be
considered (TBCs) at the site and the requirement will be met.
This remedy will attain the above mentioned ARARs as well as the
ARARs identified in the table in Appendix C. In addition, the remedy
will comply with those regulations which have beeri identified as TBCs
by meeting the groundwater cleanup levels at the site through the
operation of the groundwater treatment systems and through natural
attenuation. Treating the contaminated groundwater will reduce
levels of contamination at the site to the interim cleanup levels
identified in this ROD. Where natural attenuation is employed,
Federal and State standards will be met within the time frame
specified.
b.
Federal Clean Air Act and New Hampshire Air Pollution
Requlations
Federal Primary and Secondary National Ambient Air Quality'Standards
(NAAQS) exist for emissions of sulfur oxides, carbon monoxide, ozone,
nitrogen oxides, lead, and particulate matter whereas the National
Emission Standards for Hazardous Air Pollutants (NESHAPs) address VOC '
emissions from specific sources. Threshold Limit Values (TLVs)
provide an extensive list of control levels for workplace
environments. While those values are based on the exposure of a
select population and are not generally transferable to the general
public, they are used to assess site inhalation risks for soil
removal operations.
New Hampshire's air quality regulations parallel the federal
regulations. The sections set forth in the table in Appendix c
establish specific standards for particulate matter and ambient air
limits for a large number of toxic air pollutants. In addition, New
Hampshire has established limits on VOC emissions from certain
industries. Also, the state has promulgated fugitive dust control
regulations which require that measures be taken to limit dust from
construction and other activities.
In addition, the federal and state regulations which set standards
for VOC emissions from certain industries will be relevant and
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62
used at the Site. 'For example, the specific portion of the treatment
system at the Site to which air standards and regulations would be
most appropriate is the emissions from the air stripping unit at the
Hitchiner plant. The implementation ,of the pertinent standards and
regulations will provide protectiveness to human health and the
environment. The best demonstrated technology which will be
determined in the design phase will be employed to meet the federal
and state requirements.
2.
Location SDecific
a.
Federal and State Wetland and FloodDlain Protection
The Clean Water Act, Executive Order 11990 (Protection of Wetlands),
and state wetland protection standards are all applicable to that
portion of the remedy constructed in or affecting the wetlands on or
near the Site. Those rules prohibit activity adversely affecting a
wetland if there exists a practicable alternative which is less,
detrimental. It is necessary to construct the management of
migration groundwater extraction system in the wetland because active
management and cleanup of the plume is required to meet the
remediation objectives of the Site and the contaminant plume lies
under the wetland. Efforts will be made to locate any treatment
facilities outside the wetlands.
In the short term, construction will be conducted to avoid or
minimize the damage to flora and fauna within the wetlands.
Additionally, after construction is completed, restoration of the
wetlands will occur in two phases. The first phase which is
implemente~ at the time that construction is completed consists of
restoring the original topography and establishing shallow rooting
vegetation. The second phase which is initiated when the remedy is
completed consists of encouraging the original wetland species to
reestablish themselves naturally.
The majority of the Site is within the 100 year floodplain of the
Souhegan River. Therefore, Executive Order 11988 (Floodplain
Management) is an ARAR. Those regulations govern construction
activities which have a negative impact on a floodplain. The
construction of the groundwater extraction system should have a
minimal negative impact on the floodplain. Efforts will be made to
locate the groundwater treatment plant(s) outside of the floodplain.
However, if that is not possible, the impact of such construction
should also have only a minor impact on the floodplain.
EPA's policy on implementing Executive Orders 11990 (wetlands) and
11988 (floodplains) is contained at 40 CFR Part 6, Appendix A. That
Appendix sets forth principles and procedures governing work in
wetlands and 'floodplains so as to minimize the adverse impacts on
those valuable natural resources. Those orders as well as EPA's
policy will be implemented in the construction and maintenance of the
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In accordance with 40 CFR Part 6, Appendix A, EPA has provided an
opportunity for public comment on the work to be undertaken in the
wetlands and floodplain. EPA has issued a Proposed Plan for remedial
action at this Site, has held a public hearing, and has received
public comments during a thirty day comment period prior to this
decision. In addition, a Statement of Findings which determines that
there are no practicable alternatives to these remedial actions in
the wetlands and floodplain is included in Appendix F.
3.
bction SDecific
a.
State and Federal Hazardous Waste Reaulations
The current State of New Hampshire hazardous waste regulations are
applicable to the groundwater remediation activities to be conducted
at the site. In the limited instances where those regulations
conflict, the more stringent regulation will be followed.
.
Prior to January, 1991, the State had promulgated hazardous waste
regulations which were as stringent as, or more stringent than, RCRA
regulations. Accordingly, the State had been authorized by EPA to
administer and to enforce the hazardous waste program in New
Hampshire. However, New Hampshire has promulgated an entirely new
set of regulations in 1991. Some of those regulations are less
stringent than RCRA regulations. This new state program is still
undergoing revision and has yet to be approved by EPA. As a result,
both federal and state hazardous waste regulations existing at the
signing 01: this ROD must be consulted to ensure that the more
stringent requirements are followed.
The groundwater treatment plant(s) will be designed, constructed, and
operated in accordance with those regulations. Any sludge or other
residuals generated during the operation of the groundwater treatment
plant(s) and determined to be RCRA type waste will also be stored,
transportE!d, and disposed of in accordance with RCRA and/or the State
hazardous waste restriction regulations.
c.
ThEI Selected Remedial Action is cost-Effective
In the AgE!ncy's judgment, the selected remedy is cost effective in
that the overall effectiveness of the remedy is proportional to the
cost of the remedy. EPA came to that conclusion after first
identifying alternatives that are protective of human health and the
environment and that either attain or, as appropriate, waive ARARs.
EPA then E!valuated the overall effectiveness of each alternative by
assessing the relevant three criteria: long term effectiveness and
permanence; reduction in toxicity, mobility, and volume through
treatment; and short term effectiveness. The relationship of the
overall effectiveness of those remedial alternatives was determined
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64
A summary of the costs associated with each of the management of
migration alternatives is presented below. Alternatives MM-3 through
MM-11A are all groundwater extraction wells and treatment systems.
The number of wells and pumping rate are provided in the table below.
COST COMPARISON OF MANAGEMENT OF MIGRATION ALTERNATIVES
Capital
Costs
MM-1
Alternative
No Action
$
$
MM-2
MM-3
MM-7
MM-7A
MM-9
MM-9A
MM-10
MM-11
Limited Action
Two Wells, 400 gpm
Six Wells, 1225 gpm
1,100,000
2,500,000
six Wells, 1225 gpm
2,500,000
Eight Wells, 1150 gpm
Eight Wells, 1150 gpm
2,500,000
2,600,000
Fifteen Wells,
2975 gpm
5,100,000
six Wells, 1100 gpm
2,200,000
*
MM-11A Six Wells, 1100 gpm
2,400,000
Based on 30 year present worth analysis.
1,400,000
O&M Costs
$/Yr
o
$
81,000
... e.,
Present
Worth *
$
764,000
o
126,000
1,200,000
14,000,000
21,400,000
16,400,000
21,000,000
16,300,000
44,300,000
20,200,000
15,500,000
With the exception of Alternative MM-1, all of the management of
migration alternatives are protective of human health and the
environment and will attain ARARs. Alternative MM-1, the least
expensive one, is not protective of human health and the environment
since it does nothing to restrict usage of the contaminated
groundwater during the estimated 100 years or more required to att~in
drinking water standards. Alternative MM-2, Limited Action, is .. .
similar to Alternative MM-1 in that it relies on natural attenuation
to attain groundwater cleanup levels. However, Alternative MM-2 also
includes institutional controls such as deed restrictions to prevent
the use of the contaminated groundwater for drinking water and other
inappropriate purposes. Alternative MM-2 is the lowest cost
alternative which is protective and which meets ARARs.
1,400,000
2,000,000
1,500,000
2,000,000
1,500,000
4,200,000
1,900,000
F
Each of the remaining alternatives takes active measures; only the
number and location of wells, the rate of groundwater extraction, and
the overall treatment times differ. The cost of each alternative is
proportional to the extraction rate; the greater the amount of
~roundwater pumped and treated, the greater the cost. Alternative
-------
65
MM-lO is the most costly but it also provides the shortest
remediation time. Alternatives MM-7, MM-7A, MM-9, MM-9A, MM-ll, and
MM-llA balance the amount of water extracted in the extended plume
with the amount of contamination left to undergo natural attenuation.
Alternatives MM-ll and MM-llA are the only alternatives which address
the high levels of contamination which are present north of the
river.
Each of the treatment alternatives provides varying reductions in
toxicity, . mobility, or volume through treatment since each relies on
the extraction and treatment of differing volumes of groundwater as
well as on natural attenuation. For example, Alternative MM-3
provides significantly less reduction of toxicity and mobility and
volume through treatment than Alternative MM-lO since a significantly
smaller amount of contaminated groundwater is extracted and treated.
The use of ultraviolet oxidation in place of air stripping to treat
certain portions of the plume results in a lower present worth cost
for those alternatives where that technology was evaluated. This.is
due to a lower cost of operation. Thus, the use of ultraviolet
oxida~ion in the selected alternative is cost effective.
The short term effectiveness of each of the treatment alternatives
varies based on the number and location of the wells and the overall
rates at which groundwater is extracted relative to the amount of
groundwater allowed to naturally attenuate. with more wells and
higher extraction rates, cleanup goals are attained more quickly.
However, the shortening of the cleanup time to less than thirty years
as in Alternative MM-lO results in the highest cost. Alternative
MM-3 which is the least costly of the active remediation alternatives
requires the longest cleanup time. Of the remaining alternatives,
Alternative MM-llA is the most cost effective in balancing the amount
of contamination captured and treated with the area of the plume left
to naturally attenuate.
The table below provides a comparison of the groundwater extraction
rates and times to attain cleanup levels for the alternatives under
-------
66
Alternative
Extraction rate (GPM)
Time to cleanup (vrs)*
MM-2
o
Greater than 100
MM-3
400
25 - 90
MM-7/7A
.- MM-9/9A
1225
15 - 65
1150
20 - 85
MM-10
2975
10 - 30
MM-11/11A
1100
15 - 60
* Clean up times for extended plume. Cleanup of concentrated plume
is less than 30 years based on current available knowledge.
A summary of the costs for each of the elements of the selected
management of migration remedy are presented below. All costs are
net present worth.
TOTAL COSTS OF SELECTED MANAGEMENT OF MIGRATION REMEDY
PORTION OF REMEDY
PRESENT WORTH COST ($)*
I.
capital Costs
2,400,000
II.
Annual Operation and Maintenance
(@ $1,400,000 per year)
13,100,000
TOTAL
15,500,000
*
Based on 30 year present worth analysis.
A complete accounting of costs for the management of migration
alternative is contained in Section 4 of the FS Addendum.
TOTAL ESTIMATED COST:
$15,500,000
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to the
Maximum Extent Practicable
Once the Agency identified those alternatives that attain or as
appropriate waive 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. That determination
was made by deciding which one of the identified alternatives
provides the best balance of trade-offs among alternatives in terms
,.
-------
67
of: 1) lc)ng-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
emphasizeq long-term effectiveness and permanence and the reduction
of toxici1:y, mobility and volume through treatment; the balancing
test also considered the preference for treatment as a principal
element, 1:he 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.
All of the alternatives with the exception of Alternatives MM-1 and
MM-2 utilize the same permanent solution, extraction and treatment of
groundwater, to reduce the contamination in the aquifer. The
difference between the alternatives is how much contaminated
groundwater is extracted and treated versus how much is allowed to
naturally attenuate.
From the standpoint of long term effectiveness, the remaining
alternatives are essentially equivalent. Each of the alternatives
provides varying amounts of reduction in toxicity, mobility, or
volume through treatment depending upon how much groundwater is
extracted and treated (See the table on page 66). For the same
reason, each of .the remaining alternatives will achieve cleanup
levels in different times (See the table on page 66).
The degree of negative impact to the environment (wetlands/flood-
plains) if; dependent on the amount of groundwater extracted. As long
as rechar~Je of the treated groundwater can be accomplished, it is
expected 1:hat the impact from any of the alternatives will be
minimal. .
Each of the remaining alternatives is equally implementable since
they all E~mploy similar technology. The costs for each alternative
are included in the table on page 64.
The selec1:ed remedy represents the best balance among the above
factors since
.a) it will result in attainment of cleanup levels in the aquifer
within a reasonable timeframe (15 to 60 years);
b) it uses a middle to long range extraction rate (1100 gpm) ,
thereby minimizing impacts to the environment;
c) it is one of the lower cost alternatives (15.5 million dollars)
with thE~ exception of the no-action and limited action alternatives
and
d) one of the technologies to be used, ultraviolet oxidation, is
-------
68
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 groundwater
extraction and treatment. Groundwater extraction and treatment
addresses the primary threat at the site which is the contamination
of groundwater with volatile organic compounds (VQCs). The selected
remedy therefore satisfies the statutory preference for treatment as
a principal element.
";.~
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
remediation of the site on July 3, 1991. The management of migration
portion of the preferred alternative includes extraction and
treatment of contaminated groundwater in the concentrated plume,
extraction and treatment of contaminated groundwater in the extended
plume, natural attenuation of that portion of the contaminated
groundwater not extracted for treatment in the extended plume, and
institutional controls.
No significant changes from the Proposed Plan have been made to the
selected remedy as detailed in this Record of Decision.
XIII. STATE ROLE
The New Hampshire Department of Environmental Services (NHDES) has
been involved with the Site from the time of the 'discovery of
contamination. Through a Cooperative Agreement, the NHDES performed
oversight of field activities and provided laboratory services for
split samples. The State has also reviewed and provided comments on
the interim reports during the RIfFS as well as the final Remedial
Investigation, the Risk Assessment, and the Feasibility Study. NHDES
also provided a listing of state ARARs for use in the development of
the alternatives for the Feasibility study. NHDES has not commented
-------
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
APPENDIX A
-------
ffi
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FIGURE 1: LOCATION MAP
SA V AGE WELL SITE, Mll..FORD, NH
-------
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rl,.., I" r
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FIGURE 8
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FIGURE 9
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-------
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
APPENDIX B
TABLES
('
-------
,"
TABLE 1-..
1
DESCRIPTIVE STATISTICS FOR VOLATilE ORGANIC COHPOUNDS
MEASURED IN GKOUNDUATER SAMPLES
SAVAGE IIEll SUPERFUND SITE
Mil ford, NH
-c
o
00
:D :rJ 1
G5 0 Data available from four separate &811~lIng rounds. Duplicate or spIlt san"les were averaged Into the existing data set.
- --2
Z ~ Chemical:; present above the detection limits In at least one sa~le. Other cOlllpounds analyzed for, but not detected, were not listed.
»~-3
r C Ihe detection limit used for the majority of analyses. The detection limit may vary for Individual lianples. For sanples that were split
~ 8.1<.1 8nal yze<.l tJy the Nil DES, the detect Ion limit wali lower.
..or: 10
Volatile organic calpound:; were detected In 1100 of 201 s~~les.- Detection frequency Is the nunber of detections divided by 201. The s~le
mean Is tha geal~trlc mean of all .a~le., when trace detections end non-detects are entered Into the data set as 1/2 of the detection limit.
5
Proposed (p) maxinun contaminant concentration under the Safe Drinking lIater Act or health-based criteria (d) used by the NH DPHS.
2 3 10 10 3 4
CHEMICAL NAME METHOD NUMBER OF DETECTION MINIMUM MAXIMUH lOCATION SAMPLE MAXIMUH
DETECTION DETECTIONS FREQUENCY DETECTEO VALUE OF MAXIMUH "EAN CONTAMINANT
lIHIT PER CHEHICAl VALUE VALUE (N . 201) lEVel
(ppb) (X) (ppb) (ppb) (ppb) (ppb)
Tetrachloroelhene 5 126 63 0.62 19000 "1,210 34.5 5
Trlchloroethene 5 80 40 1.18 2300 HI.210 6.9 5
1,1,1-Trichloroethane 5 75 38 0.66 1300 HI-30 6.3 200
trans-1,2-Dichloroethene 5 105 23 0.62 1500 "1-24 10.9 100
1,1-Dichloroethane 5 33 17 0.75 110 "1-30 3.2 800
1,1-0ichloroethene 5 17 9 trace 106 "1-210 2.8 7
Hethyl-t-8utylether 10 110 7 "1. 110 60 ""-68 5.5 200 (d)
Toluene 5 10 2 2.22 125 MI-21o 2.6 1000
Benzene 5 4 2 .. 0.75 67 "11-10C 2.6 5
Methylene Chloride .5 3 2 7.00 10 "1-25 2.5 5
Acetone 20 2 1 80.69 890 "1.30 10.3 none
Total Xylenes 5 2 ; 35.00 62 ""-1IoA 2.6 10,000
Chlorobenzene 5 2 1 0.50 103 "1-210 2.5 100
1o-"ethyl-2-Pentanone 5 2 1 trace trace ""-23C 2.5 none
Ethylbenzene 5 1 1 trace trace HII-lloA 2.5 700
2-Hexanone 5 1 1 9.00 9 HII-23C 2.5 none
Vinyl Chloride 10 1 1 trace trace "1-24 5.0 2
Carbon Tetrachlorl<.le 5 1 1 5.00 5 ""-188 2.5 5
-------
TABLE 2
SCREENING OF
MANAGEMENT OF MIGRATION ALTERNATIVES
Alternative
Grout>
Representative Alternative
Retained Unless Noted
MM-l
MM-l
MM-2
MM-2
MM-3A, 3B
MM-3
MM-3C
Not Retained for Detailed Analysis
MM-4
Not Retained for Detailed Analysis
MM-S, 6, 7, 7A
MM-7, 7A
MM-9, 9A
MM-9, 9A
MM-S, 10
MM-10
MM-ll, llA
MM-ll, llA
MM-12
Not Retained for Detailed Analysis
NOTE: Alternatives that have management stategies sufficiently
similar to other alternatives were grouped together and a
representative alternative brought forward for detailed analysis.
~he alternatives designated with an "A" are the same functional
alternative as those with out an "A" but were analyzed in the FS
Addendum with a change in treatment technology only.
(:;
-------
TABLE
3
Carcinogenic and Noncarcinogenic Risks from
Future Household Use of Groundwater
Chemical
. Coitcentnitiori...
.. ... (pg/L) ,
. .
. . . - . .
. ... . ..
. ... .
A "0; MAX;
. . .. Cancer
. .Slope Factor
. Reference
DOse...
;. ToXic Effect.
...
EXpOsure
Pactor"
.. ....
..,...
. ... .............. .....
"""""'"'' . .....
. .. ....- .-........ ... .. ...
. ..... ............ H''''
.... .............. .
. C!!nc~f~i!kb(
. ... ..-. ............
. .,".," "', ..,' ",". ,",,",","
.. .. .... . ....
..H~d.ind~x~...
. (mglic:gJday)-1 . . (triglkgiday) .
(Ukg/day) .
. . ......
AVO;.
.. , ...
..... .....
... ....
... .. . .
MAx;
A.VtL
....MAXl
Tetrachloroethylene 345 19000 0.051 0.01 liver 0.2 3.5E-04 1.9E-01 2.4 1300
Trichloroethylene 69 2300 0.011 0.2 I.5E-05 5.1E-03 00 00
1,l-dichloroethylene 28 46 0.60 0.009 liver 0.2 3.4E-04 5.5E-03 0.22 3.6
trans-1,2- serum alk.
dichloroethylene 49 1500 0.02 phos. 0.2 00 00 0.17 53
1 ,1, I-trichloroethane 69 1300 0.09 li ver 0.2 00 00 0.049 10
Benzene 26 67 0.029 0.2 1.5E-05 3.9E-04 00 00
Chromium (10) 8 141 body wgt. 0.2 00 00 0.0008 0.014
Chromium (VI) 8 141 0.005 lung 0.2 00 00 0.16 2.8
1 ,1-dichloroethane 3 110 0.1 skin 0.2 00 00 0.022 0.77
Methylene Chloride 3 10 0.0075 0.06 liver 0.2 3.8E-06 1.5E-05 0.029 0.12
Lead 31 160 0.001 CNS 2.9E-02 00 00 d d
Arsenic 11 200 1.75 0.001 keratosis 2.9E-02 5.5E-04 1.0E-02 1.1 20
Beryllium 5 82 4.30 0.005 lung 2.9E-02 6.1E-04 1.0E-02 0.1 1.6
Nickel 14 165 0.02 2.9E-02 00 00 0.07 0.83
TOTALS
Exposure Factor = 2 Liters/dayl70 kg body weight = 0.029 Liters/day for metals. An additional factor of 6 (i.e. 6 x 0.029) assumed
for volatilization during household use.
b Cancer Risk = Slope Factor x Exposure Factor x Concentration
Hazard Index = (Concentration x Exposure Factor)/Reference Dose
-------
TABLE
4
Carcinogenic and Noncarcinogenic Risks from the
Potential Future Use of Groundwater for Irrigation
... ~ncentration... . Cancet .....Refererice ... Toxic Effect
. Chemical . . / ~mglDl') .. Slope Factor Dose.
...
.MAX;. . (mglkg/day)'1 (rriglkg/day) .
I,I-dichloroetbane 7.3E-04 0.10 skin
I,I-dichloroethylene 3.6E-04 0.175 0.009 liver
trans-I ,2- serum
dichloroetbylene 7.3E-04 0.02 alk. phos.
Tetrachloroethylene 2.0E-02 0.00182 0.01 liver
I,I,I-trichloroethane 9.7E-Q4 0.3 liver
Trichloroethylene 1.4E-Q3 0.00595
. ~:=~#:f
(LIkg/day)/
.. .
...can"..........
.. .-.....
tU~\t
\~~~~
...,...... ...
. "".. ...
..... ..., .
n.. P.. ..... ..
..... ....
,". '''."... .
\ :MA)t)
'. .....
o . "...
. .. .....
.....MAX......
(0.018)
0.008 (0.018)
00
5.I1E-Q7
I.4E-04
7.6E-04
(0.018) 00 6.8E-04
0.008 (0.018) 2. 87E-Q7 3. 7E-02
(0.018) 00 6.IE-Q5
0.008 6.57E-Q8
. Exposure Factor = (IR x EF x ED)/(BW x AT x 365 days/year) = 0.008 for carcinogens, 0.018 for noncarcinogens
where
IR = inhalation rate = 1 m3/hr
EF = exposure frequency = 120 days/year x 4 hours/day
ED = exposure duration = 30 years
BW = body weight = 70 kg
AT = average time = 70 years for carcinogens; 30 years for noncarcinogens
b Exposure factors are given for carcinogens (noncarcinogens)
C Cancer Risk = Slope Factor x Exposure Factor x Concentration
d Hazard Index = (Concentration x Exposure Factor)/Reference Dose
'"
-------
~
8
TABLE
SA VAGE WELL SITE
Milford, New Hampshire
5
EXPOSURE TO VOLA TILES IN AMBIENT AIR - SPRA Y IRRIGA TION
~'Yffl~ .p.:~~.~n.~~"~~~~.~",~.~ffl':~t':;~ir':~i:::}:::'~:::::::::::fW:"
klhel. W8lghl Wlllladan AI< Inhlllal\an EJlpwu,. E",-u,. EJlpwur. Roladv.
CPF of RIO Cofto. Rate Time F,equ.n", Ou,.don Aboatpdon
(mg/llil/day'"- Evldon.. mg"'gIday (mg/m"3' (m"3Ih" (h"day, (daya/Jo") (yO.,o'
C 0.1 7.3E-D4 1 4 120 30
C 0.008 3.8E-D4 t 4 120 30
0.02 7.3E-D4 t 4 120 30
0.01 2.0E-D2 t 4 120 30
0.3 8.7E-D4 t 4 120 30
t.4E~3 t 4 120 30
I, t -,
..- -
:
-------
TABLE 6
Carcinogenic and Noncarcinogenic Risks for
Current and Future Exposure to Trailer Park Brook
Surface Water and Sediment'
Surface Water. . Sediment Cancer . Reference
Chemical Concentration Concentration. d. Slope Factor . Dose Toxic Effect.
(mgIL) .. .. . (mglkg)
. AVO. MAX~ AVO. MAX. (mglkg/day)'I. (mglkg/day) AVQ. MAX;. ...AVO. ..MAX;
Acetone 0.0172 0.0043 0.013 0.051 0.1 liver 00 00 4.IE-06 1.11 Eo05
1 , 1 ~ichloroethane 0.0025 0.0030 0.1 skin 00 00 6.5E-06 7.85E-06
Tetrachloroethylene 0.0075 0.0160 0.051 a.ol liver 8.5Eo08 1.8Eo07 00 1.66Eo03
I, I, I-trichloroethane 0.0049 0.0200 0.09 liver 00 00 00 1.95E-04
Benzene 0.0027 0.0038 0.029 7.4E-09 I.OEo08 00 0.00
Styrene 0.0026 0.0028 0.03 0.02 blood/liver 7.4E-09 8.0E-09 00 1.66Eo03
Trichloroethylene 0.0031 0.00865 0.0036 0.0109 0.011 5.6E-09 1.6Eo08 00 00
Arsenic 1.4 4 1.75 0.001 keratosis 6.5Eo07 1.9E-06 3.5E-03 1.01E-02
Beryllium 0.2 3 4.3 0.005 lung 2.3Eo07 3.4E-06 1.0E-04 00
Cadmium 0.7 0.0005 kidney 00 00 3.5Eo03 5.03E-03
Chromium 29.600 33.000 body wgt. 00 00 7.4Eo05 8.3Eo05
Chromium (VI) 29.600 33.000 0.005 lung 00 00 I.5E-02 l.7Eo02
Lead 13.7 17 ___8 --- . CNS 00 00
Nickel 15.900 18.000 0.02 body wgt. 00 00 2.0Eo03 2.3Eo03
Methylene Chloride 0.0079. 0.026 0.0075 0.06 Ii ver 7.4Eo07 2.5E-06
Chloroform 0.0030 0.0053 0.0061 0.01 liver 1.3E-11 2.3E-1l 1.7E-06 3.0E-06
. ... ". .. ... .. ... ... .... .. .. ... .......
d .... . ..... ...
. .. ",... "" ..... P"" .. ...,..,.. ....
"........ .......... ". ............
S;SE4J6 .... .... . ... '..... S.30E;m ....
TOT AL.s 9:11E'-07 ;J; 784)2<
Note: Risks combine exposure from two groups - young children (2-6 yrs) and older children (7-16 yrs). Exposure routes are dermal
absorption from contact ,with surface water, ingestion of sediment and dermal absorption from co~tact with sediment. Exposure
frequency assumed is 78 days per year. Details of absorption factors and contact rates for exposure to surface water and sediment
can be found in Appendix D of the Risk Assessment.
. No cancer slope factor or Reference Dose available. Levels are below EPA's cleanup level policy values.
-------
TABLE
7
Carcinogenic and Noncarcinogenic Risks for
Potential Future Exposure to Surface Water and Sediment
at the Hitchiner/Hendrix Property
.. . .
..;.: SurfaCe Wat~i'. :
Concentration
. (mg/L) .... H. .
......Sediment.
. Concentration
-. . ...
.. """ . ...
Avo.. HMAx/:AVO.
Acetone
Arsenic
Benzene
Chloroform
Chromium
Chromium (VI)
I,I-dichloroethane
Lead
Methylene Chloride
Nickel
PCB
Styrene
Tetrachloroethylene
Toluene
I, I, I-trichloroethane
0.0574
0.0030
0.0035
0.0027
0.0040
0.0040
0.0023
0.0020
0.0080
0.0032
0.0046
0.0144
0.300
0.005
0.019
0.007
0.018
0.018
0.009
0.008
0.052
0.02
0.029
0.26
0.037
6.4
0.0009
301.2
301.2
0.019
0.012
331.0
1.010
0.006
0.036
0.012
(mgtKg) .
. ... . .
.. ..... "'"
n,. ... .
.. "'.. .... . .. ... ....
M,;.X.; (IilgnCg,dayr~HmgJkglday) H
0.213
11.2
0.0232
621.0
621.0
0.076
0.232
1830.0
8.800
0.007
3.000
0.320
H. Cancer:
.. .
~Iope faCtor
Reference ..
Dose
1.75
0.029
0.1
0.001
0.0061
0.01
0.005
0.1
0.0075
0.001
0.06
0.02
7.7
0.03
0.2
0.01
0.051
0.3
0.09
.. ..
TOTALS
H
Toxic Effect
liver
keratosis
liver
body wgt.
lung
skin
CNS
Ii ver
body wgt.
bloodlliver
liver
liverlkidney
liver
:':"':'".:::';";:,':"":-.""':".';'";';'.':',",.
.. ........ "n... n..
.~~f~r. Ri~.:. <.HO 0..
...... .. .. ..........
lt~~1fd rri~~~.
....
n', .
""",::::/::} ",.,","," ", ,',",",',", "'.'.".',',',', ... ... . ...... . :.. '::":"'.:' :.;.::.".;.;.
.. .... ...... '..',",,",",..'.,",'.',', ,',"",".,",'.,",,",',',"
i.o~YQ.;M~;:i?AY~PM~f
00 00
3.0E-06 5.2E-06
1.0Eo08 5.4Eo08
1.3E-09 3.4E-09
00 00
00 00
00 00
00 00
6.IE-ll 1.2E-09
00 00
9.6Eo07 8.3E-06
5.5Eo08 3.4Eo07
5.3Eo08 3.3Eo07
00 00
00 00
9.2E-06
1.6E-02
9.7Eo05
7.6E-04
1. 5EoO I
7.7E-06
2.0E-05
4.2E-02
4.2Eo05
4.9E-04
I.4E-04
4.9Eo05
2.8E-02
2.6E-04
1.6Eo03
3.IEoOl
2.8Eo05
7.9EoOS
2.2Eo05
2.3EoOl
2.7E-04
3.0Eo03
5.7Eo05
2.6Eo03
. . .. ..
.. ......... . ..",........ ... ........ "'". .. .
. ... ..... ..... .... . .
o:4~O~~i;4~~\.~!~B;;oj :5,,~;;ot)
Risks combine exposure from two groups - young children (2-6 yrs) and older children (7-16 yrs). Exposure routes are dermal
absorption from contact with surface water, ingestion of sediment and dermal absorption from contact with sediment. Exposure
frequency assumed is 78 days per year. Details of absorption factors and contact rates for exposure to surface water and sediment
can be found in Appendix D of the Risk Assessment. .
Note:
-------
TABLE 8
Carcinogenic and Noncarcinogenic Risks for
Potential Work"" Exposure to
Sediment at the Hitchiner/Hendrix Property
. Sedim~nt. .
..E~;~ifn.
..AVG... . MA;C
. Cancer ... .
.. Slope Factor
}~ef~~~ce . ...... ....... ..
... ....Do~. . Toxic Effect
. (mglkg/dayrl
Acetone 0.037 0.213
Arsenic 6.4 11.2 1.75
Chloroform 0.00088 0.0061
Chromium 301.2 621.0
Chromium (VI) 301.2 621.0
I, l-dichloroethane 0.019 0.076
Methylene Chloride 0.012 0.232 0.0075
Nickel 331.0 1830
PCB 1.010 8.800 7.7
Tetrachloroethylene 0.006 0.007 0.051
Toluene 0.036 3.000
1, I ,I-trichloroethane 0.012 0.320
TOTALS
(titglkg/day)
0.1 liverlkidoey (0.41)
0.001 keratosis 0.067 (0.12)
0.01 liver 0.235 (0.41)
(0.12)
0.005 (0.12)
0.1 skin (0.41)
0.06 liver 0.235 (0.41)
0.02 body wgt. (0.12)
0.036
0.01 liver 0.235 (0.41)
0.3 liverlkidoey (0.41)
0.09 liver (0.41)
7.5E~7
1.3E-12
2.0E-ll
2.9E~
7.7E-ll
1.3E~
3.3E-ll
4.1E-I0
2.5E~
8.7E-ll
1.5E~ 8.8E~7
7.5E~ 1.3E~3
3.6E~8 9 .5E~7
3.5E~5 7.3E~5
7.1E~3 1.5E~
7.8E~8 3.7E~7
7.9E~8 1.6E~
1.9E~ 1.1 E~
2.6E~7
4.9E~8
3.0E~7
4.IE~
Note: See Appendix D for chemical specific absorption factors.
. Carcinogens (noncarcinogens)
b Exposure Factor (worker) = «SIR + DIR) * F * D) / (BW * AT * 365 days/year)
SIR = soil ingestion rate (tOO mg/day) * chemical specific absorption factor
DIR = dermal contact rate (500 mg/day) * chemical specific absorption factor
F = frequency = 30 days/year
D = duration = 40 years
BW :::: body weight = 70 kg
AT. = average time = 70 years for carcinogens; 30 years for noncarcinogens
C Cancer Risk = Slope Factor x Exposure Factor x Concentration
d Hazard Index = (Concentration x Exposure Factor) / Reference Dose
5.6E~8
I.5E~
.." "'" ..
...... .....
.. '"'' ... P... ..
. .. ........ '"'''''''''' ''''''''
.<. ~:~OE~:[?j i;~/~~~8fi~:{~:~ /t~~8B~.:}[ :( 2.~~:::\
-------
TABLE
9
Carcinogenic and Noncarcinogenic Risks from
Potential Exposure to Soils under Current Use
at HitchinerlHendrix
Soil. Concentration ..,....., Cancer ...
ChemiCal... . . (mglkg) ... .. . SloPe Fac!of
. .. .. . ...
AVG. MAX. (mglkg/day)"'
Arsenic 8.7 15 1.75
Chromium (VO 19.7 80.5
Lead 7.5 48 ---e
Mercury 0.1 0.275
Nickel 16.2 50.9
PCB 0.500 24.00 7.7
. Referen~e . Toxic. Effect. Exposure facto~'~
. ..:: .OOSe..:.;. . ...
(mgllcg/day)
AVG.
... .... no,''''", ..........
..... ......... ..............
..., ......... ,.........
.. '"' ......... ....... ....
o. .... .........................
\ .~~~..Iti~~
(mgllcg/day) .
0.001 keratosis
0.005
---e CNS
0.0003 kidney
0.02 body wgt.
6.7E-02 (0.12)
(0.12)
(0.12)
(0.12)
(0.12)
1.0E-06
00
00
00
8.3E-02
2.7E-07
.. ... ..... .....
0'"' .. ......
:.'.'.h3g~
. Exposure Factors for Carcinogens (Noncarcinogens)
b Exposure Factor (worker) = «SIR + DIR) * F * D) / (BW * AT * 365 days/year)
SIR = soil ingestion rate (100 mg/day) * absorption factor
DIR = dermal contact rate (500 mg/day) * absorption factor
F = frequency = 40 days/year
D = duration = 30 years
BW = body weight = 70 kg
AT = average time = 70 years for carcinogens, 30 years for noncarcinogens
C Cancer Risk = (Exposure Factor x Concentration x Slope Factor) / l
-------
TABLE
10
Carcinogenic and Noncarcinogenic Risks from
Future Potential Residential Exposure to Soils
at Hitchiner/Hendrix
Soil Concentration ,',.,.', Cancer', "
" ". ""..Cniglicg) '"""""" ,." SlripeFactor
. P.. .. ...
. ....
. """'" . .
. . . "" .
AVG. 'MAX, Cinglkg/day)'.
1.75
Arsenic 8.7 15
Chromium (VI) 19.7 80.5
Lead 7.5 48
Mercury 0.1 0.275
Nickel 16.2 50.9
PCB 0.5 24.0
TOTALS
---e
7.7
"Reference/ >ToXic Effect
".DOSff."
(mglkg/day) .',
0.001 keratosis
0.005
---e CNS
0.0003 kidney
0.02 body wgt.
Exposure '.",
Facto~b ,
(mglkg/day)
3.7E-OI (5.2)
(5.2)
(5.2)
(5.2)
4.IE-01
. Exposure Factors for Carcinogens (Non carcinogens)
8.3E-06
00
00
00
00
2.4E-06
. . .....
. '...
, '.. "S"
>1;lE~ ,{
1.4E-05 4.5E-02 7. 7E-02
00 2.0E-02 8.3E-02
00
00 1.7E-03 4.7E-03
00 4.2E-03 1.3E-02
1.2E-04
.. ... ''''''..".
. ......... ..... .
'" .... .... ...
.,..'i;3B~t
, ,
, ,
. 'P'......
PE4Jt..;jB;,()l/
.. ..
b Exposure Factor = «SIR + DIR) * F * D) / (BW * AT * 365 days/year)
SIR = soil ingestion rate (200 mg for young child, 100 mg/dayall others) * absorption factor
DIR = dermal contact rate * absorption factor
F = frequency = 160 days/year
D = duration = 5 years
BW = body weight = 17 kg for young child, 36 kg for older child
AT = average time = 70 years for carcinogens, 30 years for noncarcinogens
C Cancer. Risk = (Exposure Factor x Concentration x Slope Factor) / lQ6 mg/kg (correction factor)
d Hazard Index = «Exposure Factor x Concentration) / Reference Dose) / lQ6 mg/kg
e No cancer slope factor or Reference Dose available. Soil concentrations are below EPA's Cleanup Level Policy.
-------
TABLE
11
Carcinogenic and Noncarcinogenic Risks from
Potential Exposure to Chemicals in Soils under Current Use
at OK Tool Area
... Soil Reference Toxic Effect. Expoirnre .. ' . '.". .... ... ." ',' ',' ',',..,.,',.',
H ... .. . .. ,...
C~ncenti'ation' c~~eiRi~k" .. . 0"""
" ... ...
Chemic81 . Dose Factor" .. Hazard iilCiex.
(niglkg)./" P
...
.. , p. ".
AVO. ' ..MAx~'.. .... (rilglkg/day)'1 .. .", ..'MAx.
(mglkg/day) (rilglkg/day) AVO.'.... MAxr ....AVO;.
Arsenic 19 204 1.75 0.001 keratosis 1.0EoOl (1.18) 3.4E-06 2.1 Eo05 l.8Eo02 2.0E-Ol
Cadmium 4.6 81 0.0005 kidney (1.18) 00 00 8.9E-03 1.6E-Ol
Chromium (VI) t 10 0.005 (1.18) 00 00 2.0E-03
Lead 23 610 ---d ---d CNS 00 00
Mercury 0.02 0.21 0.0003. kidney (1.18) 00 00 6.5E-05 6.8E-04
Nickel 117 1380 0.02 body wgt. (1.18) 00 00 5.7E-03 6.7E-02
Acetone 0.31 0.31 0.1 liverlkidney (2.97) 00 00 6.7E-06 6.7E-06
Carbon Tetrachloride 0.099 0.099 0.13 0.0007 liver 0.24 (2.97) 3.5E-09 2.6E-09 3.1E-04 3.1E-04
Methylene Chloride 0.0025 0.0025 0.0075 0.06 liver 0.24 (2.97) 5.1E-12 S.2E-09 9.1E-08 9.lE-08
PCB 4.70 10 7.7 8.7E-02 4.3E-06 3.8E-06
Tetrachloroethylene 0.006 0.44 0.051 0.01 liver 0.24 (2.97) 6.0E-09 l.3E-1O 9.6E-05 1.3E-06
Toluene 0.02 0.02 0.3 liverlkidney (2.97) 00 00 1.5E-07 1.5Eo07
Trichloroethylene 0.006 0.006 0.011 0.24 (2.97) l.8E-ll 1.3E-ll
. ...... ... ........... . .....
.... n.. ..... .
.. ...... ..... .... ...., .
. .... . .... "... .... ... .....
. ......... .... i:~~;
TOTALS... . 7 78;.()C5 '" 3~2Ei02/ \4i2itOl
:<'.. .. .. ::~:~:
. Exposure Factor = «SIR + DIR) * F * D) / (BW * AT * 365 days/year)
SIR = soil ingestion rate * absorption factor (200 mg/day for young children, 100 mg/day for older; for absorption factors
see Appendix D of Risk Assessment)
DIR = dermal contact rate * absorption factor (500 mg/day)
F = frequency = 30 days/year
D = duration = 5 years
BW = body weight = 17 kg for young children, 36 kg for older children
AT = average time = 70 years for carcinogens, 5 years for noncarcinogens
b Cancer Risk = Slope Factor x Exposure Factor x Concentration
C Hazard Index = (Concentration x Exposure Factor) I Reference Dose .
-------
TABLE
12
Carcinogenic and Noncarcinogenic Risks from
Potential Exposure to Chemicals in Soils under FtJ:ture Residential Use
at OK Tool Area
Soil Conceitiration .... -. Cancer ..- Reference . - Toxic. Erfect Exposure .... ... .
.... .. . - -
. .... '" .
Chemical (rriglkg) - Slope Facior --DoSe Factor" ~anCer Risk
. ... . "",. ",. .. . .... ".... ".
.. "... ....... . . .... ..... ... . ..
-- .. - '. .. ... ..... .
..... . ".... n..... .. .".
(mglkg/dayj\ ."'..' ,",".","..",
Avo. .-.MAXJ (mg/kg/day)" (mglkg/day) - _--AvO;/ .MAjC--.. AVO; MAx.
.. ..
.. ;:: . ~ ":::':
Arsenic 19 204 1.75 0.001 keratosis 5.3 (5.4) I.4Eo05 1.3E-04 I.IEoOl 1.1E+00
Cadmium 4.6 81 0.0005 kidney (5.4) 00 00 5.4Eo02 8.4EoOl
Chromium (VI) t 10 0.005 (5.4) 00 00 1.1 Eo02
Lead 23 610 ---c ---c CNS c 00 00
Mercury 0.02 0.21 0.0003 kidney (5.4) 00 00 3.9E-04 3.6Eo03
Nickel 117 1380 0.02 body wgt. (5.4) 00 00 3.4E-02 3.6EoOl
Acetone 0.0131 0.31 0.1 liverlkidney (5.4) OQ 00 1.7E-06 1.8Eo05
Carbon Tetrachloride 0.0042 0.099 0.13 0.0007 liver 5.3(5.4) 5.1E-IO 1.1 Eo08 8.0Eo05 1.6E-03
Methylene Chloride 0.0025 0.0025 0.0075 0.06 Ii ver 5.3(5.4) 1.8E-11 1.6E-11 5.SE-07 4.8Eo07
PCB 4.70 10 7.7 6.2 1.7Eo05 3.SE-06
Tetrachloroethylene 0.0067 0.006 0.051 0.01 liver 5.3(5.4) 3.2E-I0 2.5E-tO 8.8E-06 7.0E-06
Toluene 0.0035 0.02 0.3 (5.4) 00 00 1.5Eo07 7.7Eo07
Trichloroethylene 0.0026 0.006 0.011 5.3 2.7E-11 5.4E-11
-- . .... .... ".. '''." """" . .. ". ......
. ...... P'" ....... .. ...... ... ...
...... ........... .. .. ... ... ..
TOTALS . .. - S i4E~) fott.6f 2i3~+oo,...-.
3.1EoO(
. Exposure Factors for Carcinogens (Noncarcinogens)
b Exposure Factor = «SIR + DIR) * F * D) / (BW *AT * 365 days/year)
SIR = soil ingestion rate * absorption factor (ingest. rate = 200 mg/day for young child, 100 mg/day for all others)
DIR = dermal contact rate * absorption factor
F = frequency = 160 days/year
D = duration = 5 years
BW = body weight = 17 kg for young child, 36 kg for older child
AT = average time = 70 years for carcinogens, 30 years for noncarcinogens.
C No cancer slope or Reference Dose available. Contaminant levels are within EPA's Cleanup Policy Values.
-------
. Chemical .
.. .
. Coricentratiorii
H H (mg/l:n~) ..
AVG. ..MAX;H
Acetone 8.7E-05 3.1 E-03
Methylene Chloride 2.5E-06 2.2E-03
Tetrachloroethylene 1.1 E-05 1.2E-02
1, I, I-trichloroethane 2.7E-03 2.1 E-02
TOTALS
TABLE 13
Carcinogenic and Noncarcinogenic Risks from
Exposure to Ambient Air - PTesent Use
Exposure ...;
;.FaCtor--~
. .. . ..
.. .. .
;fjan~~r ~.:i:
. .. . . . ..j!; .
. .. .....
. '. ... ...
.. .
HaZani tnde .\
.. Cancer
. ~lope FaCtor. .....
Reference. ... Toxic Effect.
...:.DOse ...
,',".",',",",".' , ," ",',",".".'.. .". ".',"..".'., ',",',
.. ,'... ....... ... ... ..."'"
M~/.>Ayo~.MA){\
. Exposure Factors for Carcinogens (Noncarcinogens)
.. ...
. . . ..
. .. '.
. . . ..
(mglkg/day)'I. .. (mglkg,day)
','.".:..;.."
-,'..'
. ....
.. ... .....
.. . ...,
. .
. (mglkg/day):', ~ ::'~'A VG{~\ . '"
O. 1 liver (1) 00 00 8.7E-04 3.1 E-02
---e 0.06 (1) 1.2E-09 1.0E-06 4.2E-05 3.7E-02
0.0018 liver 0.28 5.5E-09 6.0E-06
0.3 liver (1) 00 00 8.9E-03 6.9E-02
.. . .. n... ...... . . . ......... .
. H .......... ~i8E~:r ' ...... .
\6:6E.;09} /7;o.E~f 1;4~~r)
b Exposure Factor = (IR x EF x ED)/(BW x AT x 365 days/year) = 0.28
where
For Carcinogens:
IR = inhalation rate = 0.83 m3/hr
EF = exposure frequency = 365 days/year x 24 hours/day
ED = exposure. duration = 70 years
BW = body weight = 70 kg
AT = average time = 70 years
For Noncarcinogens:
IR = 0.42 m3/hr
EF = same as carcinogens
ED = 1 year
BW = 10 kg
AT = 1 year
C Cancer Risk = Slope Factor x Exposure Factor x Concentration
d Hazard Index = (Concentration x Exposure Factor)/Reference Dose
-------
t Endnote for Tables 9 and 10 for OK Tool Soils re: chromium
Hexavalent chromium concentrations are the results from special analytical techniques used on
the additional soil samples collected at the OK Tool Property during the Feasibility Study to
determine how much, if any, of the total chromium was present in the hexavalent state. Because
of its toxicity, hexavalent chromium is the form of chromium of importance in evaluating health
risks. The additional samples were collected only in the areas where maximum total chromium
was found during the Remedial Investigation; therefore, only a maximum concentration is
presented. .
-------
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
APPENDIX C
-------
LOCATION-SPECIFIC ARARS
Federal - Executive Order 11988 - 40 CFR Part 6, Appendix A
Floodplain Management
Applicable
, .
Requires federal agencies to take action to reduce the
risk of flood loss, to minimize impact of floods on
human safety, health and welfare, and to restore and
preserve the natural and beneficial values served by
floodplains.
Measures will be developed to ensure that the
construction and operation of the facility does not
adversely affect the floodplain and that the facility
is designed to withstand any adverse impact from a 100-
year flood.
Federal - Executive Order 11990 - 40 CFR Part 6, Appendix A
Protection of Wetlands
Applicable
Requires federal agencies, to the extent possible, to
conduct activities to avoid the long- and short-term
adverse impacts associated with the destruction or
modification of wetlands.
Actions will be taken to minimize the potential harm to
'the wetlands, to avoid adverse effects to the, wetlands,
and to mitigate any impact on the wetlands.
Federal - 40 CFR 230
Clean Water Act - Guidelines for Specification of Disposal
Sites for Dredged or Fill Material
Applicable
No discharge of dredged or fill material is allowed if
there is a practicable alternative having less adverse
impact on the aquatic ecosystem so long as the
alternative does not have other significant adverse
environmental consequences.
-------
Federal - 16 U.S.C. 661
Fish and Wildlife Coordination Act
applicable
Requires federal agencies to consider
water-related projects will have upon
and to take action to prevent loss or
resources.
the effect that
fish and wildlife
damage to those
Contact with appropriate federal agencies will be
maintained during construction and operation of the on-
site treatment system(s).
state - RSA 485-A:17
DrE!dging and Control of Run-off
Env-Ws Part 415
Dredging Rules
Applicable
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. Activities within the scope of these
provisions include excavation, dredging, filling,
mining, and grading of topsoil in or near wetland
areas.
Any significant excavation in or around the Souhegan
River or other large surface water bodies on-site will
be coordinated through NHDES and in accordance with all
requirements of this regulation.
state - RSA 482-Ai Env-Wt Parts 300-400, 600
criteria and Conditions for Fill and Dredge in Wetlands
Applicable
Regulate filling and other activities in or adjacent to
wetlands, and establish criteria for the protection of
wetlands from adverse impacts on fish, wildlife,
commerce, and public recreation.
All activities within the on-site wetland and
floodplain areas will comply with the wetlands
protection requirements.
-------
state - He-P 1905.09
Hazardous Waste Facility siting criteria
Relevant and appropriate
Owners and operators required to identify whether the
facility is or will be located within a 100-year
floodplain. Flood control measures must be identified.
Similarly, new facilities located within 3,000 feet of
faults displaced in Holocene times must show that no
faults pass within 200 feet of the facility.
Siting of the treatment facility will be done in
accordance with these regulations.
-------
CHEMICAL-SPECIFIC ARARS
Federal - 40 CFR 141.11 - 141.16
Safe Drinking Water Act - Maximum Contaminant Levels
Relevant and Appropriate
MCLs have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the concentration of contaminant in public
drinking water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
. potentially used for drinking water.
MCLs will be attained in the groundwater.
Federal - 40 CFR 141.50 - 141.51
Safe Drinking Water Act - Maximum Contaminant Level Goals
Relevant and Appropriate
..
Non-enforceable health-based limits set at a level at
which no adverse effects on a person's health exist.
For non-carcinogens where the MCLG is set at a
threshold level above zero, the MCL is nearly always
set at the same level as the MCLG. For carcinogens,
many MCLGs are set at zero.
Since MCLs exist for the contaminants of concern in the
groundwater and those MCLs will be attained by the
implementation of the remedy within 25 to 90 years, t'he
MCLGs set at 0 will not be attained.
Federal - 33 USC 304(a) (1) .
ClE~an Water Act - Ambient Water Quality Criteria -
Prc)tection of Freshwater Aquatic Life, Human Health
Consumption
- Fish
Relevant and Appropriate
AWQC are health-based criteria developed for chemical
constituents in surface water. They have been
developed to protect aquatic life and human health from
harmful effects due to exposure to chemically impacted
surface water. AWQC can be more stringent than MCLs if
it is necessary to protect aquatic organisms. The more
stringent AWQC for aquatic life will be relevant and
appropriate under certain circumstances.
-------
Federal - 40 CFR Part 50
Clean Air Act - National Ambient Air Quality standards
Relevant and Appropriate
Define levels of air quality necessary to protect
public health with an adequate margin of safety.
Secondary standards define levels of air quality
necessary to protect public welfare from any known or
anticipated adverse effects of a pollutant.
The on-site air stripper will have its off-gas treated
to ensure that any discharge to the ambient air meets
pertinent regulations.
. -
Federal - u.S. EPA Reference Doses (RfDs)
To be considered
Dose levels developed by EPA to protect sensitive
individuals over the course of a life-time. RfDs
reflect a daily exposure level likely to be without
appreciable risk of adverse health effects.
These standards have been considered in the
determination of cleanup levels.
Federal - u.S. EPA carcinogen Assessment Group Potency Factors
To be considered
Cancer potency factors are developed by EPA from the
Health Effects Assessment (HEA) (U.S. EPA, 1985) or
from evaluations by the Carcinogen Assessment Group
(CAG) (U.S. EPA, 1985)
These standards have been considered in the
determination of cleanup levels.
State - Env-Ws 410.05(e)
Health-based Groundwater Protection Standards
To be considered
c
Provide that groundwater shall not contain any
substance which the Water Supply and Pollution Control
Division determines may be harmful to human health or
the environment. In determining applicable standards,
WSPCD may refer to health advisory limits established
-------
by the New Hampshire Division of Public Health
Services.
Require remedial action to eliminate discharge of
substances which may be harmful to health or the
environment, and which may include substances exceeding
the 10.6 cancer risk health advisory limits established
by DPHS.
State - Env-Ws 410.09
cri.teria for Groundwater Discharges
Applicable
Establishes groundwater discharge criteria which
include MCLs and MCLGs adopted by the Water Supply and
Pollution Control Division.
Require remedial action to eliminate discharge of
contaminants including VOCs and inorganic contaminants
resulting in groundwater contamination above State MCL
and MCLG levels.
state - Env-Ws Parts 315-317
Drinking Water Quality Standards - Maximum contaminant
Levels and Maximum contaminant Level Goals
Relevant and Appropriate
New Hampshire MCLs establish levels of contaminants
allowable in public water supplies. They are generally
equivalent to the MCLs established by the Safe Drinking
Water Act.
Allowable levels will be attained in the
discharge from the groundwater treatment
Allowable levels will be attained in the
25 to 90 years.
effluent
system.
aquifer within
State - Env-Ws 432
Surface Water Quality Standards
Applicable
Establish water quality criteria
The criteria are essentially the
ambient water quality criteria.
established for fresh and marine
for toxic substances.
same as the federal
Criteria are
waters.
-------
Discharge to surface waters in or adjacent to the site
must meet these standards.
state - Env-A 300, Parts 303 and 304
Ambient Air Quality Standards
Relevant and Appropriate
Set primary and secondary ambient air quality standards
equivalent to federal standards. The standards do not
allow significant deterioration of existing air quality
in any portion of the state for particulate matter,
sulfur dioxide, carbon monoxide, nitrogen dioxide,
ozone, hydrocarbons, lead, and fluoride.
The on-site air stripper will have its off-gas treated
to ensure that any discharge to the ambient air meets
pertinent regulations.
state - Env-A 1300
Toxic Air Pollutants
Applicable
Establishes
Ambient air
ambient air
contaminant
ambient air limits for 74 chemicals.
limits (AALs) are levels at or below which
concentrations of a respective air
will not adversely affect human health.
Any discharge to the ambient air from the on-site air
. stripper will meet the pertinent regulations.
-------
ACTION-SPECIFIC ARARS
Federal - 40 CFR Part 262, Subparts A-D
RC]~ - Standards Applicable to Generators of Hazardous Waste
Applicable
Establishes manifesting, pre-transport, and
recordkeeping and reporting requirements for generators
of hazardous waste.
Any hazardous waste shipped off-site will comply with
these requirements.
Federal - 40 CFR Part 122
EPA Administered Permit Programs:
Discharge Elimination System
The National Pollutant
Applicable
Basic permitting requirements for the discharge of
pollutants from any point source into waters of the
united States.
Effluent from the treatment system will meet the
substantive requirements of the NPDES program.
Federal - 33 CFR Parts 320-329
Regulation of Activities Affecting Waters of the United
States
Applicable
U.S. Army Corps of Engineers permit program identifying
federal statutes, policies, and procedures applicable
to:
--dams or dikes:
--other structures or work including excavation,
dredging and/or disposal activities:
--activities that alter or modify course,
condition, location, or capacity:
--construction of artificial diversions or other
devices: .
--discharges of dredged or fill material:
--transport of dredged material for disposal in
ocean waters: .
--nationwide general permits.
-------
Any remedial activities such as the installation of
discharge or collection pipes conducted along the
Souhegan River will comply with these regulations.
Federal - 40 CFR Part 61
National Emission Standards for Hazardous Air Pollutants
Applicable
\~
Establishes standards for e~issions of designated
hazardous air pollutants.
Emissions from the on-site air stripper will comply
with all pertinent standards.
state - RSA 485-A:13; Env-Ws 410
Protection of Groundwater
Applicable
Regulates discharge to groundwater and provides for
groundwater protection. Prohibits discharge of
hazardous waste to groundwater or any discharge to
groundwater that results in a degradation of surface
water quality in adjacent surface waters. Prohibits
alteration of groundwater so as to make it unsuitable
for drinking water.
Discharges to the groundwater will meet pertinent
standards.
state - RSA 485-A:12
Water Pollution and Waste Disposal
Applicable
Prohibits the disposal of wastes in a manner lowering
the quality of any surface water below the minimum
requirements of the surface water classification.
Specific standards for classification of surface waters
are found at RSA 485-A:8.
Discharges from the treatment system will meet all
federal and state discharge standards and will not have
any adverse impact on receiving surface water bodies.
-------
state - New Hampshire Administrative Code Env-Wm, c. 500
Manifesting Requirements
Applicable
a
Requirements for manifesting and recordkeeping.
Shipments of treatment residuals from the site will be
properly manifested and handled in accordance with
these regulations.
state - New Hampshire Administrative Code Env-Wm, c. 500
Packaging and Labeling Requirements
Applicable
Requirements for labeling and packaging shipments of
hazardous waste.
shipments of treatment residuals from the site will be
properly labeled and packaged in accordance with these
regulations.
.
state- New Hampshire Administrative Code Env-Wm, c. 500
Standards for Generators
Applicable
Establishes requirements for generators of hazardous
waste including persons transporting treatment
residuals.
Generators of hazardous waste will obtain a generator
ID number and will perform recordkeeping in accordance
with these regulations.
state - New Hampshire Administrative Code Env-A, Part 1002
Fugitive Dust Emission Control
Applicable
Requires precautions to prevent, abate, and control
fugitive dust during specified activities including
excavation, construction, and bulk hauling.
Necessary precautions to control fugitive dust
emissions will be implemented during and after site
remediation.
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state - New Hampshire Administrative Code Env-A, Part 1204
Control of VOC Emissions
Applicable
Specifies VOC emission control methods and establishes
limitations on VOC emissions for various process
categories.
Precautions will be taken during excavation and grading
to minimize VOC emissions. Controls will be placed on
all air emissions from the treatment equipment to
minimize VOC emissions to the ambient air.
state - Env-Ws 346, 347, and 700
Sewage and Wastewater Treatment Systems - Best Available
Technology
Applicable
Requires use of best available technology when treating
organic and inorganic contaminants in wastewaters.
Remedial activities aimed at achieving MCLs for organic
and inorganic contaminants will use the best available
technology.
State - Env-A, Part 800
Testing and Monitoring Procedures
Applicable
Require emission testing and ambient air quality
monitoring. Establish procedures for VOC testing and
Continuous Emission Monitoring.
Remedial measures generating air emissions will be
tested to ensure the attainment of pertinent standards.
State - Env-A, Part 900
Owner and Operator Obligations
Applicable
Require owners and
pollutants to keep
emitted. Identify
"requirements.
operators of sources discharging air
records of quantities of pollutants
general and VOC record keeping
-------
operational records for the treatment facility will be
maintained.
state - Env-We 604
Abandonment of Wells
Applicable
Abandoned wells must be sealed to prevent the entry of
contaminants into the groundwater.
Once monitoring wells are no longer needed, the wells
will be sealed.
state - RSA 125-C: Env-A 604-606
Air Pollution Control
Relevant and Appropriate
Establishes standards for the release of air emissions
including VOC's and hazardous air pollutants.
Applicable standards include the most stringent of the
following requirements:
1) New source performance standards (40 CFR
Part 60):
2) National Emission standards for Hazardous Air
Pollutants (40 CFR Part 61):
3) New Hampshire state Implementation Plan
limits. .
Discharges of contaminants to the air from treatment
operations shall be restricted and treated to ensure
that no regulatory air discharge limits are exceeded.
-------
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
APPENDIX D
-------
United States
Environmental Protection Agency
Region I
SUPERFUND
Responsiveness Summary
Savage Municipal Water Supply Site
Milford, New Hampshire
-------
Table of Contents
Preface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
.-
I.
Overview of Remedial Alternatives Considered in the
Feasibility Study. . ; . . . . . . . . . . . . . . . . . . .. . . . . . . . . . '. . . . . . . . . . . . . . . . .. 2
II.
Site History and Background on Community Involvement
and Concerns. . . . . . . . . . . . . . . ; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
m. Summary of Comments Received During the Public
Comment Period and EPA Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
Part A - Citizen Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
Part B - State Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
Part C - Potentially Responsible Party Comments. . . . . . . . . . . . . . . . . .. 30
IV. Remaining Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 39
Attachment A
Formal Community Relations Activities Conducted To Date at
the Savage Municipal Water Supply Superfund Site
Attachment B
Transcript of the July 29, 1991 Informal Public Hearing
Attachment C
Paul Harvey Article and EP A Region X Response
Attachment D
'"
-------
Preface
The U. S. Environmental Protection Agency (EPA) held a public comment period
from July 12, 1991 to August 10, 1991 to provide an opportunity for interested parties to
comment on"the Remedial Investigation (RI), Feasibility Study (FS), and the Proposed Plan
prepared for the Savage Municipal Water Supply Superfund site in Milford, New Hampshire.
The FS examines and evaluates various options, called remedial alternatives, to address
groundwater contamination at the site. EP A identified its preferred alternative for addressing
groundwater contamination in the Proposed Plan issued in July 1991, before the start of the
public comment period. All documents for the site were placed in an Administrative Record
for public review. The Administrative Record is a collection of all documents considered by
EP A in choosing the remedy for the site. The Administrative Record was made available at
the EPA Records Center at 90 Canal Street in Boston, Massachusetts, and at the Wadleigh
Memorial Library at 21 Nashua Street in Milford.
. The purpose of this Responsiveness Summary is to document EPA responses to the
questions and comments raised during the public comment period. EPA considered all of
these: questions and comments before selecting the fmal remedial alternative to address
contamination at the Savage Municipal Water Supply Superfund site. Details of EPA's
decision on the cleanup remedy itself are contained in the Record of Decision of which this
Responsiveness Summary is a part.
...
Savage Municipal Water Supply Superfund Site
-------
I.
Overview of Remedial Alternatives Considered in the Feasibility
Study .
Based OD the results of the RI and Risk Assessment, EPA developed the fonowing
cleanup objectives for groundwater at the site:
. Prevent ingestion of contaminated groundwater that would pose an
unacceptable risk to human health; and
Restore groundwater quality to meet federal and state Applicable or
Relevant and Appropriate Requirements (ARARs).
EP A screened and evaluated a total of 17 potential cleanup alternatives for the site in
the FS. The FS desaibes the remedial alternatives considered as wen as the screening
criteria used to narrow the list to 11 potential remedial alternatives. The Proposed Plan and
the FS should be consulted for a detailed explanation of these remedial alternatives.
Preferred Alternative. EPA's preferred alternative, MM-IlA, has three components:
1) extraction of 1100 gallons per minute (gpm) of contaminated groundwater from five new
weDs and from the Savage Well itself; 2) treatment of the extracted water to federal and
state drinking water standards by air stripping and carbon adsorption or by ultraviolet-
oxidation; and 3) discharge of the treated water into the Souhegan River, to the Hitchiner-
Hendrix discharge stream, or to the aquifer. The preferred alternative would treat the most
concentrated portions of the plume near OK Tool and Hitchiner, much of the extended
plume south of the river, and the most contaminated portions of the plume north of the river.
Some portions of the extended plume will be allowed to naturally attenuate. Institutional
controls will be implemented to restrict access to the groundwater. Long-term monitoring
win be conducted. Remediation will take 15-60 years to complete.
Other Alternatives. The ten other remedial alternatives considered in detail by EP A
are described briefly below.
.
Alternative 1: No Action No removal, containment, or treatment of contaminated
groundwater would take place. Long-term monitoring would be conducted.
Remediation would take at least 100 years to complete.
Alternative 2: Umited Action Institutional controls would be implemented to
restrict access to the groundwater. The entire plume would be allowed to naturally
attenuate, and no groundwater removal, containment, or treatment would be
performed. Long-term monitoring would be conducted. Remediation would take at
least 100 years to complete.
Alternative 3/3A: The concentrated portions of the plume near OK Tool and
Hitchiner would be treated at a rate of 400 gpm, but the remainder of the plume
would naturally attenuate. Institutional controls and long-term monitoring would be
included. Groundwater would be treated by either air stripping alone (3), or air
stripping and ultraviolet oxidation (3A). Remediation would take 25-90 years to
complete.
Alternative 7/7A: The concentrated portions of the plume near OK Tool and
Hitchiner and the middle section of the extended plume would be treated at a rate of
1225 gpm. The remainder of the plume would naturally attenuate. Institutional
controls and long-term monitoring would be included. Groundwater would be
treated by either air strippi~g alone (7), or air stripping and ultraviolet oxidation
(7A). Remediation would take 15-65 years to complete.
Alternative 9/9A: The concentrated portions of the plume near OK Tool and
Hitchiner and almost all of the extended plume south of the river would be treated at
2
-------
a rate of 1150 gpm. The remainder of the plume would naturally attenuate.
Institutional controls and long-term monitoring would be included. Groundwater
would be treated by either air stripping alone (9), or air stripping and ultraviolet
oxidation (9A). Remediation would take 20-85 years to complete.
Alternative 10: The concentrated portions of the plume near OK Tool and Hitchiner
and almost all of the extended plume south of the river would be treated at a rate of
2975 gpm. The remainder of the plume would naturally attenuate. Institutional
controls and long-term monitoring would be included. Groundwater would be
treated by air stripping alone. Remediation would take 10-30 years to complete.
Alternative 11 This alternative is the same as the preferred alternative except that air
stripping alone would be used for groundwater treatment. No ultraviolet oxidation
would be used for groundwater treatment.
II.
Site History and Background on Community Involvement and
Concerns
Site History
The Savage Municipal Water Supply site is located in the town of Milford, New
Hampshire, about two miles west of the town center. The area around the site includes
residences, farms, and light and heavy industry. .
Four major industrial plants are situated to the west of the Savage Well: Hendrix
Wire and Cable Corporation; Hitchiner Manufacturing Company, Inc.; OK Tool Company;
and New England Steel Fabricators, Inc (NESFAB). From the 1940s until the 198Os, process
waters and wastes from these plants were released untreated onto the ground or into the
Hitchiner /Hendrix discharge stream which flows into the Souhegan River.
In 1983, a New Hampshire Department of Environmental Services (NHDES)
inspection of the OK Tool plant found that a degreasing tank had been directly connected to
a drain in the plant floor, and that the area located north of the plant showed signs that oily
wastes and other materials had been disposed of onto the ground. NHDES ordered OK Tool
to cease the discharge of any waste and to begin an investigation to determine the extent of
the contamination.
In 1983, as part of a routine sampling of water supplies, NHDES analyzed water
from the Savage Well and found several volatile organic compounds (VOCs) above drinking
water standards. These VOCs, which are commonly used as solvents, were also found in the
water from the well supplying the nearby mobile home park. The Savage Well and the trailer
park well were shut down because the water was unsafe to drink. The 75 residents of the
mobile home park were connected to the town's water supply using EPA Superfund
emergency funding.
In 1984 the Savage Municipal Water Supply site was placed on EPA's National
Priorities List (NPL) of hazardous waste sites under the Superfund program.
In 1985, EPA notified OK Tool, Hitchiner, Hendrix, and NESFAB that they may
have contributed to the site contamination and therefore are Potentially Responsible Parties
(PRPs). In 1987, these four PRPs signed a legal settlement in which they agreed to perform
the R.I and FS for the site under EP A supervision. The studies began in 1988 and are now
complete.
Savage Municipal Water Supply Superfund Site
-------
Community Involvement and Concerns
Community concern surrounding the contamination and EPA's activities at the site
was moderate until the release of the Proposed Plan. Approximately 45 people attended the
August 1990 public meeting on the results of the RI. Comments received at that meeting
focused on the following issues:
.
Delays in construction of a replacement for the North Street Bridge;
Risks posed by commercial/industrial use of the OK Tool property;
Potential reuse of the contaminated aquifer as a water supply;
Rights and liabilities of landowners on the site; and
Potential migration of groundwater contamination.
. '0
.
.
Following the release of the Proposed Plan, community concern increased
dramatically. On May 28, 1991 EP A held a public informational meeting to present the
Proposed Plan and more than 200 people attended, many of whom were employees of the site
PRPs. Public comments at that meeting focused on the potential economic stress the cleanup
might place on the PRPs. In general, the audience was critical of the amount of money
required for EPA's preferred alternative and questioned EPA's choice of the preferred
alternative over other less costly alternatives. They were also concerned over the proportion
of the cleanup cost that Hitchiner and Hendrix might have to bear, and they expressed the
opinion that these two PRPs should only have to bear costs in proportion to their contribution
to the contamination problem. Only one resident spoke in direct support of EPA's cleanup
effort.
A complete list of community relations activities conducted at the site is included in
Attachment A at the end of this document.
III.
Summary of Comments Received During the Public Comment Period
and EP A Responses
. This Responsiveness Summary addresses the comments received by EPA concerning
the FS and Proposed Plan for the Savage Municipal Water Supply Superfund site in Milford,
New Hampshire. Forty-one sets of written comments were received during the public
comment period (July 12 - August 10, 1991). These included a statement signed by 66
employees of Hitchiner's Littleton plant. Thirty-six people provided oral comments at the
July 29, 1991 informal public hearing, which was attended by more than 230 persons. In
addition to residents, commentors included representatives of the Town of Milford,
neighboring towns, and some of the PRPs. Many of those making comments were employees
of Hitchiner or Hendrix. A copy of the transcript of the public hearing is included as
Attachment B.
Citizen Comments
Many of the comments received during the comment period were associated with the
overall cost of the proposed remedy, and particularly with who ultimately would have to bear
that cost. The com mentors expressed fears that the financial impact on Hitchiner and
Hendrix of implementing the proposed remedy could drive both industries out of business
with disastrous financial and social impact on the Town of Milford and its residents.
EPA understands the fears and concerns expressed by the public, particularly given
the current economic climate in southern New Hampshire as well as in most of the northeast.
EPA is bound by federal law to select remedies that comply with specific criteria set forth in
A.
4
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the Comprehensive Environmental Response, Compensation, and Liability Act (CERClA).
One such criterion is that the remedy accomplish the environmental objectives of the statute
in a cost-effective way. EPA believes that the selected remedy is cost-effective in that it
achieves environmental protectiveness within an acceptable period of time at a cost that is
proportional to the protection it affords.
The remedy selection process is distinct from the process whereby EP A seeks to hold
responsible parties liable for the cleanup costs. EPA may not properly base a remedy
selection decision on the fmancial circumstances of particular responsible parties. In
negotiating with the responsible parties for performance of the remedy and for payment of
response costs, however, EPA can and will take into account any information relating to
ability to pay that the negotiating parties choose to bring to EP A's attention.
EP A acknowledges the high level of public interest in this site and appreciates the
level of concern that has been shown by the community. Public participation is vital to the
cleanup process that Congress envisioned under CERClA. EPA encourages the community
to remain actively involved with the site as it moves into the Remedial Design and Remedial
Action phases of the cleanup.
The comments from citizens given at the public hearing and in writing are
summarized below along with EP A responses. The comments are organized in the foUowing
categories:
Impact of the Cost of the Cleanup on Local Employers and the Community
Source of the Contamination
PRP Negotiations and Cost Allocation
Preferred Alternative
Other Issues
Impact of the Cost of the Cleanup on Local Employers and the Community
COMMENT 1: A State Senator, the Milford Selectmen, a fonner Milford Selectman, the
Littleton Selectmen, and many citizens from Milford and other towns stated that they were greatly
concemed over the possibility that Hitchiner alld Hell(irix might go out of business and/or lay off
large numbers of employees if they must bear most of the financial burden for the cleanup. They
felt such layoffs would ha\'e a severe negative impact all the towns where Hitchiner plants are
located. Statements from the Littleton Selectmen and a number of employees from the Hitchiner
plant in Littleton described the importance of Hitchiner to Littleton and expressed their desire to
see Hitchiner remain a financially stable compal'Y in the state. A citizen commented that
proteC'lion 01 the ellvironment should include consideration 01 the quality 01 life and the health
of the economy in the local community. The Milford and Amherst Selectmen stated that EPA
must consider the impact of EP A's decisions at the site on the entire community, not just the .
PRPs. The Milford Selectmen stated that the choice of remedy and the allocation of financial
liability lor the site cleanup must cause no hann to the town, its taxpayers, or its tax base; and
pose 110 threat to the viability, marketability, and fillancial soundness of Hitchiner, Hendrix, and
other parties. Many citizens commented that the health 01 the entire community will be
detem1ined by EP A's decisions regarding the site cleanup. One citizen commented that a clean
aquifer is not worth the loss of any of the town's major employers or the unemployment and
depopulation of the town that would result from such a loss. TIle Milford Selectmen noted that
the town's already strained finances would be severely affected by the additional services and
benefits that would be required by the unemployed workers and by the loss of tax revenues. A
member of the Milford Planning Board commented that, if Hitchiner and Hendrix shut down,
approximately one lourth 01 the households in the town would be directly affected and that a
30% increase in taxation would result. One citizen commented that Hitchiner was already
Savage Municipal Water Supply Superfund Site
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financially strained and that any additional burden could produce layoffs. Two citizens
expressed fear that such layoffs would drive their families into poverty; one asked whether this
potential impact disturbed EP A. One citizen suggested that EP A staff does not have sympathy
for those who may be laid off because EP A staff are well paid professionals, established in their
fields, and would never be faced with requiring welfare assistance for their fami/ies. A citizen
requested that EPA decision makers consider how they would feel if a govemment agency came
to their town and made a decision they considered very unfair and that would lUin the
employment base and the property values in their town.
RESPONSE: EP A acknowledges the concerns expressed at the public hearing and in the
letters EPA has received. EPA recognizes the community's apprehension over potential
employment losses, the town's tax base, the quality of life, and the economic health of the
region. In keeping with CERCLA's mandate, EPA's goal in selecting the remedy for the site
is to protect public health and the environment and to clean the aquifer in a reasonable time.
Under CERCLA, cost is also one of the criteria for consideration in the selection of a
remedy. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
provides that costs shall be considered in relation to the overall effectiveness of the
alternatives in order to determine which alternatives offer results proportional to their costs
such that they represent a reasonable value for the money. The NCP further explains that
alternatives providing effectiveness and implement ability similar to that of other alternatives,
but at greater cost, may be eliminated.
In proposing alternative MM-11A as the remedy for this site, EPA was careful to
select the lowest cost remedy that would achieve the cleanup goals. The well placement
strategy embodied in alternative MM-11A was designed to capture the areas of highest
contamination with the fewest possible number of wells. Alternative MM-11A also employs
the best and most cost-effective treatment methods available today. EPA rejected other more
aggressive treatment alternatives in favor of the one that struck the best balance between cost
and overall effectiveness. EP A understands the interest of the community in knowing
precisely how the funding of the selected remedy will be allocated. CERCLA provides for a
negotiating period during which EP A and the PRPs work together to achieve a mutually
acceptable agreement for the funding of the cleanup. However, negotiations cannot begin
until the remedy has been selected. Therefore, EP A is unable to say at this time precisely
how the remedy will be funded.
COMMENT 2: A citizen commented that an expedient resolution of the cleanup method and
liability issues will be clUcial to the future prosperity of the community because only. when these
matters are resolved will local businesses be able to plan and grow.
RESPONSE: EPA is committed to working toward an expedient implementation of the
selected remedy as well as resolution of the liability issues at the site.
COMMENT 3: A resident stated that EP A's cost estimates for the preferred alternative did not
take into account the possibility that the treatment plants may 11m much longer than 30 years
and that costs would continue to affect Hitchiner and Hendrix during that time.
RESPONSE: EPA's cost estimates for the remedial alternatives that were evaluated in the
Feasibility Study (FS) were calculated in the same manner based on a 30 year operating time.
A 30 year time frame was selected for two reasons: (1) achieving the site cleanup goals would
be likely to take 30 years or more for any of the alternatives, and (2) costs beyond thirty years
do not have a significant value in terms of today's dollars as illustrated in Section 4.5 of the
FS. Converting future expenditures to values in today's dollars is ~lIed net present value
analysis. The fundamental question answered by net present value analysis is what amount of
money must be invested today at an assumed interest rate (10%) to assure full funding over
6
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the lifetime of a given alternative. All of the total costs for the alternatives were converted to
their net present value for comparison. The impact of costs beyond 30 years on net present
values can be shown by the following example: the net present value of MM-11A over 60
years is $16.3 million while its net present value over 30 years is $15.5 million. As
demonstrated in this example, costs beyond 30 years may be funded with only a relatively
small investment in today's dollars. Net present value analysis is used because it takes into
account the fact that money may be invested over time. Simply multiplying the annual
operation and maintenance cost of an alternative by the number of years over which it will
operate does not reflect the fact that money available today is more valuable than the same
amount of money in the future. Therefore it is not as realistic a method of comparing the
totaJI cost of different alternatives as net present value analysis.
COMMENT 4: One citizen stated that govemment should be encouraging companies to strive
and grow and, in particular, to build overseas business to secure the economic health of the state
and nation rather than forcing management to expend their resources trying to defend the
compa~y against prosecution for crimes they did not commit. The Milford Cabinet also noted
that Hitchiner and Hendrix produce products that the nation needs.
.
RESPONSE: EPA acknowledges the public's concern over the nation's economic health.
Through the enactment of environmental laws, Congress has established that the protection of
public health and the environment are also national priorities. In enacting CERCLA,
Congress created a scheme for the selection of remedies and for the allocation of costs
associated with cleaning up hazardous waste sites. That scheme takes into account economic
cont:erns. EPA is required to carry out the program established in CERCLA.
COMMENT 5: The Milford Cabillet asked how much damage EPA has done to the nation's
ecollomy by forcing cun-ell/lalldowllers to pay for pollution caused by fonner owners. The paper
also asked how many industrial properties remaill ullsold alld ullused due to the risk of liability
for the cleanup of exiStillg cO,ltami/latioll.
RESPONSE: EPA acknowledges the public's concern over' the nation's economy. However,
there is little agreement on the effects of specific factors on the national economy. Although
CERCLA's primary mandate is to protect public health and the environment, another goal of
the program is to encourage sound waste management practices by private industry.
COMMENT 6: 17le Littletoll Selectmell stated that the fulldillg for the technology to be used in
the cleallup should be "amortized" over a time period sufficiellt to allow the companies involved
to remain viable.
RESPONSE: In the context of seulement negotiations, EP A will entertain any good faith
proposals for PRP-fmancing of the remedy. . EPA will consider economic viability issues
raised by the parties involved in the negotiations.
Source or the Contamination
COMMENT 7: A citizen asked what blfon7latioll EPA has regarding the hazardous waste
handling and disposal practices of other finns and illdividuals ill the site area who could have
cOII/ributed to tlte contamination. 17le citizen asked EPA to idelltify otlterS in the area who
migltt be PRPs. He also asked whether EPA was plallnillg to name any additional PRPs and
wilY EP A Itas not pursued any other persolls or compallies located lIear tlte site.
Savage Municipal Water Supply Superfund Site
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RESPONSE: EPA's enforcement process for this site, including the search for other PRPs, is
continuing. Because the process is not complete, EPA cannot comment on the investigations
at this time.
COMMENT 8: Many citizens stated tile belief tllat tile vast majority or all of the contamination
in tile aquifer originated from OK Tool, based on tile site studies in 1983 as well as more recent
RI/FS work. Olle residellt asked wily EPA lias IIOt public~v identified OK Tool as being
responsible for 95 percent to 100 percent of the pollution ;n the Savage Well. He suggested that
EPA had not made tllis public statemellt because EPA wislles to implicate PRPs who are
finallcially so/~'ellt, and therefore, potentially able to pay for the cleanup.
~.
RESPONSE: The purpose of the RIfFS process is to determine the nature and extent of
contamination, assess potential risks to human health and the environment, and, if necessary,
develop alternatives for site cleanup. In determining the extent of contamination, the RI does
attempt to determine the physical location of contamination and the direction of its
movement. This information has been documented in the site reports which arc available to
the public. However, the RIfFS process itself does not draw any conclusions regarding who
was responsible for causing the contamination or who is financially liable for the cleanup.
Through its enforcement process, EPA develops a list of PRPs that may be
responsible for the site contamination. However, CERCLA provides that the question of
financial liability for site cleanups ....;11 be resolved through negotiations, settlements, and,
potentially, court decisions. Until those processes have concluded, EPA is unable to predict
which parties will pay what amount of the cleanup costs. Enforcement investigations are
continuing and new information may become available that will affect the final allocation of
financial liability.
COMMENT 9: Se~'eral citizells commellted tllat OK Tool was tile ollly Olle of the four major
PRPs tllat used tetrachloroethcllc (PCE), olle of tllc cOlllamitlallts found at the site.
RESPONSE: Based on information available at this time, Hitchiner also used a relatively
small quantity of PCE at its Milford plant. However, records for all of the PRPs may not be
complete throughout the entire history of their operations in the area. As noted above,
EPA's enforcement investigations are continuing and may result in additional information
regarding the past chemical use and disposal practices at Hitchiner, Hendrix, OK Tool, and
NESFAB.
COMMENT 10: A residelll commellled tllat, prior to COllstruction of tile new water pollution
buildillg, Hitcl,iller disposed of large qllalllities of waste chemicals illlo floor draills and the
Hitclliller/Helldrix discharge stream alld, tllerefore, Hitchiller sllould be held responsible for 90
percellt of the cost of the cleallup,
RESPONSE: As noted above, EPA's enforcement investigations are continuing and may
resull in additional information regarding the past chemical use and disposal practices at
Hitchiner, Hendrix, OK Tool, and NESFAB. EPA welcomes any additional information
regarding past chemical handling and disposal practices at these plants or any other facilities
near the site which may have impacted the aquifer. Anyone wishing to discuss such
information is encouraged to contact Richard Goehlert at (617) 573-5742. The issue of
financialliability, however, is a matter for future negotiations between EPA and the PRPs.
8
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Tbe PRP Negoiiations and Cost Allocation
COMMENT 11: A State Senator requested tit at tlte public be given the opportunity to comment
on tlte process tltat will determine fi/lancial responsibility for tlte cleanup. A resident asked
whetlter the final amounts to be paid by eaclt PRP for the site cleanup will be made public,
noti/lg tit at tlte community has a rigltt to know tltis infonnatio/l.
RESPONSE: Although the actual negotiations with the PRPs are conducted in private, the
public is given an opportunity to comment on the settlement agreement. After an agreement
is reached, the government lodges the consent decree in federal district court as well as
providing notice of the consent decree in the Federal Register. Upon publication of the notice
in the Federal Register, the public has 30 days in which to submit written comments. EPA is
required to respond to the comments. The court will review both the public comments and
EPA's response to those .comments before deciding whether the settlement is in the public
interest. EP A may take additional steps to keep the community informed about these events
due to the high level of public interest exhibited during the RIfFS process. Such steps could
include the mailing of a notice of any settlement and related public comment period to the
site mailing list.
COMMENT 12: A State Senator, a State Represelllati\'e, tlte Milford Selectmen, tlte Littleton
Selectmen, and man)' citizellS commellled tltat EP A sltould take a balanced approach to
assig7ting liability for tlte cleanup so tit at the liabilit)' of tlte various PRPs at the site would be .
proponional to tlte extent of tlte polllllion caused by eaclt PRP. TIle Milford Selectmen and
many citizens commented tltat holding Hitcltiner and Hendrix responsible for the entire cleanup
would be unfair and not in tlte spirit of currelll legislation. One citizen asked whether EPA
would consider it fair if Hitcltiner and Hendrix were reql/ired to pay for tlte cleanup when OK
Tool is clearly the calise of most of the pol/lltioll. MallY citizens commented that OK Tool
sltould be forced to pay most or all of Ihe cleanup costs. Se\'eral citizells added that the
u/lfaimess would be exacerbated by the fact that there is no gl/aralltee that the preferred
altemati\'e will achie\'e tlte cleanup goals.
RESPONSE: EPA acknowledges the community's concern over the fairness of the final
apportionment of the cleanup costs. Current legislation (CERCLA) provides that EPA may
seek recovery of all of the costs of the site investigation and cleanup from any of the PRPs if
the harm to the environment cannot be dhided among the PRPs in any meaningful way. .
Federal courts have held that the PRPs, not EPA, must prove that responsibility for the
contamination can be di\ided among the PRPs. At this time, EP A has not made any
determination regarding the allocation of responsibility at this site, and EP A may not make
any such determination in the future. It should be noted that under CERCLA one PRP may
sue another PRP, or other parties not named as PRPs, to recover costs for the site.
investigation and cleanup. .
Based on site studies and experience at similar sites, EPA believes that the remedy
will be effective. EPA acknowledges that complete success can never be guaranteed.
COMMENT 13: TIle Milford Selectmen, tlte Littleton Selectmell, a fonner Milford Selectman,
and many citizens stated that SI/perfund money should be used to pay the difference between
what HitcJliner and Hendrix Ita\'e offered to pay and the total cost of the remedy if financial
COlltriblllions from otlter PRPs are not a\'ailable. Se\'eral citizens stated tltat only Superfund
monies should be used for tlte cleanup.
RESPONSE: CERCLA and EPA policy require that EPA seek either performance of or
funding for the site investigations and cleanup from the PRPs before committing any
Superfund monies to the site. However, CERCLA also provides for mixed funding, which is
Savage Municipal Water Supply Superfund Site
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the use of Superfund monies to fund a portion of the cleanup. Mixed funding may be
considered where some PRPs are unknown or insolvent, or where some PRPs refuse to settle
through the negotiation process. In considering the appropriateness of mixed funding at a .
site, EPA considers several factors including the strength of EPA's liability case against the
PRPs, demonstrated cooperation and good faith on the part of the settlors during
negotiations, and the amount of the portion for which the Superfund will be responsible.
Because the negotiating process has not yet started, it is premature for EPA to make any
statements at this time regarding the potential use of Superfund monies to fund the cleanup
at this site. More information on EP A's guidelines for mixed funding are available in the
EPA memorandum "Evaluating Mixed Funding Settlements Under CERCLA" dated October
20, 1987.
COMMENT 14: Se\'eral citizens asked why EP A will not publicly discuss who is going to pay
lor the cleanup given that EPA is goi1lg to decide u1li/aterally the nature 01 the remedial action to
be perfonned. 17Je Milford Selectme1l stated that they could not perfonn a comprehensive review
01 EPA's cleanup proposal because inlonnation regarding the jinancialliabi/ity allocation
process lor the clea1lup and the decisio1l-making rules, authority, and eligibility lor the use 01 the
Superftmd were witlJlleld from the Selectme1l a1ld the public by EPA.
RESPONSE: As discussed previously, funding of the cleanup will be determined through
upcoming negotiations between the PRPs and EPA. Those negotiations will be conducted
pursuant to CERCLA ~ 122. As required by CERCLA, EPA's goal is to have the cleanup
fully funded by those parties responsible for the contamination at the site. Liability for
contamination at Superfund sites is determined pursuant to CERCLA ~ 107.
EPA's decision-making rules. EPA's statutory authority, and the rules governing
eligibility for use of the Superfund are embodied in CERCLA, the NCP, and other EPA
guidance which are all public documents.
COMMENT 15: 17le Milford Selectmen requested that the town be a party to the negotiations
011 the apponioll17lem 01 the clea1lup costs.
RESp'ONSE: Those negotiations will be held between EP A and the PRPs in private. One of
the reasons for the negotiations being held in private is that the PRPs may wish to maintain
confidentiality regarding some of the information revealed in the negotiations. The town
would only become a party to the negotiations if the town were named as a PRP; that is, if
EPA determined that the town was potentially liable for site cleanup costs pursuant to
CERCLA. At this time, EPA does not intend to name the town as a PRP.
COMMENT 16: A citizen asked what measures EPA had taken to e1lsure that OK Tool assets
will be a\'ailable to help pay for OK Tool's share of the cleanup costs. The resident also asked
whether NESFAB assets could be used to cover a ponio;1 01 the costs. (Other residents asked.
why EPA allowed the original owners 01 OK Tool to sell the company when EPA knew a
clea1lup would be necessary.) She also alleged that EPA is u1lwillillg to pursue the previous
oWllers 01 OK Tool, alld would ill stead rather pursue Hitchiller lor the cost 01 the cleanup and
thereby lorce the plant to shut dow1l a1ld lay off all 01 the workers. She stated that allowing the
lomler oWllers 01 OK Tool to keep their assets while 10rci1lg Hitchiner to shut down is not la;r
and that the assets 01 the lonner o",,"ers 01 OK Tool should be sold to fund the cleanup.
RESPONSE: The sale of OK Tool does not render its owners and former owners and
operators immune from liability under CERCLA. As part of the enforcement process, EPA
is currently investigating the fate of OK Tool's assets. Because this process is ongoing, EPA
cannot comment on it at this time. EPA's policy, however, is to seek funding for site
cleanups from all PRPs if possible. If a PRP declares bankruptcy, EPA may become one of
10
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the creditors and may still recover costs. Thus. NESFAB asseLS may eventuaIly be used to
pay for a portion of the cleanup.
COMMENT 17: . A State Represelllati\'e, the publisher of the Milford Cabinet, and many citizens
recommended that EPA accept the Hite/liner and Hendrix funding and treatment proposal
because it is ge1lerous, effective, alld reasonable. TIle RepreseTUati\'e noted that by law, if EPA
Call1lot force OK Tool to pay for their share of the cOlllamillatioll, Superfulld money must be
used to complete the cleanup. He also stated that the amount the two companies had offered to
pay was in excess of their share of the responsibility for the pollution. A citizen suggested that
the HitchinerjHendrix proposal would be the best altemative for treatment until EPA was certain
that a more atellsive program of treatment would be necessary and effective.
RESPONSE: The Hitchiner /Hendrix proposal was premature because the formal negotiation
period for the site has not yet started. CERCLA and the NCP provide for a special notice
from EPA to the PRPs inviting them to submit a proposal either to fund the site cleanup or
to undertake the job themselves. This notice is usually sent after the cleanup method has
been determined because until that time, there is no fU'm plan about which to negotiate.
Following receipt of the special notice, the PRPs have 60 days in which to present to EPA a
proposal for the site cleanup. If EPA determines that the submitted proposal is a good faith
offer, EPA will extend the negotiation period for an additional 60 days. If the PRPs are
umlble or unwilling to perform or to finance the cleanup, EPA may use Superfund monies to
fund all or part of the cleanup. EPA may then seek in court to recover the Agency's costs.
Please see the response to Comment 13 for a discussion of the use of Superfund monies to
finance cleanups. . .
Since EPA has not made any determination regarding the level of each PRP's
responsibility for the site contamination, EPA cannot comment on whether or not the
Hil.chiner /Hendrix proposal is in proportion to their responsibility for the site contamination.
EPA believes that studies from other sites and existing data from the RI/FS for this
site show that implementation of alternative MM-llA would be effective in protecting clean
areas of the aquifer from contamination and in achieving a cleanup of the contaminated
aquifer within a reasonable period of time.
COMMENT 18: A citizen asked for all CJ.plallatioll of the ratiollale EPA would use to justify
forcillg Hitchiller alld Helldrix to rcmediate the PCE plume gi\'en that neither of the companies
used PCE in their productioll processes.
RESPONSE: EP A understands that the public is very concerned over the outcome of the
upcoming negotiations between EPA and the PRPs. However, because the negotiations for
funding the cleanup have not yet begun, EP A cannot provide any information on the outcome
of those negotiations, including the rationale for any agreements that may be reached. Any
discussion of such topics would be premature at this time.
COMMENT 19: Two resideTUs commented that EPA regulatiolls seem to exempt companies
that have gone out of business from respollsibility for remediatillg the pollution they caused. The
Milford Cabillet stated that EP A's failure to explaill the cost allocatioll process left the
impression in the community that EPA will apportion the cleanup costs based on ability to pay
rather than on the cOlltribution made to the pollutioll. TIle Milford Selectmen stated that an
assessmclll based 011 ability to pay is IIOt acceptable to tile commullity. Many citizens
commellted tllat HilClliller alld Helldrix should IIOt be held respollsible for the cleanup cost only
because tlley are tile sole compallies remaillillg ill busilless. Olle residellt stated that HilChiner
ships Ol'er $50 millioll ill products each year alld call tllerefore afford to pay for their past
em'irOllmelllal mistakes alld carelesslless.
Savage Municipal Water Supply Superfund Site
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RESPONSE: CERCLA ~ 107 confers liability on four classes of persons. Ability to pay and
fmancial solvency are not considered in determining Superfund liability.
The apportionment of the costs among the PRPs will be reached through a negotiation
process which has not yet begun. EPA expects to enter into negotiations over the cost of the
cleanup with all of the PRPs. Ability to pay and financial viability are factors that will be
considered during those negOliations.
COMMENT 20: A citizen comme1lted that an unfair decision on cost allocations by EPA
would result in a lengthy legal battle that only would delay the cleanup of the site and be
counterproducti\'e to EP A's objecti\'es at the site.
,~
RESPONSE: CERCLA provides for a negotiations and settlements between PRPs and EPA
in an attempt to avoid lengthy and costly legal battles: If EPA and the PRPs cannot reach an
agreement, EPA may either (1) order the PRPs to perform the cleanup and collect fmes of
up to $25,000 per day if they refuse, or (2) if the PRPs refuse the order, perform the cleanup
using Superfund monies and sue the PRPs, to recover the cost plus triple that amount in fmes.
Thus, the PRPs have incentives to settle early in the process.
COMMENT 21: A citizen comme1lted that CERCLA may need to be changed if it causes
innoce1lt parties to be jinancial(\' liable for em'irOllmelltal c01ltamination.
RESPONSE: CERCLA does not cause innocent parties to be financially liable for
environmental contamination. Rather, CERCLA specifically confers liability on four classes
of people:
a) current owners and operators of a facility;
b) people who at the time of the disposal of hazardous substances owned or
operated the facility at which such hazardous substances were disposed of;
c) generators of hazardous substances;
d) transporters of hazardous substances who select the disposal or treatment facility.
CERCLA also protects innocent landowners from liability for environmental contamination.
Pursuant to ~ 101(35)(A), an innocent landowner is a person who acquired by inheritance or
bequest the property after the disposal of hazardous substances, or a person who acquired the
property after the disposal of hazardous substances and who did not know or had no reason
to know that hazardous substances were disposed of on the property.
COMMENT 22: A reside1lt asked whether Superfulld would pay the cost of the cleanup or
whether local taxes would be used to co\~er portions of the cost. Another resident stated that
placillg the jinancial burden of the cleanup 011 local taxpayers would not be fair.
RESPONSE: EP A, will seek to recover cleanup costs from the PRPs in accordance with
CERCLA. As EPA has not named the town as a PRP, there is no reason to expect local
taxes to be used to fund the cleanup.
COMMENT 23: A resident noted that EPA has told the town it has a groundwater problem
and exactly how EPA will sob'e that problem without consulting the town about either the
problem or the solution. He stated that, if EPA uses Superfund monies to achieve EPA's goals,
the townspeople will be ful(v supportive.
RESPONSE: During the recent public comment period, EPA solicited comments from the
town on EPA's field investigation results, risk assessment, and proposed remedy for the site.
EPA has made available all of the site reports for review by the town at the local library, and
EPA has also been available for discussions with the town regarding the site.
'"
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As stated previously, one of Congress's aims in creating CERClA was to promote a
polluter-pay policy. Funding the cleanup entirely through Superfund monies without
attempting to obtain contributions from the PRPs would be contrary to the mandate of
CERClA.
Preferred Alternative
COMMENT 24: A State Senator and several citizens commented tllat a phased approach to the
cleanup would be more economical for reasons including: 1) the lack of an immediate threat to
human healtll or need for the water supply, 2)tlle fact that the proposed recovery technolOlD' is
unproven, and 3 )the likelihood that less expensive treatnient methods will be developed in the
foreseeable future. A resident also stated that a faster remedy would not be superior if free phase
DNAPLs exist. The State Senator and the publisher of the Milford Cabinet suggested that
institutional controls sllould be implemellted and the site allowed to naturally attenuate for a
period of time. 77ley proposed that at some later date the site could be re-evaluated and, if
progress is not satisfactory, a more aggressive cleanup program could be started.. Another citizen
also asked why EPA has not proposed a phased implementation program for the remedy and
wllether a phased approacll will be considered by EPA in tile future. One citizen proposed
limiting the remedial action to colltainment of the concelltrated plume until the pump and treat
system has been pro\'en effecti\'e or until a more effecti\'e and less expensi\'e method of solving
the problem has been found.
RESPONSE: EPA believes that a phased cleanup would be inappropriate at this site because
the recovery technology proposed by EPA is proven. Based on results at other sites, EPA
believes that the proposed treatment technologies will accomplish the cleanup objectives at
this site.
If free phase DNAPLs do exist, EPA does not contemplate that the remedy will
substantially change, except perhaps for the duration of the treatment of the concentrated
plunle. EPA is confident that containment of the concentrated plume is possible, and
therefore that cleanup of the extended plume is feasible even if free phase DNAPLs exist in
the concentrated plume.
EP A agrees that there is no data showing an immediate threat to human health if the
groundwater is not consumed, or any urgent need for the aquifer as source of drinking water.
EPA has incorporated these facts into the design of the remedy by not choosing .the most
aggressive cleanup alternatives.
EPA cannot fail to take action at a Superfund site today on the premise that some
new technology may become available in the future. A phased approach would only delay the
restoration of the aquifer.
Please also see Comment 106.
COMMENT 25: A State Senator commented t/,at he felt the preferred altemative may either fail
to achieve EPA's cleanup goals or prove to be more elaborate and expensive than is necessary.
RESPONSE: EP A recognizes the public's concern over the uncertainties involved in the
cleanup. Nevertheless, EPA believes that MM-IlA will achieve the cleanup goals at the least
possible cost, as discussed in Section IX of the ROD.
COMMENT 26: Se\'eral citizens requested that EPA work with Hitclliner, Hendrix, and the
community in fomlulating a final cleanup alld fulldillg plall for the site that will address threats
to both the natural e1l\'ironmellt alld the commll1liry.
Savage Municipal Water Supply Superfund Site
-------
RESPONSE: EPA has selected a remedy in accordance with the procedures and criteria set
forth in CERCLA and the NCP. EPA now intends to work with the PRPs to fund the
cleanup through the upcoming formal negotiation process.
COMMENT 27: Two citizens requested the engineering justification for the two wells at the end
of the plume across the river gi~'en that these wells will be pumping water with only very dilute
concentrations of PCE. One commentor noted that less than one cubic inch of contaminant
would be recovered by these wells per day of pumping and that the total volume of contaminants
recovered from these two wells would be less than one half of one percent of the total volume of
contaminants that would be recovered from all of the wells in the preferred altemative. He also
noted that, if all of the contaminants in the northem portions of the aquifer discharge into the
Souhegan River, they would quickly be diluted to concentrations below paTtS per trillion. He
commented that the Hitchiner/Hendrix cleanup proposal would recover 97 percent of the
contaminants that would be recovered by the prefe"ed altemative. He added that to spend
limited resources on such a small amount of additional recovery would be a crime. He stated
that he did not wish PRP, local, state, or federal fu1J(is to be squandered in this manner.
RESPONSE: EPA has found contamination across the river near the location of the two
wells in question at about 600 ppb, or more than 100 times the Safe Drinking Water Act
Maximum Contaminant Level (MCL) for PCE. This represents a high level of contamination.
Thus, EPA believes the selection of a remedy including wells on the north side of the river is
a prudent choice.
Although it may constitute a small percentage of the total contaminants recovered by
the remedy, the one cubic inch per day of pure PCE referenced in the comment above is
sufficient to contaminate approximately 865,000 gallons of water to 5 ppb, the MCL for PCE.
. The protection achieved is therefore significant. In devising Alternative MM-I1A, EPA
carefully located the extraction wells according to the size and location of the contamination
problem. The two wells on the north side of the river were included to ensure treatment of
only the most seriously contaminated portions of the aquifer in that area.
COMMENT 28: A citizen asked for a justification of the additional expense that would be
required to constmct and operate EP A's prefe"ed altemati~'e instead of MM-5 as proposed by
Hitchiner and flendrix.
RESPONSE: At a conceptual level. MM-5 is essentially the same as MM-7, which was
considered in the detailed analysis of alternatives. Both treat the concentrated plume and the
middle section of the extended plume. The principle difference between MM-7/7A and MM-
l1A is that MM.I1A includes wells on the north side of the river. The justification for these
wells is provided in the response to Comment 28 above.
COMMENT 29: A citizen asked what treatment technologies ha~'e been successful at similar.
Superfund sites around tlte COUlltl')' alld wltetlter tlte treatmelll tecllllology proposed by EPA is
considered Cll"ent. In particular she asked whether bio-remediation and ill-situ treatments have
been successful. She also asked whether EPA would work with the PRPs to ensure that the
technology used in the site cleanup is cu"ent alld reasonable.
RESPONSE: The proposed technologies are being successfully applied at a number of sites
in North America and are considered to be current. Within EPA Region I, air stripping is
currently being used at Superfund sites in Groveland and Acton, Massachusetts. Ultraviolet
oxidation has been successfully pilot tested at a Woburn, Massachusetts Superfund site and is
expected to be in operation by the end of the year.
14
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Based on current information, bie-remediation technologies and other in-situ
methods are not sufficiently advanced or proven to warrant their recommendation as
treatment alternatives at this site.
Since the PRPs prepared the FS, EPA has been working with them to ensure that the
treatment technologies to be used are current and cost effective. EPA hopes to maintain a
productive working relationship with the PRPs throughout the implementation of the remedy
COMMENT 30: The Milford Selectmen commented that restoring the aquifer to drinking water
stalldards may not be necessary because the aquifer is not cun-ent/y used as a drinking water
supply, other water supplies are available for use by the town in the future, and state regulations
may not allow the use of the aquifer due to the nearby industrial, commercial, and agricultural
land uses. A citizen also commented that the aquifer would never be used again as a drinking
water source due to adjacent land uses.
RESPONSE: EPA concurs that the aquifer is not currently a drinking water source, but
disa!~ees that this fact constitutes a reason for allowing it to remain contaminated. The
contamination, if left untreated, may spread to portions of the aquifer that are currently used
for drinking, including portions of the bedrock aquifer. The aquifer could also be used as a
drinking water supply in the future. EPA's national groundwater policy requires the cleanup
of such aquifers, if practicable, within a time frame that is reasonable. This policy only
considers the availability of alternative water sources a factor in determining the time frame
for the cleanup, not whether a cleanup should be conducted. EPA policy states that
reasonable time periods may range from very rapid (one to five years) to relatively extended
(perhaps several decades). The selection of Alternative MM-I1A, with a restoration time of
three to six decades, is consistent with the nation's goals for groundwater restoration and
protection.
The state has not ruled out the future use of the aquifer as a drinking water supply.
The state's groundwater policy is that all of New Hampshire's groundwater should be
considered a potential drinking water source. According to a letter from the state to the
Milford Selectmen (7/11/91), "The recently enacted Groundwater Protection Act, RSA 485-C,
clearly established that the best use of all state groundwater is drinking water supply, and that
all potential contamination source activities shall be conducted so as to eliminate or minimize
the threat of groundwater contamination, regardless of where those activities are located. . .
Although the aquifer in the vicinity of the Savage Well may remain unsuitable for drinking
without treatment for a long period of time, the ultimate goal must remain restoration to
drinking water quality: EPA has considered the state's classification of the aquifer in the
selection of a remedy for the site, and EPA's remedy is consistent with the state's
groundwater policy.
COMMENT 31: TIle Milford Selectmen commented that EPA has not given sufficient
consideration to their projections of water use and supply in detemlining whether the town may
ever need to use the aquifer for drinking water in the future. TIle Selectmen stated that Milford's
water supply is adequate well into the next centu,y (2037+), and they provided worst case
scenario projectiol1S to documelll this asserrion. TIle Selectmen also stated that substantial
additional amounts of water could be drawn from the Curris well field, from the Penechuck
Water Works, and from the neighboring Town of Amherst. TIle Selectmen concluded that the
cleanup need not take place at all accelerated rate in order to supply tlte town witlt drinking
water, and tltat EPA should considcr tit is fact in selecting a final remedy for the site. Many
citizens agreed, stating that a longer cleanup period than EPA proposed would be more
appropriate. .
Savage Municipal Water Supply Superfund Site
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RESPONSE: MM-llA will achieve drinking water standards in the aquifer within
approximately 15-60 years, that is, by approximately 2051. Thus, EPA's cleanup time frame
matches well with conservative local projections of potential water demand for the community.
COMMENT 32' A resident commellted that the Proposed Plan appeared to cOlltradict itself on
the issue of whether or not free phase DNAPLs exist.
RESPONSE: There is circumstantial evidence for the existence of free phase DNAPLs.
However, no free phase DNAPLs actually have been discovered in the field at this site.
COMMENT 33: A citizen asked whether EP A's preferred alternative would cost betWeen $30
million and $45 mil/ion or more o\'er the next 20 to 30 years.
RESPONSE: EPA's estimate of the net present value of MM-llA for 30 years is $15.5
million based on a $2.4 million capital cost and a $1.4 million annual operation and
maintenance cost. This cost estimate is designed to be within a range of
-30 percent to + 50 percent. Thus the maximum expected net present value would be $233
million.
COMMENT 34: A citizell asked whether hea"y metals would be remo\'ed from the treated water
to levels that meet drillkillg water stalldards, alld, if /lOt, what is the purpose of removillg the
volatile cO/lta17lillallts if the water remaills ulldrillkable due to high cOllcentratiolls of metals.
..
RESPONSE: Metals, as well as organic contaminants, will be removed from the groundwater
by treatment to drinking water standards if the treated water is recharged into the ground or
the Hitchiner /Hendrix discharge stream, or to standards for the protection of aquatic life if
the water is discharged to the Souhegan River.
COMMENT 35: A citizen asked whether EPA or the state will evelltually appro\'e the Sa\'age
. Well as a drinkillg water source if the treatmelll of the extellded plume proves effective, but the
cOlltamillatioll ill the cOllcelllrated plume cali/lOt be elllirel)' remo\'ed. 77le Afilford Cabinet
asked w~lether the state would pennil use o[ the aquifer as a mUllicipal water supp~v if the
aquifer is clealled.
RESPONSE: EPA does not have the authority to approve a municipal drinking water source.
This authority rests with the state. Once the extended plume is clean, EPA would allow the
removal of institutional controls restricting use of the groundwater whether or not the
concentrated plume has been fully restored to drinking water standards, provided that such
use of the groundwater would not interfere with any continued treatment of the concentrated
plume. EPA cannot predict whether the state would approve of the use of the Savage Well as
a drinking water source in the future. However, the state does currently consider the aquifer
at the site to be a potential future source of drinking water.
COMMENT 36: A citizen commellled that the failure of the preferred alternative to address
bedrock groundwater conta17lillation at the site is a major flaw in EPA's cleanup plan. He
stated that some kind of actioll should be added to the preferred alternative to treat the
cOlllaminated bedrock groulldwater alld thereby protect cleall bedrock groundwater.
RESPONSE: EPA disagrees; the remedy does adequately address bedrock groundwater
contamination. The operation of the extraction and treatment system contained in MM-llA
will greatly decrease the amount of contamination entering the bedrock aquifer. This will
allow the bedrock cOntamination to attenuate naturally while the overburden cleanup is in
operation. EPA will monitor bedrock contamination at the site to ensure that the natural
16
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attenuation is progressing as expected. EP A will also monitor bedrock groundwater in areas
not affected by the contamination to ensure that the bedrock contamination is not spreading.
COMMENT 37: A citizen commellted thQt Q repon from the U.S. DeptJ1fment of Energy's Oak
Ridge NatiOllal LaborQtory concluded thQt pump and treat is an ineffective metlaod for restoring
aquifers to "heQlth based le~'els" Qlld may, in some CQses, do more environmentQI harm than
gooli. He stated llaat Qctioll on the extended plume should be put on hold because the,t1eatment
technology has not been proven to work and another branch of the federal government has stated
tlaQt it will not work.
RESPONSE: The conclusions of the Oak Ridge report (ORNLfTM-U866) are debatable.
The study was not an evaluation of pump and treat technology, but rather a generalized status
report of groundwater remediation at a variety of sites. The report does not include site
specific in-depth analyses of factors that can inhibit remedial progress such as hydrogoelogical
complexity, the nature of contaminants, and the adequacy of remedial design. Therefore, it is
not applicable to the cleanup EPA plans for this site. EPA is aware of and participating in
resf:arch on pump and treat technologies. Information to date indicates that pump and treat
is very effective in containing or capluring contaminant plumes and is effective in remediating
dissolved-phase contamination.
COMMENT 38: A citizell stQted tllat tile Hitclliller/Hendrix proposal would Qccomplish all of
EP A's imponallt clcanup objectil'es illcluding tile protectioll of public heQltla and tlae
cOlltQillmelll of tlae COllcelllrated plume wllile laa~'illg mucla less of QII impQct 011 wetlQnds than
tile preferred altc11Iatil'e.
RESPONSE: The Hitchiner/Hendrix proposal, outlined in a letter dated 51'213/91, primarily
addresses funding for the treatment of the relatively small l,l,l-trichloroethane (TCA) plume
and would fund only operation of groundwater treatment at the Savage Well for 20 years. As
PCE is the most dangerous and widespread contaminant, and PCE cleanup is likely to take
longer than 20 years, the Hilchiner /Hendrix proposal would fail to meet EP A cleanup
objectives for almost the entire site.
COMMENT 39: TIle oWller of propen)' IICQr tile site stated tlaat lae is opposed to any pumping
OIl his lalld 011 Nonla Ri~'er Road because lie beliel'es tlaQt pumpillg llae groulldwater from his
lall.1 would spread tile contamillatioll ratller tllall COlllaill il.
RESPONSE: At this time, EPA's remedy does not include pumping from the land mentioned
by this commentor, which is located north across the river from the drive-in theater. In
general, pumping of the extraction wells will spread the contamination to a limited extent.
However, pumping the water from downgradient well locations is the only technologically
feasible method of achieving a site cleanup through treatment. Pumping sufficient amounts of
contaminated water against the natural direction of groundwater now would ,be hydrologically
impossible.
COMMENT 40: A residelll expressed suppon for tlae preferred altemQtive alld a lotal cleanup of
tlae site for tlae bellefit of future generatiolls.
RESPONSE: EP A acknowledges the comment.
COMMENT 41: A residelll expressed doubt IhQt tlae preferred alte11lati~'e would be able to clean
tlae Qquifer givell tlaQt tlae problem Qbol'e tlae fisla pOlld Qlld laatcllcl)' wil/lIOt be Qddressed and
could spread to funhcr cOlllamillate tlae area EPA is attemptillg to remediate.
Savage Municipal Water Supply Superfund Site
-------
.
RESPONSE: The RemediaJ Design phase of the cleanup will specify the location of
extraction wells to ensure that all significant contamination in the area of the fISh hatchery
will be captured and treated. The remaining contamination would attenuate naturally within a
reasonable period of time.
COMMENT 42: 77le Milford Selectmen stated that human exposure to unsafe groundwater is
not a sigllificant possibility. They argue tluzt al/ of the area in the contaminant plume south of
the Souhegan River is served by town water alld is zolled to prohibit residential uses and restrict
any development in the wetlands or f/oodplaill. They state that residential lands nOl1h of the
river, according to the RI and FS, are protected from contamination by natural geologic and
hydraulic boundaries in the aquifer. They also note that the impact of the plume on the ri~'er
will be negligible due to the volume of water in the river. They conclude that it is unlikely that
the plume will tra\'el beyond the river at harmful levels. The Selectmen stated that the omission
of an analysis of the Souhegall River after the SG-5 samplillg point and Hal'tShom Mill Brook
limits EP A ~ ability to determine the nature of the aquifer/river interaction. They conclude that
ful1her research may be necessary to determine whether a potential threat to human health exists
on the nOl1h side of the river, but that existillg information indicates that no human health threat
exists. 77le Selectmen state that EP A should reassess the method and timetable for site cleanup
in light of these conclusions.
RESPONSE: Zoning is nOI a reliable control on land use for the 100+ year time frames
needed by the less rapid cleanup alternatives. Zoning may be changed by future governments
for reasons not anticipated at this time.
Domestic wells located north of the river have not shown any contamination to date,
but their use constitutes a potential risk. Those wells \\;11 be monitored since there is no
guarantee that the existing water quality will persist, especially if more residential
development Occurs. It should be noted that, in some areas, the plume has already traveled
beyond the Souhegan River at concentrations above MCLs (see figure in Attachment D).
Although current river water quality appears not to be adversely impacted by
contaminated groundwater, there is insufficient data to conclude that the leading edge of the
plume is stationary. The extent of the contaminated groundwater discharge zone to the river
and resulting impact on surface waler quality will require further evaluation during remediaJ
design.
COMMENT 43: 77le aUOnte)' for the fanner of the COnt field on the site stated that the farmer
plalls to comi1lue culti\'ati01l of that lalld. 77le attontey commented that this use of the land
bellefits the community a1ld the state. 7Jle attontey stated that the fanner objects to any
ill/fUsiOlls illto the agricultura/~\' sigllifica1lt pOl1iollS of the property for the purposes of
construction of the preferred altemati\'e. 77le attomey stated that any such intfUsion should be
accompanied by a simple and fair plall to compensate the fanner for his financial loss and that
allY il/tTUsion should be undel1akell in a way so as to minimize that loss. The Qnomey noted
thai the famler is not in a position to pursue the PRPs fo~ any loss he may suffer.
RESPONSE: EP A recognizes the value of the farmland to both the farmer and the
community. The remedy requires that necessary construction minimize the impact on the
farmland and wetlands in the area. The Remedial Design phase of the cleanup will
investigate the potential impact of any construction on the farmland and wetlands. Mitigation
measures will be taken to prOtect the agricultural productivity of the farmland. Such
measures should be effective.
COMMENT 44: 77le attomey for the fan/ler of the com field Oil the site stated that the
proposed pumpillg is like~\' to disrupt or destroy the agricultural use of the property because it will
lower the water table sig1lificant~\' a1ld dry Ollt the la1ld. 77le attontey noted that com can be
18
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grown 011 the property without inigatioll due to the elevation of the water table. The attorney
requested that: 1 )further study of the impact of the pumping on the agricultural operations be
canied out prior to EPA's commitment to any particular cleanup plan; 2)any alternative selected
be cOllSistellt with the agricultural use of the property; alld 3)a1lY cleallup plan put forth by EPA
that could restrict or eliminate use of the fannland contain clear provisiolls for compensation to
the famler. TIle attorney emphasized that the famler wishes to continue using the land for
famli1lg alld is not interested in exchallgillg his rights to the land for compensation at this time.
RESPONSE: EPA recognizes the value of the farmland to both the farmer and the
community. The Remedial Design phase of the cleanup will investigate the potential impact
of the pumping on the water table under the farmland and specify mitigation measures to
help protect the agricultural productivity of the farmland. Therefore those concerns are being
addressed and no delay in the selection of a remedy is y.'arranted.
COMMENT 45: TIle Litt/etoll Selectmen stated that the technolo~ used in the cleanup should
be CO.ft effecti~'e.
RESPONSE: Congress, through CERCLA, requires EPA to select remedial technologies that
are cost effective. EPA compares the costs of each of the alternatives to their overall
effectiveness to determine which alternatives represent reasonable value for the money.
Through this balancing of cost with long-term effectiveness, implement ability, short-term
effectiveness, and the reduction of toxicity, mobility, and volume of the contaminants through
treatment, EPA ensures that the final remedy is cost effective. EPA concludes that
Alternative MM-llA is cost effective when compared with the other alternatives because it
will effectively capture and treat the most highly contaminated portions of the plume and
restore the aquifer within a reasonable period of time, but costs less than other alternatives
that are able to accomplish the same objectives. Section IX of the ROD discusses further
how the chosen remedy provides overall effectiveness proportional to its costs.
COMMENT 4fJ: A citizell asked EP A to address the potelltial impact of the preferred alternative
011 the state oWlled com fields alld fish hatchery.
RESPONSE: The potential impact of the remedy on corn fields is addressed in the responses
to comments 43 and 44 above. EPA does not anticipate that the remedy will have any impact
on the hatchery.
Other Issues
COMMENT 47: A State Sellator commellted that the New Hampshire COllgressional delegation
should become i1l\'01~'ed in the site due to the extreme importallce of the site and the viability of
the local PRPs to the commullity.
RESPONSE: EPA acknowledges the importance of the site and, as at any site, welcomes the
involvement of the state's elected representatives.
COMMENT 48: A resident asked why EP A had not considered placing a treatment plant at the
Sa~'age Well to produce cleall water for use by the tOWII instead of wasting the water by
dischargillg it to the ril'er or rechargillg it to the groulldwater. Allother citizen asked EP A to
address the potelltial use of treated water by the tOWII for cOllsumptioll.
Savage Municipal Water Supply Superfund Site
-------
RESPONSE: Under CERClA, EPA has no authority to authorize municipal use of tbe
treated water or to require the PRPs to provide the equipment necessary to connect any of
the treatment plants to the town's water system. However, this does not preclude tbe
possibility that such an arrangement could be made betWeen the PRPs and tbe town if tbe
PRPs are operating the treatment plants. The town may wisb to pursue this option witb tbe
PRPs.
COMMENT 49: A citizen asked whether EPA would modify the proposed remedy to obtain
community and state acceptance of the cleanup plall. He noted that this issue was not
addressed at the July 11 public meetillg.
.-
RESPONSE: Community and state acceptance are tWo of the nine criteria used by EPA in
selecting remedial actions. Under CERClA, EPA may modify its proposed remedy in
response to state and community comments, and EP A bas done so in tbe past at otber sites.
CERClA is very clear, bowever, that the final decision making autbority rests witb EPA.
Moreover, EPA may not ignore the other criteria in order to acbieve state or community
acceptance. Congress provided that authority in CERClA to ensure the protection of public
health and the environment as discussed in the introductory paragraphs to this section on
page 6.
COMMENT 50: A citizell commellted that EP A's OIlZV goal appears to be the cleanup of the
ell tire aquifer to drillkillg water stalldards.
RESPONSE: EPA's goals at the site are 10 protect human health and the environment and
to restore the aquifer to drinking water standards.
COMMENT 51: A residellt requested that EPA release pote1ltial purchasers of his property,
which is located 011 the site, from allY cleallllp liability so that he call seJ/ his land.
RESPONSE: EP A cannot issue waivers of liability to owners of land or to potential owners
of land located on a Superfund site. Under certain circumstances EPA may consider
negotiating a settlement with a prospective purchaser of contaminated property.
COMMENT 52: A residellt eJ.pressed cOllfliSioll ol'er how NESFAB could be named as a PRP
el'ell thollgh the NESFAB bllildillg is IIOt ill the cOlltamilla1lt plume. He noted that EPA's
nz eth ods of deten7linillg who is a PRP do 110t appear to be fair, but that these methods should
be fair.
RESPONSE: Pursuant to CERCLA ~ 107, PRPs are any individuals or companies, including
past or present owners or operators of hazardous waste facilities, transporters of hazardous
substances, or generators of hazardous substances who may be responsible for contamination
at a Superfund site. On June 18, 1985, EPA notified four parties (Hitchiner Manufacturing
Company, Hendrix Wire and Cable, OK Tool, and New England Steel Fabricators) tbat tbey
were PRPs under CERClA. Based on a review of each company's past hazardous waste
management practices and manufacturing processes, EPA determined that it had reason to
believe that each named party had contributed to the contamination of the Savage Well and
that each named party may be liable for response action costs at the site pursuant to ~ 107a
of CERClA. In particular, NESFAB generated hazardous wastes in association with painting
processes related to its manufacture of custom steel components and structures. NESFAB
voluntarily entered into agreement with EP A to perform the RI and FS with the other tbree
named PRPs.
20
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COMMENT 53: A citizen asked wlty EP A has let seven years pass without any containment or
treatment of tlte PCE hot spot at OK Tool wlten as early as 1984 it was clear that such
treatment, at a minimum, would be necessaT)'. Anotlter citizen asked why so much time was
required to fonnulate a solution to tlte site contamination. A,lotlter citizen noted that the plume
would Itave been smaller and easier to contai/l ill tlte past and blamed EPA for spending large
amounts of time alld money to deten7line wllat tile citizen felt Itas been known for years, that
OK Tool is sole~v responsible for tlte pollution. Olle citizen also stated tllat in the early 1980s
the contamination was l)\'ery localized around OK Too~ 2)had not yet entered the bedrock, and
3)would have been much easier and cheaper to remediate at tllat time.
RESPONSE: EPA acknowledges that the cleanup process for the site has been lengthy. This
has resulted in part from several factors: 1) the study and cleanup of environmental
contamination in general. and groundwater contamination in particular, often poses very
complex and difficult scientific problems; and 2) in order to select a cost effective remedy that
win reliably protect public health and the environment, EPA must thoroughly investigate the
problem and potential solutions, and such investigations can take a considerable amount of
time. EPA notes that the processes followed in the investigation of the site are those
required by CERCLA and the NCP.
There is no evidence that, in the early 1980s, the contamination had not entered the
bedrock or that the contamination was very localized around OK Tool.
COMMENT 54: A citizen asked wllether tlte PRPs would Ita\'e any rigltts of appeal after EPA
made its decision OIl tlte clcanup mctllod and tile apportionment of cleanup cost liability.
RESPONSE: Courts have generally agreed that judicial review of EPA decisions prior to the
filing by EP A of an action to recover its costs or an action to enforce an order is inconsistent
with CERCLA's goal of encouraging prompt action to clean up Superfund sites. However, if
a settlement is not reached between EPA and the PRPs and EPA brings a cost recovery
action against the PRPs, the PRPs will have all of the legal rights afforded to any defendant
in court. The PRPs may raise any appropriate defense at that time.
COMMENT 55: A citizen commcnted that EPA's meetings on the site were insincere because
most citizens do not have tlte knowledgc to evaluate tlte technical merits of EPA's proposals. He
stated thac whac the public could underscand and comment on would be the costfbenefit
relationships for differelll altenzacives. He cricicized EPA for not being more specific about the
cost.s of eaclt altenzative and for noC fuIZ\' disclosing EPA's plans for funding the cleanup. He
scated thac only wltcn tlte full costs of the cleanup altenzati\'es Co tile commUllicy's economic
IIealell are establislted could tlte public ask meaningful questions and make infon7led judgemellls
cOllcenzing tlte relati\'e merits of altenzati\'e strategies. He furtlter stated tltat EPA's refusal to
discuss cost and funding issues suggcsts tltat EPA is noC sincerely seeking public comment, but
merely complying witlt tlte letter of tlte law. Anotlter citizen agreed with tltese comments, noting
tltat tlte local community is \'ery anxious due to tlte lack of infomlation on who will be required
to pay for tlte cleanup and tlte presumpcion tltat EPA will require Hitchiner and Hendrix to pay.
the tlllire cost. He stated that EPA could impro\'e its credibility with the community if it would
discuss funding issues frallkly with the public. A Scate Representati\'e noced that EP A's rapport
with the public is Ilot good because EPA refuses to discuss tlte topic of funding, which is clUcial
to the people who are attending the public n.leecings. The Stace Represelllative also urged EPA to
more fully infomr the public on the costs and proposed funding for tIre cleanup. The publisher
of tile Milford Cabinct suggestcd tltac' a sCatemenC from EPA tltat clcanup coscs will be allocated
"rougltly in proportion to tile exlent to wllich the companies im'ol\'ed ha\'e contributed to the
cOlllaminatioll of the aquifer" would ease public apprehension over this matter, and that the lack
of SUell a statement leads tlte public to conclude tltat EPA's final cost allocation decision may
not be fair. Anotller citizen commellled that EPA appears an-ogallt and in-esponsible to the
Savage Municipal Water Supply Superfund Site
-------
-.
community when EPA fails to answer all questions put to it in a public forum, including
questions on funding.
RESPONSE: EPA recognizes that Superfund remedies are usually technic:ally complex, and
EPA has taken measures to make the information more accessible to the public. As part of
the Superfund process, EPA actively solicits public comment and review of EPA activities.
EPA has beld public meetings to ensure that the public bas an opportunity both to comment
on EP A activities and to ask questions of EP A. EP A also has published Cact sheets to help
keep the public informed and explain the results of tbe site studies. EPA's public involvement
eCCorts at the Savage site have gone beyond simple compliance witb the letter of the law.
EPA will continue these efforts as the site progresses into the Remedial Design and Remedial
action phases of the cleanup.
In recognition of the need Cor citizens to be well informed, EPA also provides
Technic:al Assistance Grants to community organizations to allow them to hire their own
consultants to evaluate EPA's studies. The availability of these grants was made known to the
public through tbe RI Cact sheet issued in July 1990 and at the August 1990 public meeting.
To date, no organization from the Milford community has applied to EPA Cor one of these
grants.
With respect to funding for the cleanup, CERClA provides that those costs are to be
shared by the responsible parties and establishes a negotiation process for the resolution of
cost allocation issues. EP A is hopeful that a seulement will result from the process. If not,
the allocation of costs may be decided by the courts. At this stage, however, EPA is unable
- to predict how those costs will allocated. It should be noted that the costs for each alternative
.. are detailed in the FS report, which has been available to the public in its final form since
July 12, 1991 at the Wadleigh Memorial Library.
Because "fair" is a relative term EPA cannot assure that future settlements or court
decisions will appear "Cairn to all people. However, EPA can assure the public that all of
EPA's actions will be consistent with the law.
COMMENT 56: A State Representatiw! asked, if EPA acn/ally does take into consideration the
opinions of the community, why EPA had not brought fourth allY new ideas, information, or
modifications to EPA's Proposed Plan based OIl public comments at the July 11 meeting.
Specifically he asked why MM.5 and well head treatment ha\'e not been included along with the
other altematives under consideration and why Hitchiner had not recei\'ed any con-espondence
from EPA on tlleir proposal of MAt-5.
RESPONSE: EPA takes community input into consideration in the remedy selection process.
Under CERClA, the ROD, which includes this responsiveness summary, is the document in
which community comments are incorporated, not the Proposed Plan. It should be noted that
the purpose of the public hearing held during the comment period is for EPA to receive
comments and questions rather than to present new proposals.
EPA considers MM-7 to be representative of MM-5 at the conceptual level, and
therefore the MM.5 concept was considered as a potential remedy for the site. All of the
alternatives considered by EPA were conceptual alternatives designed to achieve the cleanup
in different time periods by capturing different portions of the contaminant plume. The
precise number and location of the wells was not intended to be fIXed at this time. The
Remedial Design will establish the precise number, location, and pumping rate of the
extraction wells for the chosen treatment alternative. This is due to the fact that conditions at
tbe site will change between now and the start of the cleanup.
q
c.'
COMMENT 57: A citizen expressed concem that EPA had not given the HitchinerjHendrix
proposal full and formal consideration and noted theIact that EPA has ignored this proposal
gi\.es the appearance of in-espollsibilit)' alld an-ogallce 011 the part of EP A.
22
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RESPONSE: As discussed in previous comments, the Hitchiner /Hendrix treatment proposal
would address onJy part of the contamination problem and therefore would not be able to
accomplish the cleanup. As a remedy it would not be complete or protective of human health
and the environment and so cannot be considered as a viable alternative under CERCLA. As
a funding plan, the Hitchiner /Hendrix proposal was premature. Both Hitchiner and Hendrix
are aware that EP A does not consider funding proposals until the final decision on the
cleanup method has been made and the costs can be estimated. EPA wiU accept and respond
to funding proposals during the upcoming formal negotiation period provided for by
CERCLA.
COMMENT 58: A State Representati\'e criticized EPA for not presenting the total cost figures
for the various alternatives in a manner understandable to the general public in light of the fact
. that public confusion o\'er this issue was presented very clearly to EPA at the July 11 meeting.
He nmed that the Proposed Plan distributed at the July 29 hearing showed no evidence of EPA
effort to resolve this problem..
RESPONSE: EPA acknowledges this comment and has provided additional clarification on
the methods used for calculating costs in the response to Comment 3 above. With regard to
the Proposed Plan, see the response to Comment 56 above.
COMMENT 59: A citizen asked whether EP A represelltati\'es prese1lt at the July 29 public
hearing were the ultimate decision makers for the site. He noted that com'eying the sentiments of
the people at the hearing to higher lel'elmanagers who were not in attendance would be a
difficult task.
RESPONSE: The Regional Administrator, Julie Belaga, has the authority, delegated by the
President of the United States, to make the final decision on the site. EPA had the July 29
hearing transcribed and has produced meeting summaries of previous meetings to help convey
the community's sentiments. EPA representatives present at public hearings and meetings
ensure that the community's feelings regarding the site cleanup are conveyed accurately to the
Regional Administrator.
COMMENT 60: A resident commcnted that the colltaminated groundwater is not going to hurt
anyone provided they do not drink it, and that unhealthy water is not a problem unique to
Milford. He addcd that he bciiel'ed none of the nation's groundwater may be fit for drinking
within 30 years.
RESPONSE: The site groundwater is not harmful to human health unless it is used for
household purposes including drinking. However, the possibility that someone in the future
may use the contaminated water for household purposes, and the fact that the aquifer is a
potential drinking water source, require EPA action at the site under CERCLA and the NCP. ..
EPA agrees that groundwater pollution is not unique to Milford but disagrees with the
implication that it therefore should be ignored. On the contrary, EPA's policy is to restore
potential drinking water resources so that the prediction voiced by the commentor is less
likely to come true.
COMMENT 61: Several citizens and public officials noted that Hitchiner and Hendrix are good,
responsible corporate citizens.
RESPONSE: EP A acknowledges this comment.
COMMENT 62: A citizen stated that EPA's expcnditure of effort on this aquifer is a poor use
of taxpayers' dollars given that other water sOl/rees are a\'ailable to the town. The citizen
Savage Municipal Water Supply Superfund Site
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suggested that these dollars would be better spent on other environmental problems such as acid
rain and ozone depletion. Another citizen suggested that EP A expertise should be exponed to
Kuwait, Prague, Gennany, Tokyo, Shanghai, Mexico City, or other environmentally dmnaged
areas that could use EPA talent. Still another pointed out that $1 million could be used to feed,
clothe, and shelter many people.
RESPONSE: EPA recognizes that there are many good uses for scarce public funds.
Congress has decided, through its enactment of CERClA, that the identification,
investigation, and cleanup of uncontrolled hazardous waste sites in the United States is a
significant nationaJ priority and that those efforts should be fmanced by the responsible
parties. EPA's efforts at this site are in keeping with the wishes of Congress as expressed
through CERCLA.
. o.
COMMENT 63: A citizen asked why a fine sufficient to cover the cost of the investigation and
remediation of the site was not levied against OK Tool in 1983 when the first studies of the
contamination were perfonned.
RESPONSE: EP A did not then and does not now have the authority to levy such fmes.
COMMENT 64: A citizen asked whether EPA is exercising common sense and being fair to the
City of Allchorage, Alaska ill EPA's enforcemelll of its sewage treatment requirements as
reponed in a syndicated newspaper cO/limn by Palll Han'ey, and how citizens involved in the
Sa~'age site call have confidence in EP A given EP A's actions in Anchorage.
RESPONSE: A copy of the Paul Harvey article and the response by the EPA Region X
Administrator are included in the attachments to this Responsiveness Summary.
COMMENT 65: A citizen proposed that EP A establish a proacti~'e research and development
facility at the site funded by federal grants and nm by a research university. The justifications
gi~'ell for this course of action are: l)pllmp and treat is not yet a proven technology, 2)the aquifer
is nOI needed ill the near future for drinking waler, and 3)llew more effective and less expensive
remediation technologies are likely to be de~'e/oped in the near future. 77lis research facility
would help pro~'e the viability of EP A's prefe"ed altemati~'e as well as hasten the introduction of
more effecti~'e and less expensi~'e remedial tecllllologies.
RESPONSE: EPA considers pump and treat to be an effective technology based on
successful results at similar sites. As EP A continues to refine the technology, the experience
gained in the cleanup at this site will contribute to the body of scientific knowledge on
groundwater re:'lediation. EP A recognizes that new more cost effective technologies may
emerge in the future, and has incorporated provisions for the evaluation of such new
technology in the ROD. .
COMMENT 66: A citizen asked whether bioremediatioll was considered for the Savage site and,
if not. why not. He funher asked what is the likelihood that bioremediatioll will become feasible
in the next 20-50 years, and, if bioremediatioll does become feasible, would it render obsolete
some or all of the treatment equipment that would be purchased under the prefemd altemative.
i ~
RESPONSE: Bioremediation was considered for the site. Based on current information,
however, bioremediation is not effective on PCE contaminated water and so was not included
in the alternatives retained for detailed analysis. In addition, EPA cannot fail to take action
at a Superfund site today on the premise that some new technology may become available in
the future.
24
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COMMENT 67: A State Sellator stated tllat EP A's preferred alternative is a reasonable choice
for cleanup at tile site. Several citizells expressed suppon for the cleanup of the site, and one
called for the protection of tile site wetlands and the nearby fislleries. However, none of these
commentors supponed any more illtensi\'e efforts tllall tllose included in the Hitchiner/Hendl'ix
proposal or MM-5. The Milford Cabinet expressed general suppon for EPA and related state
agencies. Allotller resident expressed sllppon for a strong alld effective EPA. The Milford Area
League of Women Voters expressed gelleral suppon for environmental protection, cleanup, and
community relations on the pan of EP A.
RESPONSE: EPA acknowledges these comments.
COMMENT 68: A citizen alleged improper and unethical dealings between the town, Hitchiner,
and the local press regarding the town wastewater treatm~nt plant and the purchase of the Savage
Well.
RESPONSE: EPA acknowledges the comment.
COMMENT 69: A citizen asked for tllc "statc documclllatioll" of tile town's pumping and
testillg of the Savage Well ill 1986 as promised at tile July 11 public meetillg. TIle citizen did not.
specifv who had made tile promise.
RESPONSE: EPA is unable to identify the document referred to in this comment. EPA
suggests that the commentor may wish to contact Carl Baxter at the New Hampshire
Depa.rtment of Environmental Services at 603-271-2910 to pursue this question.
COMMENT 70: A citizell asked wllat steps lIa\'e beell takell by tile PRPs sillce 1983 to reduce
toxic waste at tlleir plallts.
RESPONSE: As a result of EPA permitting programs, some of the PRPs have made
substantial changes in the management of discharges from their plants which have reduced or
eliminated the discharge of wastewater to the environment. Some of the wastewaters are now
sent [0 the local sewage treatment plant. EPA refers interested members of the public to the
PRPs themselves for additional information on this issue. .
COMMENT 71: A citizell asked for a descriptioll of Hi/chiller's respollses to other EPA
citatialls for violatiolls of em'irOllmelllallaws tllat were 1I0t specified by the citizell.
RESPONSE: EP A is unable to identify the violations and citations referred to in this
comment. The commentor may wish to contact Project Manager Richard Goehlert at (617)
573-5742 to pursue this question further.
COMMENT 72: A citizen asked whether Hendrix is pumpillg coolallt illto tile Souhegan River.
RESPONSE: At this time, Hendrix has a permit to discharge only storm water on their own
property.
COMMENT 73: A citizen asked how for the contamillation has spread and how fast is it
movillg.
RESPONSE: The extent of the plume is shown in Figure 1 of the Proposed Plan which is
included in Appendix D. Groundwater flow rates calculated by the PRPs' consultants were
approximately 1.05 to 1.21 feet per day.
Savage Municipal Water Supply Superfund Site
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.
COMMENT 74: A citizen asked lIow much attention is being paid to tile public health dlmger
posed by contaminated water in the aquifer and the river.
RESPONSE: EP A has been addressing these issues through its investigation and cleanup
process at the site. The cleanup alternative selected by EP A is designed specifically to
mitigate the threat to human health posed by the site contamination through the use of
institutional controls in the short-term and the eventual restoration of the aquifer through
treatment in the long-term. The extensive commitment of government and private funds to
this process is evidence that a significant amount of attention is being paid to these issues.
COMMENT 75: A citizen asked whetller the PRPs will attempt to recover the costs 01 site
investigations and the cleanup by suilrg otller PRPs including the town. The citizen also asked
wlretlrer tile town and others will seek compensation for environmental dmnage under CERCLA..
RESPONSE: CERCLA does not limit the ability of any party to sue any other party for
damages relating to the site except where the party being sued has settled with EPA to pay
for some portion of the site work. EPA does not know whether the town or any other parties
will seek restitution for any damages relating to the site contamination.
COMMENT 76: 77le Milford Cabinet commellted tlrat tire size of tire audiellces at recent public
meetings on tire site slrould gi~'e EPA a sense of the magnin/de of concem regarding the cleanup.
RESPONSE: EPA recognizes the high level of public interest in this site and appreciates the
level of concern that has been shown by the community. Public participation is vital to the
Superfund cleanup process that Congress envisioned under CERCLA. EPA encourages the
community to remain actively involved with the site as it moves into the Remedial Design and
. Remedial Action phases of the cleanup.
COMMENT 77: 77le Milford Cabillet stated tlrat, by delayillg construction of a new bridge
across tire Soulregall Ri~'er, EPA e.1posed the public to far more risk tlrall would have been
created by disn/roallce of tire cOlltamillated soils required for tire COllstructi01r of tire bridge.
RESPONSE: The question of whether the chromium in the contaminated soils posed a threat
to human health raised a number of difficult technical issues. Until the Risk Assessment
could be completed and these issues resolved, EPA was unable to evaluate the risk associated
with removal of the soil. As soon as the risk was evaluated, EPA promptly notified the state
that, based on the available information, EP A has no objection to construction of the bridge
once the ROD is issued.
COMMENT 7&- 77re Milford Cabinet stated tlrat sufficient evidence has not been presented to
cOllcJude tlrat the cost/bellejit ratio for tire prefc"ed alten/ative is reasOIlable.
RESPONSE: Under CERCLA, remedy selection decisions are not based upon a simple
cost !benefit ratio. Instead, cost is one factor that is weighed along with long-term
effectiveness, reduction of toxicity, mobility and volume through treatment, short-term
effectiveness, and implementability. All CERCLA remedies must be cost-effective.
COMMENT 79: 77le Milford Cabinet asked whether, in retrospect, the Sa~'age Well
cOlltamillati01I was serious ellough to merit illclusion on the NPL, and wlretlrer EPA could
re~'erse its cleanup decisions if EP A dctennilled that the con tam illation was not serious enouglr
to warralrt remediatioll.
26
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RESPONSE: In retrospect, there is no information that has been made available since the
time of the site's listing on the NPL which would mdicate that the listing was incorrect. If
during the RI it becomes apparent that the site no longer meets the requirements for listing
as a Superfund site, EPA would initiate the process to delist the site, which would include the
selection of a "No Action" cleanup alternative for the site.
COMMENT 80: The Milford Cabinet asked how the risk from the contamination compares
with 'he risk of cancer from eating mea' cooked over a charcoal grill.
RESPONSE: The health risk associated with exposure to carcinogenic compounds is
expressed as the probability of a person developing cancer given some level and duration of
exposure. The risk of developing cancer from exposure to benzo(a)pyrene from eating 100
charcoal-broiled steaks over a lifetime is one in one million (based on published information
supplied by the commentor). That is, if one million people each eat 100 charcoal-broiled
steaks in each of their lifetimes, one of those persons will develop cancer attributable to
eating the steaks. The risk of developing cancer from drinking two liters of water from the
most heavily contaminated part of the plume every day for a 7o-year lifetime is estimated to
be one in five. That is, if five people drink two liters of the contaminated water every day of
their lives for 70 years, one of them would develop cancer due to the contamination.
It should be noted that the groundwater contains other compounds that are not
considered to be carcinogenic. The risks associated with these compounds are Dot expressed
as probabilities, and therefore are not directly comparable to the charcoal-broiled steak risk.
COMMENT 81: A resident urged EPA to prosecute any criminal violations of environmental
law OIl tl1e part of the PRPs.
RESPONSE: EPA will enforce the environmental laws which Congress has authorized it to
enforce. Under CERCLA, EPA's focus is to dean up the site and to recover response costs
from the PRPs.
COMMENT 82: A resident stated tllat tile cleaning and demolitioll of a storage 'ank had taken
place and tllat tllis acti~'it)' included the discharge of wash water to the groUlld. No location was
gi~lell for tllis actMty.
RESPONSE: EPA recommends that residents with concerns over activities they observe that
may be violations of environmental law report their observations to the New Hampshire
Department of Safety at 800-346-7009.
COMMENT 83: A resident claimed 'l1at 'he resident's housellold well had been contaminated
by bt~nzene, dich/orotrifluroetllalle. and triclliorotrifluroethane by 'he "Grugnale Waste Disposal
site. "
RESPONSE: The Grugnale site is Dot known to have any relation to the Savage site. More
information on the site may be obtained by contacting Carl DeLoi of EPA at 617.573.9645 or
Carl Baxter of the New Hampshire Department of Environmental Services at 603-271-2910.
COMMENT 84: 77le publisher of the Milford Cabinet had tile following comments on EP A's
July 11th public meeting: J )/71uch of.the discussion was 'ec/mical and beyond 'he understanding
of most of 'lie audience; 2),lIe o~'erhead projector was frequently out of focus and the images
were often impossible to read fro/71 the back of the rOO/71; 3)tlle public address system was
inadequate; 4)EPA failed '0 repeat ques'ions for tile audience resulting in the responses being
meallingless '0 tile audience; 5) a larger air-conditioned lIall would have been more comfortable;
and 6)tlle audience participated in the meetillg and EPA did listell to residents' concerns.
Savage Municipal Water Supply Superfund Site
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..
RESPONSE: EPA recognizes that environmental problems are often very complex, and EPA
has made efforts to explain the issues to the public in writing as well as at the meetings. EPA
acknowledges the comments regarding the facilities used for the July 11 meeting and notes
that EP A took steps to correct all of the deficiencies by the time of the public hearing. EP A
appreciated the level of audience attention and participation at both of the recent public
meetings.
COMMENT 85: A citizen made the following comments regarding the July 11 public meeting:
1) EP A should speak clearly and with compassion to convey a caring attitude - residents need
to know that EPA is prepared to respond to their concerns in a positive way: 2) the public
wants to be infonned in tenns of certaimies, not probabilities: and 3) the public is generally
scientifically unsophisticated and lacks interest in technical complexity and the will to make the
effort necessary to understand the problem. Another citizen commented that EPA talked "in
circles" at the meeting.
.
RESPONSE: 1) EPA acknowledges the comment.
. 2) Scientific data collected regarding environmental problems often contains a great
deal of uncertainty. EPA will attempt to explain the nature and level of the uncertainty to the
public so that the public can better understand the data and the decisions derived from it.
3) EPA understands that the general public is not schooled in scientific matters, and
EPA takes steps to explain issues to the public in a manner that can be readily understood.
EPA acknowledges that this effort may not always be successful for all members of the public,
however, EPA will continue to strive for increased public understanding of EPA programs
and emironmental issues in general.
COMMENT 86: Olle citizen requested a clear alld direct response to her comment letter.
RESPONSE: EPA hopes that the responses to all of the comments presented in this
responsiveness summary will be considered clear and direct by the public. Members of the
public may contact Susan Frank, the EPA Community Relations Coordinator for the site, at
617-565-3419 for clarification on responses in this document as well as with any other
questions they may have regarding the site.
. . .
COMMENT 87: The League of Womell Voters suggested that a meetillg be held betWeen EPA,
the PRPs, the state, alld the Milford Selectmell with all impartial negotiator ill attendance to
discllss the effects the proposed cleallup plalls may ha\'e 011 these parties. The League offered to
facilitate such a meetillg.
RESPONSE: CERCLA expressly provides for a negotiation process between the government
and the PRPs. Those negotiations will be conducted in private among the negotiating parties.
As noted above in the response to Comment 11, the public will have an opportunity to
comment on any proposed settlement before it is finalized. Therefore EPA thanks the
League, but declines the offer.
COMMENT 88: TIle Milford Selectmen stated that the community alld state acceptance criteria
should carry more weight at this site thall is usually allotted to those criteria in the Superfund
decision makillg process.
,)
RESPONSE: EPA has given serious and thorough consideration to all of the comments given
during the comment period. At the same time, EPA must comply with all of the
requirements of CERCLA.
28
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B.
State Comments
Wriuen comments from the State of New Hampshire are summarized below.
COMMENT 89: 77le New Hampshire Department of Agriculture requested that EPA inclu/k in
any cleanup plans provisions to ensure the continued suitability of state-owned farmlands 011 the
site for agricultural use.
RESPONSE: Please see EPA's responses to Comments 43 and 44.
Savage Municipal Water Supply Superfund Site
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C. Comments from Potentially Responsible Parties
Written and oral comments from PRPs are summarized below. Some of the comments submitted
by the PRPs dealt with the allocation of financial liability for the cleanup, responsibility for the
contamination, mixed funding, communication of funding issues to the public, EPA's enforcement program at
the site, and the impact of the cost of the cleanup on the local economy. EP A has addressed these issues in
the previous section on comments from the general public and readers are referred to EPA's responses to
the comments in that section.
COMMENT 90: The responsibility for cOlltamination at tlte site is e"asily divisible and must be divided. The
cost of tlte remedy should be apportioned.
.L
RESPONSE: Allhough CERClA does not explicitly confer joint and several liability on defendants, courts
have consistently interpreted CERClA liability to be joint and several unless defendants can demonstrate
that the harm is divisible. The courts have reasoned that where all of the contributing causes 10
contamination cannot fairly be traced, Congress intended that those proven partially responsible should bear
the cost of the uncertainty. O'Neil v. Pi cillo, 883 F.2d 176 (1st Cir. 1989)
EPA cannot impose joint and severalliabilily on a PRP. It is a question of law that can only be
decided by a court. However, the guiding principles used by the court are settled. If there are distinct
harms, or if there is a reasonable basis for determining the contribution of each cause to a single harm, the
court will not impose joint and several liability. The court will look to the PRP to prove its claim that joint
and several liability does not apply at this site.
COMMENT 91: Would the levels of TC4 ill the Savage Well would by themselves ha\'e been high enough to
require closure of the Sa\'age Well ill 1983 ullder regulatiolls ill effect at that time?
RESPONSE: The level of TCA in the Savage Well sampled by the state on February 15, 1983 was 326 ppb.
A recommended MCL for TCA was proposed by EPA in June 1984. The chemical was not regulated by the
Safe Drinking Water Act in 1983. The current MCL for TCA is 200 ppb. TCA, at the level given above,
was cited by the state as a contaminant which led to the closing of the well.
COMMENT 92: Hitclliller is not respollsible for tlte PCE cOlltamination emanating from the O.K Tool
CompallY. Hitclliner has ne\'er used PCE ill its production processes.
RESPONSE: EPA acknowledges the comment and appreciates any information relating to contamination at
this site.
COMMENT 93: TIle Oll(V part of the TC4 plume requirillg remediatioll at the site is a small area near the
Hitclliller property. Hitchi,ler is prepared to COIIStruCt alld operate a well alld treatment plant at Hitchiner to
remediate tile TCA plume adjacellt to tlte Hitclliller pia lit. Hitcllillcr already lias paid part of OK Tool's share
. of the site im.estigation cosls.
RESPONSE: In considering the extent of cleanup required at the site, the degradation products of the
contaminants cannot be ignored. TCA, which has an MCL of 200 ppb, can break down into vinyl chloride,
which has an MCL of 2 ppb and poses a much more significant human health risk. Another breakdown
product of TCA is 1,I-DCE, which has an MCL of 7 ppb. Thus the presence of TCA can result in
contamination of the aquifer with chemicals that pose a significantly higher risk. The PRP's comment
assumes that there is no danger from the continued presence of TCA below MCLs and ignores the potential
for degradation of the chemical. Therefore, the PRP has not made a complete assessment of the potential
risks to human health at the site. .
Funding proposals are premature at this time. The PRPs are aware that, following the signing of
the ROD, EPA will send special notices to each of the PRPs imiting them to enter into negotiations aimed
at funding the cleanup. EPA will consider funding proposals during the upcoming negotiation period.
30
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COMMENT 94: TCA contamination did IIOt cause tile closing of tile Sa~'age Well. TCA levels at the well are
below drinking water standards. and TCA is not a carcinogen.
RESPONSE: As described above (see Comment 91), TCA contamination was cited as one reason for the
closure of the Savage Well, and TCA, although not a carcinogen itself, can break down into other chemicals,
some of which are carcinogens. Based on limited sampling, the levels of TCA near the Savage Well at this
time are below the MCL of 200 ppb. For reasons such as seasonal variability, it is premature to state that
TCA concentrations at the well will remain below the MCL.
COMMENT 95: Hitcllitler generally supports EP A's proposed remedy for the site with some reservations
regarding tecllnical and phasing matters.
RESPONSE: EPA acknowledges the comment. Please see EPA's response to Comment 24 for a discussion
of phasing.
COMMENT 96: The site studies confirmed tllat OK Tool caused lhe PCE conlamination at the sileo
RESPONSE: EPA acknowledges the comment.
COMMEN7' 97: 71le preferred allemali~'e will not. ullder any circumstances. provide tile town with a water
- .supply in tlae foreseeable future. 71le preferred allemati~'e was more expensi~'e III an necessary.
RESPONSE: Both of these assertions are incorrect. Please see response to Comment 48. EPA has selected
the least costly remedy that will accomplish EPA's cleanup goals. The PRP group, which includes Hitchiner,
has had ample opportunity in the RifFS process to prepare cost estimates, perform studies of technologies,
and search for less costly alternatives which will meet the goals of CERCLA. The cost estimates for all of
the alternatives were developed under the guidance, direction, and re\iew of the PRP group.
COMMENT 98: 77le rate at wllich Superfund remedies in llle nation are being found to be ineffectiw! is
increasing, and, therefore, treatment of tile extended plume should be deferred until cOlltainment of the
cOllce/ltratea' plume has been proven effecti~'e.
RESPONSE: EPA is not aware of any evidence that the rate of Superfund remedies being found to be
ineffective is increasing. Even if such a trend did exist, it would not apply to this site because proven
technologies will be used. In addition, please see response to Comment 24 for a discussion of the difficultie.s
that would arise from delaying the start of any portion of the cleanup.
COMMENT 99: Hitchiner would be willing to gi~'e the Sa~'age Well site back to tile tOW1l and to extract and
treat 500 gpm of water for potential use by tile town as a water supply.
RESPONSE: As this is a matter between the town and Hitchiner, EPA has no comment.
COMMENT 100: Joillt alld several liability historically has applied only to those cases where responsibility
could /IOt bl! dMded among se~'eral parties. 77le PRP stated tllat the principle cannot be applied to the
allocation of tile costs for cleanup at tllis site because it is possible to divide tile responsibility for lhe pollution
of tile aquifer. The PRP commented tllat imposing 0/1 HitclJiner and Hendrix jinancialliability for pollution
tllat Illey did nOI cause would be gross(v unfair and COlllrary 10 tile law.
RESPONSE: These issues \\;11 be addressed in the context of settlement negotiations. The burden of
proving divisibility rests with the PRPs. Under the law, joint and several liability will apply to this site if the
PRPs cannot prove di\isibility.
Savage Municipal Water Supply Superfund Site
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COMMENT 101: The cumnt owner.s of OK Tool were not made aware of the magnitude of the contaminalion
problem that may have been caused by the former OW1ler.s and operator.s of the plant, and the cumm owner.s of
OK Tool did not contribute to the contamination because the plalll was closed immediately following its
purchase.
RESPONSE: Pursuant to CERCLA ~ 107, both the current and former owners of the OK Tool facility are
potentially liable for the contamination at the site. However, it is also possible that the current owners of
OK Tool may be in a position to bring other forms of legal action against the former owners of the facility.
COMMENT 102: Due to the groundwater flow patterns as established in the site studies, dissolved PCE would
not have migrated from the OK Tool plant to the area under the Hitchiner and Hendrix plants. This conclusion
is based on the Rl groundwater elevation and flow direction figures which were developed while the Hitchiner
and Hendrix wells were in full operation. Hitchiner records indicate that Hitchiner did use PCE in the past and
that Hitchiner has a past record of problems regarding improper waste disposal practices. Therefore, the PCE
contaminated groundwater found on the Hitchiner alld Hendrix properties may have resulted from the past
operations and waste management practices of those companies rather than from releases of PCE at the OK
Tool plam.
RESPONSE: EP A has drawn no conclusions regarding responsibility for the site contamination.
,
COMMENT 103: PCE is the on~v potential problem at the site, and only PCE or its degradation products
exceed EP A required cleanup levels at the downgradient portion of the site.
RESPONSE: Strictly using exceedences of MCLs, PCE concentrations in the distant downgradient portions
of the site are used to drive the required cleanup level. However, the PRP's consultants provided no
predictions as to the future transport of other chemicals that may spread to the downgradient portions of the
plume or the transport of transformation products of chemicals to downgradient portions of the plume. Two
of the transformation products, vinyl chloride and 1,I-DCE, have MCLs of 2 ppb and 7 ppb which are very
close to the MCL of 5 ppb for PCE.
1,1 DCE and vinyl chloride may actually result in some of the same biodegradation by-products.
This factor would seem to cloud the consideration of impacts as Well as the efforts being made to separate
the two plumes.
COMMENT 104: PCE at the site can be attribllled to only OK Tool.
RESPONSE: Capture zones constructed using groundwater contour maps in the RI Report (Figures 3-13, 3-
14,3-16) suggest contaminated groundwater beneath the OK Tool facility has not moved toward the
Hitchiner production well but has moved to the Hendrix production well. This information coupled with
Hitchiner's admission of PCE use appears to contradict the assertion that the PCE portion of the
groundwater contamination is attributable only to OK Tool.
COMMENT 105: DNAPLs should be the primary concern of the remedy at the site. The most that can be done
is to coma;'1 DNAPLs to prevent the spread of contamination. Numerous studies of remedial programs at other
Superfund sites have confirmed that containment of suspected DNAPL sources is the onl)' way to address such
contamination. EPA's continued attempts to deny the presence of DNAPL has led to the selection of an
inappropriate remedy for this site
.\,,:'0
RESPONSE: There exists a considerable amount of circumstantial evidence to indicate that DNAPLs exist
at the site. However, no sample of DNAPL has been obtained from any well and no water samples from a
given well have exhibited concentrations of contaminant at 10 percent or more of individual solubility limits.
The comment letter itself and attached exhibits actually pr0\1de information to support EPA's position. The
PRP comment letter itself is contradictory. The PRP letter references an attachment from one of their
consultants and provides the following: "...attached as exhibit 3 which further supports the conclusion that
','
32
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DNAPLs likely are present..: A conclusion of another PRP consultant presented in Exhibit 1 of the package
cited above is: "Unfortunately, it is not possible to calculate the reduced, effective solubility at the Savage
site because a sample of the DNAPL has not been colIected: The use of the word "likely" is not a mistake
and provides insight as to what can or cannot be defmitely said by the PRP Group. While EPA agrees that
DNAPLs m..y be present, EPA must approach the site recognizing that EPA has no conclusive proof as to
its existence, extent or volume.
In light of the lack of conclusive proof of the existence of DNAPLs at this site, EPA has not chosen
to emphasiZl~ the DNAPL "argument" or the probability of existence of DNAPLs. At no time has EPA
expressed or sought to imply that DNAPLs, if they exist in volume, could be remediated within a 30 year
time frame. Furthermore, a "containment system" is an integral part of the Proposed Plan in recognition of
the probable existence of DNAPL. The predictions of cleanup time have never been misrepresented. EPA
has consistently recognized that the cleanup time for DNAPLs would be indeterminate.
COMMENT 106: A phased approach is necessary and only after containment is accomplished would it be
remotely practicable to implement funher measures in any ponion of the downgradient plume.
RESPONSE: The NCP indicates that where there is significant uncertainty as to the success of the
groundwater remediation a "phased" approach to the remediation may be appropriate. In this case EPA
does not believe sufficient uncertainty exists with regard to the success of the remediation of the "extended
plume" since contamination within the extended plume is in a dissolved state. Remediation of the extended
plume is the functional portion of the remedy which v.ilI result in aquifer restoration. The phased approach
would delay aquifer cleanup and result in longer time for restoration and a lesser degree of protectiveness.
EPA agrees that successful remediation of the extended plume is in part dependent upon
containment, and, if possible, the remediation, of the concentrated plume since it does appear to act as a
"source" of c:ontamination for the extended plume. However there is reason to believe that the hydraulic
containment proposed wilI be sufficiently successful such that remediation of the extended plume can
commence nearly simultaneously. Additionally, since the two extended plume pumping locations are
significant distances from the concentrated plume, the pumping of the concentrated area will have no adverse
impact on the physical location of downgrl1dient wells or the design and implementation of these extraction
systems. Further, there is nothing in the ROD that precludes a short time lapse between implementation of
the concentrated plume remediation/containment system and the downgradient systems should this be
determined to be appropriate during the remedial design phase. The "phased" approach as proposed in the
comment is not necessary and accomplishes little other than a delay in the time required for the overall
cleanup of the aquifer.
COMMENT 107: TCA (J, J, J- Trichloroethall e ) is not a silJllificallt problem at the site and does not contribute
to downgradient groundwater contaminatiOlI above MCLs.
RESPONSE.: TCA (l,l,l-Trichloroethane) concentrations do exist in the aquifer above the MCL of 200 ppb
and therefore it is a contaminant of concern. TCA may also degrade to by-products in a way that individual
by-product concentrations, such as vinyl chloride, may eventually exceed MCLs.
COMMENT 108: EPA has ignored the TOWII of Milford's zonillg designation for the site area and that.
de~'elopmelll alld land use in and around the site make the aquifer an ulllikel)', and under State regulations and
polic)', unpemlitted, site for a drinkillg water well.
RESPONSE: Zoning is not a reliable control on land use over the 10()+ year time frames of the less rapid
cleanup alternatives. Zoning may be changed by future governments for reasons not anticipated at this time.
Zoning does not preclude the development Qf a public water supply welI at this time.
The potential use of the aquifer has been diminished only by the need and cost to treat water
extracted from it. High yield aquifers are limited in number and its is national and state policy to protect
and restore its water resources.
The Department of Environmental Services' letter of July 11, 1991 to the Town states that:
Savage Municipal Water Supply Superfund Site
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7he recently enacted Groundwater Protection Act, RSA 485-C, clearly established
that the best use of all state groundwater is drinking water supply, and that all potential
contamination source activities shall be conducted so as to eliminate or minimize the tbreat
of groundwater contamination, regardless of where those activities are located.:
"Although the aquifer in the vicinity of the Savage Well may rem.nn unsuitable for
drinking without treatment for a long time, the ultimate goal must remain restoration to
drinking water quality. If you would like further discussion on these issues, please call
myself or Paul Currier, P.E., Administrator of the Groundwater Protection Bureau at 271.
3503:
~.
In comments on the NCP as presented in the Federal Register Vol. 55 No. 46 3/8/90 Pg. 8732. It is noted
that:
"Reasonable restoration time periods may range from very rapid (one to five years) to
relatively extended (perhaps several decades)"
"... If there are other readily available drinking water sources ... the necessity for
rapid restoration of the contaminated groundwater may be reduced:
The proposed plan recognizes the above discussion with the "several" decade goal clearly considered and
adopted.
- The Town's zoning and PRP arguments ignore the current use of the aquifer as a water supply for
housefiold wells nonh of the river, which is zoned residential. Those houses represent a current use with a
future risk of contamination.
COMMENT 109: CU"Cllt cOllditiolls do II0t pose a risk to humall hcalth or thc elU'irOllment as documented by
the samplillg alld allalysis data alld ill the documcllts which address the Humall Health Risk Assessment and
the Ecological Risk Asscssl7lcllt.
RESPONSE: The assessment of current risk without any water use is correct. If the water is to be used,
there is a risk. It should also be noted that there is a current use of the bedrock aquifer for household water
supply nonh of t}ie river, which creates a future risk. The objective of a site remediation is to clean up the
aquifer to a level that will allow future use as a drinking water supply without treatment and to protect
existing uses. This policy is used at Superfund sites throughout Region I and is consistent with the NCP,
which recognizes that contaminated groundwater be returned to its beneficial use in a reasonable time frame.
COMMENT 110: EP A's remedy is lIeithcr cost effectil'e nor e/ll'irolll7lentally co"ect. TIle costs were not
developed co"ectly.
RESPONSE: Per RI/FS Guidance and the NCP, a range of alternatives is compared using a total of nine
criteria. These nine criteria are explained in detail in the FS and the Proposed Plan, and were also
presented at the public meeting on July 11, 1991. The cost comparison guidelines are detailed in the RI/FS
guidance and the comparisons are done in accordance with the guidance.
In the EPA's judgement, the selected remedy is cost effective, in that overaJi effectiveness of the
remedy is proportional to the cost of the remedy. EPA came to that conclusion after first identifying
alternatives that are protective of human health and the environment and that attain ARARs. EPA then
evaluated the overall effectiveness of each alternative by assessing the three relevant criteria: long term
effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment; and short term
effectiveness. The relationship of the overall effectiveness of those remedial alternatives was determined to
be proponional to their costs.
34
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COMMENT 111: 17le PRP Group states olle of its consultants has determined that problems with the pumping
configuration combined with flaws in the capture zone analysis would lead to junher downgradient migration of
high concentrations of PCE from OK Tool. 17lis is interpreted to mean that contamination from the
concentrated plume cannot be contained with the well configuration as in the Proposed Plan due to flaws and
problems in Ihe Feasibility Study.
RESPONSE;' The capture zone analysis was proposed and implemented with full knowledge of the PRP
Group since it was done by one of the PRP consultants. The use of the Hitchiner well pumping test data
was requested by the PRP Group and their consultants. Capture zones estimated by these data may be
optimistic for lower portions of the aquifer. The estimates are, however, believed to be sufficient for ROD
purposes and additional data will be obtained during the Remedial Design phase.
The pumping configuration for the concentrated plume was and is still the proposal from the PRP
Group and its consultants. EP A did not alter the PRP proposed configuration of the wells at the
concentrated zone. If there are flaws in the analysis, the PRP Group should have identified them during the
study rather than after the reports were final and the remedy proposed. Throughout the FS and in the
Proposed Plan the number of wells, the location of wells and their extraction rates are subject to refmement
during design. The concept of extraction, however, at three locations in the length of a 6000 foot long plume
is correct.
COMMENT 112: UV oxidatiOlI tec/llIology call be IIsed to treat effecti\'ely TCA and the ROD should allow the
use of the tedlllolo~' to treat TCA.
RESPONSE: The FS Addendum was developed at the last minute at the specific request of the PRP Group
to include UV oxidation at certain treatment locations. It was the PRP's determination that use of UV
oxidation to treat TCA is less effective than air stripping technology. There have been no treatability studies
performed specific to the site and the use of either technology must be addressed in the design phase
through treatability studies to address the problem of metals in the groundwater. If studies prove that UV
oxidation is superior to air stripping, it could be utilized.
COMMENT 113: 17lere is little differellce betweell the cleollllp times of MM-3 alld MM-llA thus the extended
plume should be aI/owed to lIotllrol/)' ottelll/ote.
RESPONSE: The 25-90 year cleanup time frame for MM-3 does not compare favorably with MM-1IA.
MM-11A is expected to take 15 to 60 years, or roughly 10 to 30 years less than MM-3. The downgradient
remediation portion of MM-llA is the truly functional feature of the Proposed Plan. While extraction wells
in the more concentrated plume areas may achieve a high mass rate of removal, extraction wells further.
downgradient y,ill result in a positive and timely effort to remediate much of the bulk volume of the
contaminated aquifer. The uncertainty in cleanup times is clearly recognized in the FS and the Proposed
Plan. Also, it should be noted that the shorter time frames included in each range are based upon the same
pump test that the PRPs themselves question in these comments, and from a technical standpoint seem to be
extremely optimistic. The most likely timeframes is somewhere between the range extremes.
COMMENT 114: 17le contaminant plumes are chemically distinct and call be separately delineated.
RESPONSE: The PCE and TCA portions of the plume are alleged by the PRPs to have tWo distinct origins.
TCA was reported to have been used at Hitchiner and Hendrix and possibly at OK Tool. PCE was reported
to have been used at OK Tool and in small quantities at Hitchiner. However, both contaminants appear to
be intermingled in a single plume.
COMMENT 115: 17le capture zOlle colculotiolls are flowed olld the dowlIgradient wells will result in the
pumpillg o",j treotmellt of cleoll wOler from the .Souhegoll Ril'er.
Savage Municipal Water Supply Superfund Site
-------
RESPONSE: The data used by the PRP consultants to calculate hydraulic coefficients of the sand and gravel
aquifer beneath the site were obtained from the Hitchiner well (MW-31) pump test. The Hitchiner well is
screened in the highly productive sediments of the middle sand and gravel aquifer. As one might expect,
hydraulic conductivity values calculated from this data set are the highest of aU the tests conducted.
Therefore, the most optimistic range in values (required for flushing) were obtained. As a result of this
choice, discharge rates for aU well schemes are probably high and the time periods required for plume
attenuation or cleanup are short. Accelerated "cleanup" of the extended plume is feasible. However, it may
be appropriate to modify alternative MM-ll during design to include pulsed pumping and injection wells.
The number, locations, and rates of pumping of the extraction wells, as has been noted in the
responses to several comments above, are used to estimate cost for the ROD. During Remedial Design,
specifics as to the array of extraction wells and pumping rates will be determined.
The current aquifer conditions and plume size constrain the volume of extraction well discharge to
approximately 1000 gpm. Pumping a volume of water greater than this would extend the capture zones of
the extraction wells outside the area of the plume. As a result, an unnecessary percentage of clean
groundwater would be mixed with the plume degraded groundwater and the efficiency of the extraction
system would be reduced.
Alternative MM-llA would operate at an appropriate pump rate of up to 1100 gpm.
The downgradient wells are located to remediate areas where MCLs or risk based limits are
exceeded. While PCE appears to be the contaminant of concern in the extended plume, sample dilution
needed to quantify PCE may mask exceedances of MCLs by other compounds. Also the detection limit for
,inyl chloride exceeded its MCL and no judgement can be made for this contaminant at this time.
COMMENT 116: Region I chose the inco"ect ARAR for the quality of the effluent to be discharged from the
treatmem plam.
RESPONSE: The use of MCLs to establish treatment/discharge criteria is appropriate where treated water
may be discharged either directly to groundwater or a surface water body that recharges an aquifer such that
the groundwater quality may exceed MCLs. The goal of CERCLA is to restore the aquifer to drinking water
quality and the quality of the discharge of water to the ground is directly related to that goal.
The aquifer, while currently not used for public water supply, may have any number of possibilities
as a private water supply and in fact is currently used for drinking water by residences north of .the Souhegan
River. Thus, a goal of drinking water standards is not unreasonable.
COMMENT 117: TIle mass removal rate of MM-11A and the Hitchiner-He~ldrix phased approach is not so
signijicalll as to require additional cleall-up of the aquifer beyond the cOllcelltra/ed plume. The additional 300
lbs/yr of MM-11A remo~'ed over the 1920 lbs/yr of the Hi/chiller-Helldrix proposal is not cost effective.
RESPONSE: The 300 Ibs/yr. or mass removal is the 16 percent increase over the mass removal of 1,920
Ibs/yr for alternative MM-3. Moreover, MW.llA address a much larger area and volume of the affected
aquifer than MM-3 and will inhibit further migration of the more downgradient portion of the plume. The
downgradient portion of MM-llA is the functional feature of the Remedy. While the wells in the more
concentrated plume are designed to contain that area and may achieve a high mass rate of removal, wells
further downgradient will result in a positive and timely effort to remediate much of the bulk volume of the
contaminated aquifer. See Comment 106 for further discussion on the extended plume cleanup.
COMMENT 118: TIle sciemiJic studies alld other site infonnatioll indicate that OK Tool is not the sole source
of cOllla17lillatioll.
RESPONSE: EPA has drawn no conclusions regarding responsibility for the site contamination in the
Record of Decision. .
36
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COMMENT 119: Based on groundwater ele~'ation contours and flow direction figures developed while Hitchiner
and Hendrix were pumping tile aquifer, PCE migratitlg witlt groundwater from OK Tool should not result in
contaminating groundwater at tile Hitchiner and Hendrix facilities.
RESPONSE: See Comment 104.
COMMENT' 120: Tlte study sltows a bias against OK Tool and clearly favors the other PRl's regarding sources
of contaminmion.
RESPONSE: EPA has expressed concern about this matter in correspondence to the PRPs during the
conduct of the RIfFS. The internal tensions between the PRPs and the influence that one PRP or a group
of PRPs exerts over their consultants is not a matter over which EPA has control. However, the reference
to bias concerns the identification of sources and associated responsibility for site contamination and not th~
adequacy of the technical data which is used for remedy selection.
COMMEN7' 121: Hite/liner and Hendrix manipulated the RI/FS to avoid investigation of the former "lAke
Louise. ..
RESPONSE: The investigation of contamination and possible source area is part of EPA's continuing
enforcement activities.
COMMEN7' 122: Tlte pumping of groundwater at 250 gpm at tlte OK Tool location would itlcrease the
groundwater flux at tllis location to cause an increase in the nOlI contaminated groundwater from the Souhegan
Ri~'er flowing to the extraction well which would result in all IlIlIIecessarily large capacity treatmellt system and
reduce groundwater treatment efficiency.
RESPONSE: The FS and the Proposed Plan have stated that there are studies to be accomplished in the
Remedial Design phase that will address the location, size. and pumping rate of extraction wells. The
concern raised in the comment is one that is known to the field of hydrogeology and will be addressed in
design.
COMMENT 123: DNAPL sources in all aquifer affects tlte design of groundwater extraction systems and it is
recommended tit at multile~'el monitoring wells be installed.
RESPONSE: EPA has acknowledged the potential for DNAPLs and that review and implementation of
technologies particular to DNAPLs will be a part of the remedy should design studies indicate they are
appropriate. A monitoring plan will be included in the selected remedy. .
COMMENT 124: 17le Remedial DesilJll sltould include groundwater modeling to assess pumping rates,
groundwatel' captllre zones, contaminallt attenllation and potential groundwater contaminant plume migration.
It is specifically recommended tit at f).1ractioll well # 2 in tlte extended plume be relocated or eliminated to
a~'oid treating non-contaminated Soultegan Ri~'er water, well # 1 be relocated to cut off the contaminated
plume, and tltat wells # 3 and # 4 be eliminated.
RESPONSE: The FS, Proposed Plan, and the ROD identify broad design issues that would include the
assessment of the location and pumping rate of wells for the maximization of extraction and treatment of
contaminated groundwater. Wells # 3 and # 4 are located to capture for treatment contaminated
groundwater with PCE concentrations greater than 500 ppb. This is 100 times greater than the MCL Cor
PCE. This represent a high level of contamination that must be prevented from spreading. Additionally the
low v.ithdrawal rates of 50 gpm for each well is recognition of the need to maximize the efficient removal of
contamination at this location in the aquifer. EPA believes the selection of a conceptual remedy that
includes wells in the vicinity of the river is a prudent and realistic choice.
Savage Municipal Water Supply Superfund Site
-------
COMMENT 125: Site characteristics, COIlSiSlellt wilh EPA guidallce and CERCLA requirements, indiCale a
long time frame restoration with limitcd trcalmCllt is warrallted. It is recommended that groundwater extraction
and trealment be conducted at Ihe OK Tool CompallY, Hitchitler Manufacturing Company, and in the vicinity of
the Sa\'age Well downgradient of Hendrix Wire alld Cable CompallY. 17le remaining ponions of the
contaminated plume should undergo natural atlelluatioll.
RESPONSE: The time frame for restoration is consistent with EP A guidance. The selected remedy,
MM-llA has a caJculated clean up time of 15 to 60 years. Sixty years is considered a long time frame and is
consistent with the NCP.
In comments on the NCP as presented in the Federal Register Vol. 55 No. 46 3/8/90 Pg. 8732. It is
noted that:
~.
"Reasonable restoration time periods may range from very rapid (one to five years) to
relatively extended (perhaps several decades)"
"n. If there are other readily available drinking water sources .n the necessity for
rapid restoration of the contaminated groundwater may be reduced."
The proposed plan recognizes the above discussion v.ith the "several" decade goal clearly considered and
adopted.
The precise locations, number of extraction wells, and pumping rates will be refined in the Remedial
Design. The elimination of three of the wells in the extended plume is not acceptable. The capture of the
plume in the middle at the location of wells # 1 and #2 is necessary to eliminate further downgradient
migration of the highest concentrations of contaminated groundwater in the extended plume. The amount of
natural attenuation that is allowed is significant. The elimination of wells # 3 and # 4 is addressed in
comment 18 above. Finally, the selected remedy results in the cleanup of the Savage Municipal Water
Supply aquifer in a "reasonable" time period as defined by the NCP, whereas the PRP proposal would appear
to add a significant number of years to the cleanup.
38
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IV.
REMAINING CONCERNS
Issues raised during the public comment period that will continue to be of concern as the site moves
into the RD IRA phase are described briefly below. EP A will continue to address these issues as more
information becomes available during the RD IRA.
1.
£Con,omic Impact: The public will continue to be interested in and concerned over the question of
who \\ill pay for the cleanup until this issue is resolved through a settlement or court action. The
public will wish to be informed on developments related to the negotiations and any legal action
EPA may take. Intense public opposition is likely to arise if EPA takes actions which are
incOluistent with the public's concept of what is a fair allocation of costs at the site or if EPA takes
actions which the PRPs strongly oppose. The public will also expect EP A to fully justify its actions
to the community and to be available to listen to community input into the decision making process.
Public interest is likely to be high at the time of a settlement, the initiation of a legal action by EPA
against either Hitchiner or Hendrix, and at any time during the Remedial Design or the Remedial.
Action when EP A may make decisions which could greatly increase the cost of the remedy. The
issue of economic impact is the chief cause for public concern at this site, and when this issue is
resolved public interest can be expected to wane considerably.
2.
Public Water Supplies: The town is likely to pursue the potential for use of the treated water as .
public water supply. Public interest could increase if EPA took any steps that could preclude the
use of the water by the town or increase the cost of that water.
3.
Sprl~ad or Contamination: If the contamination spreads to encompass many additional private
properties or contaminate water supply wells, public interest may increase. Issues that would arise
include: l)the ability of the remedy to stop further spread of the plume, 2)delays in implementation
of the remedy, 3)the liabilities and rights of the property owners impacted by the plume, and 4)the
extend of EPA well testing programs related to the site.
Savage Municipal Water Supply Superfund Site
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ATIACHME~" A
Formal Community Relations Activities Conducted To Date at
the Savage Municipal Water Supply Superfund Site
continuous
EP A maintenance of the site mailing list.
6/85
7/12/85
EPA Community Relations Plan (draft only).
EP A press release announcing 7/29/85 public meeting to discuss start of Remedial
Investigation and Superfund process.
(undated)
EPA Meeting Summary of 7/29/85 public meeting.
9/86
8/10/87
EPA Community Relations Plan completed.
EP A press release announcing Consent Order between EP A and Potentially
Responsible Parties.
1/88
10 /88"
Community Inter.;ews for Community Relations Plan Revision.
Revised Community Relations Plan.
12/88
Fact Sheet covering site history and providing an overview of the Remedial
InvestigatiO"n/Feasibility Study and the Superfund process.
12/6/89
EPA Community Relations Coordinator letter to citizen in response to inquiry
regarding Technical Assistance Grants program.
7/90
EPA fact sheet on the Remedial Investigation/Risk Assessment announcing 8/8/90
public meeting.
8/8/90
8/90
EPA public meeting on the Remedial Investigation.
EPA meeting summary of 8/8/90 public meeting.
7/91
EPA Administrative Record made available to public.
7/2/91
EPA press release announcing availability of EPA's Proposed Plan, the public
comment period, public meeting, and public hearing.
7/3/91
EPA public notice of the Proposed Plan, comment period, public meeting, and
public hearing.
7/11/91
7/12/91-8/10/91
EPA public meeting on the Proposed Plan and Feasibility Study.
EPA public comment period on the Proposed Plan and Feasibility Study.
6/21/91
EPA public notice of new public hearing location and time.
7/29/91
9/27/91
EPA public hearing on the Proposed Plan and Feasibility Study.
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ATTACHMENT B
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I
1 - '35
pll.IS i
2
UNITED STATES OF AMERICA
3
ENVIRONMENTAL PROTECTION AGENCY
4
BOSTON REGION
.~
5
6 In the Matter of:
PUBLIC HEARING RE:
7
SAVAGE MUNICIPAL WATER
8 SUPERFUND SITE
MILFORD, NEW HAMPSHIRE
9
SUPPLY
10
11
12
Mc,nday
July 2'3, 1'3'31
13
14
Jc.hn Burns R,:,c'm
Hampshire Hills Sports & Fitness
50 Emersam R.:.ad
Milford, New Hampshire
15
16
17
The above entitled matter came on for hearing,
18 pursuant to Notice at
2:15 o'clock p.m.
19
20 BEFORE:
. .~(
DANIEL COUGHLIN
Chief
New Hampshire Superfund Section
U.s. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02203
21
~4..~
:.~:;.....
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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i
APPEARANCES: Continued
1
2
RICHARD GOEHLERT
Remedial Project Manager
U.S. Environmental Protection
J.F.K. Federal Building
Boston, Massachusetts 02203
Agency
-;.
~,
4
5
6
RICHARD H. PEASE
Supervisor of Remedial Engineering
New Hampshire Department of Environmental Services
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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23
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25
APEX REPORTING
Registered Professional Reporters
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2
3
4
IgE.!~
5
Opening Remarks
6
Proposed Plan Overview
7
Public
C':.mments
8
9
10
11
12
IgE.!~
13
Openi ng F~emar ks
14
Proposed Plan Overview
15
Pub I i c Cc,mment s
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17
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25
.-.
..:.
.!_~_JLg_~
~EIg8~QQ~_agaa'!Q~
aEg~tSge
E~!aS;
Mr. C.:oughlin
2
Mr. Gc.eh I er t
7
Partio:ipants
16
g~g~HHLaS:aa'!Q~
aEg~t;s:e
E~!aS:
Mr. Coughlin
58
Mr. 130ehlert
62
Participants
71
APEX REPORTING
Registered Professional Reporters
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..,
.;,
E_8_Q_h_g_g_~_1_~_~_a
2
COMMENCED
(2:15 p.m.]
3
MR. COUGHLIN:
G,:,od a ftel"n':oon.
4
My name is Dan Coughlin.
I'm Chief of the
5
New Hampshil"e Supel"fund Section at EPA in Boston.
6
As you know, we'l"e hel"e today to conduct an
7
in f':11" mal
public heal"ing on the pl"oposed plan fol" the cleanup
8
of the Savage Municipal Well Supel"fund site.
9
Plesent with me tonight aye, on my I"ight,
10
Dick Goehlel"t, he's the Remedial Pl"oject ManageI' fol" EPA, .and
11
on my left, Dick Pease fl"om the New Hampshil"e Depal"tment of
12
Envil"onmental Sel"vices.
13
The pUl"pose of this heal"ing is to fOl"mally I"eceive
14
publi,:
EPA's pl"oposed plan of the Savage site as
': ,:ommen t ,:,n
15
well as the othel" altel"natives that we've considel"ed in the
16
I"emedial investigation and feasibility study.
On Thul"sday,
17
July 11th, EPA held a public infol"mation meeting in which we
18
pl"esented the I"esults of those studies, RI and FS as we call
19
them, and pl"esented the pl"oposed cleanup plan.
The pI" c'pc.sed
20
cleanup plan looks like this.
Thel"e aye copies available as
21
you come up the stail"s out back if you don't have one.
I
22
would encoul"age you to get one if you don't.
23 The public cc.mment pel"iod began con FYi day,
24 July 12th and wi 11 I"un till Satul"day, August 10, 1 991 .
25 Befol"e beginning, I would like tCI descl i be fc.r you
APEX REPORTING
Registel"ed Professional Reporters
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9
10
11
~
12
13
14
15
4
the format for the hearing.
First I'm going to ask Dick to
2
give us a brief overview of EPA's proposed cleanup plan.
3
Essentially, the plan is outlined in that proposed, in that
4
document I just held up.
5
Following that, we will accept any oral
comments
6
from anybody who wishes to make a comment on the record.
That
7
record will be taken, we're transcribing everything in its
8
entirety and we'll take that back and put together a complete
copy.
80 that everybody has an opportunity to comment,
I'm going to ask that you keep your comments to a maximum of
fifteen minutes.
If you think your comments are going to run
over the fifteen minute period, please summarize them for the
purpose of the oral presentation and then give them here today
in the written form or mail them. to us during the comment
16
period.
Again, that's so that everybody will have an
17
opportunity.
We have a lot of people here and we want to make
18
sure that everybody has an opportunity to offer whatever input
19
they would like to.
20
If I find that your comments are wandering a
21
little bit, I may attempt to focus you a little bit.
Again,
22
there are a lot of people that want to give comments.
This
23
will not be an attempt for me to try to limit on what you want
24
to say but rather to make sure we accomplish what we want to
25
do at this particular hearing and that's to get all the
APEX REPORTING
Registered Professional Reporters
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5
comments from everybody that wants to comment on the proposed
2
plan and on the alternatives that we're presenting for the
3
clean up the Savage Municipal Well Superfund site.
4
The hearing is an opportunity for EPA to listen to
5
your concerns regarding the studies that we did on the Savage
6
site as well as the proposed plans and the alternatives
7
investigated.
This is not a meeting as we had a couple weeks
8
ago in the public hearing for exchange of information.
It's a
9
public hearing, we will take comments,
transcribe them and
10
there will not be a back and forth that we had at the previous
11
meeting.
12
If you wish to make a statement,
you should sign
13
up on an index card that's available up back or at the top of
14
the stairs when you came in.
If there
I have several here.
15
are more of you who wish to make a statement, please sign on
16
the cards, I will get the cards and then I'll ask you to speak
17
~n order of which you signed them up, unless you have
18
indicated that you have some particular pressing reason why
19
you should go earlier.
20
After all the comments have been heard, I will
21
close the public hearing.
And if anybody would wish ~o su~mit
22
written comments during the public comment period, which ends
23
August 10th, I would encourage you to do so.
They should be
24
postmarked no later than August 10th.
They should be mailed
25
to our address in Boston and the address is on the third page
APEX REPORTING
Registered Professional Reporters
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5
of that proposed plan.
2
The summary of today's hearing and EPA's responses
3
to your comment, both written and given here tonight will be
4
part of the Record Of Decision for the Savage site.
The
5
Record Of Decision is a legal document in which EPA describes
6
its selected remedy and the basis for that remedy.
7
5,;:1, I thank y,;:lU all f':or
I hope y':lu have
c.;:.mi ng.
8
plenty of comments for us, I'm sure you do.
But befc.re we dc.
9
start,
I would like to thank the Hampshire Hills for having us
10
here today, it makes for a nice comfortable setting,
I think.
11
everyone can hear well.
12
So, with that, Dick, perhaps you can give your
13
presentat i ';:.n.
14
15
16
17
18
19
20
21
22
23
24
25
"
APEX REPORTING
Registered Professional Reporters
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7
E!QeQa~g_Elso_Q~~!~i~~
2
MR. GOEHLERT:
I would like to make one
3
suggestion,
mail them to me at
~f you want to mail comments,
4
this address.
And obviously we're not at the Milford Town
5
Hall, but we are on a low budget now and we didn't revise the
6
overheads.
7
Much of what you'll see now was said approximately
8
two weeks ago.
Briefly, this is the process we're going
9
through and we are at the hearing.
The next step is the
10
Record Of Decision with a response and a summary and the
11
response and summary is the responses to the comments that are
12
given both during the comment period and today.
And there
13
will be negotiations to facilitate and implement the final
14
decision of EPA, that is known as remedial action.
There are
15
two portions of that remedial action, construction and
16
operational
maintenance.
17
Briefly, these are again the results of th~
18
remedial investigation, site contaminants, the extent and the
19
site risks.
These are also in the proposed plan.
20
A question as to why a cleanup, this was begun at
21
th.last informational meeting and there have been several
22
cal1~ to me as well as some letters written in.
And again,
23
the reason for the cleanup is to protect residents to exposure
24
to unsafe groundwater, to restore. the aquifer drinking water
25
standards and those drinking water standards are known as
APEX REPORTING
Registered Professional Reporters
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. 13
~
o
maximum contaminant
levels.
We believe the aquifer could be
2
needed for drinking water in the future.
And we also believe
3
the aquifer can be suitable for drinking water.
4
This is the extent of contamination and
it goes
5
from by the OK Tool, Hitchiner, Hendrix facilities,
basically
6
parallel to Elm Street and across back over to Elm Street all
7
the way down to the river,
back over
other side of the river
8
there.
1000,
The number on each of these contours of 10,
100,
9
represents parts per billion of contamination, and this
is of
10
total
in the aquifer.
volatile organic contamination
11
The portion in the light blue down at the end of
12
the plume is is considered to be below the maximum contaminant
levels and if you were to sink a well down in here and
14
withdraw water, it would be considered safe for drinking.
15
Anywhere above this line, approximately above the 5 contour,
16
if you were to sink a well
in any of that area, that would be
17
considered unsafe drinking water.
18
Before putting on an overhead showing you the
19
components of the preferred alternative, this map shows the
20
locations of the six production wells that would provide
21
withdrawl of groundwater here, here, two one here and one
22
here, and two here on the other side of the river.
23
The volumes of water to be wiihdrawn from the
24
aquifer total
So that would be
1100 gallons per minute.
25
approximately 400 gallons ~er minute at the head of the
APEX REPORTING
Registered Professional Reporters
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9
contaminant right in there, approximately 600 gallons a minute
2
withdrawn from the middle of the plume, and approximately 100
3
gallons a minute withdrawn from the end of the plume on the
4
other side of the river.
There would be an amount of
5
contamination which is not covered by the shaded green
6
portions here which would not be captured for treatment and
7
would undergo what is known as natural attentuation.
Each of
8
the alternatives that EPA studied included natural
9
attentuation as part of the remedy.
10
The preferred alternative,
if any of you have
11
gotten over to the library to see the documents over there,
12
the preferred alternatives had a number and some letters, MM
13
stands for management of migration and the alternative number
14
was llA and basically this is what I've just described using
15
the map.
There would be two treatment plants, one using air
16
stripping, one using ultraviolet oxidation in the location
17
near OK Tool and the Hitchiner facilities, and there would be
18
one treatment plant in the middle of the plant presently
19
located near or at the existing Savage Well using ultraviolet
20
oxidation.
21
An important point to be made is that all
22
alternatives, including the preferred alternative, would have
23
to have institutional controls over the plume to preve~t the
24
use of the groundwater until the groundwater is safe to use,
25
that is for drinking water purposes.
MM11A has a minimization
APEX REPORTING
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11
... 12
13
10
of wetlands and what impacts, as do all alternatives.
We
2
believe that there may be wells or pipes,
the plants,
cone 0:' f
3
treatment plants would have to be located in the flood plan of
4
the wetland.
Pumping of the water from the aquifer could
5
impact the water table which would impact wetlands.
6
These items will be carefully considered in design
7
and every effort will be made to minimize any impact of that
8
nature.
Groundwater will
There will also be site monitoring.
9
be tested on a periodic basis, both on the site where
10
contamination is and where contamination has not yet reached
or where sampling is necessary to be protective of peo~le
using drinking water from bedrock wells.
Cost, this is it's present worth,
.:.:)st, we have
14
sl.lmmed all
the costs to today's dollars, would be 15.5 million
15
dollars.
16
I would like to briefly go through the other
17
alternatives.
I will"go through this overhead and the present
18
the maps that go along with each of the treatment
19
alternatives.
20
Plan number 1, the management migration number 1
21
is no action.
No action is required by the national
22
contingency plan which is the regulation under which we study
23
these sites and remediate these sites.
The no action
24
alternative was carried forward as a requirement of that as a
25
contingency plan.
APEX REPORTING
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11
If we did nothing, the MCL, the maximum
~~
contaminant levels would not be attained in over a hundred
~,
C.:ost
of monitoring under a no action alternative for
years.
4.
thirty years is estimated at $764,000.
5,
A limited action plan or management migration 2
e,
includes natural attenuation and institutional controls.
NC1w;
7
the difference between number 1 and number 2 is that number 1,
8
is we do nothing except monitor.
Number 2 is we have
9
institutional controls on the land wherever contamination is
10
above the maximum contaminant
Again, natural
level sail clwed.
11
attenuation would mean you would have the aquifer restored to
12
drinking water quality
hundred years.
i n .:.ver a
13
Cost of the monitoring, because the monitoring
14
would be increased over what we do
WC'LII d be 1.2
in n,:, ac t i c1n,
15
million dollars over a thirty year time period.
16
And then 3 is treatment of the concentrated plume
17
.:on I y.
And then 7 and 7A is treatment Of the concentrated
18
plume and treatment of a portion of the plume downstream.
19
Before I get any further, let me point out what we
20
mean by the concentrated plume.
There is an area in here
21
which we have designated a concentrated plume.
The remaining
22
portion of the contamination is considered. to be dissolved.
23
The concentrated plume and the dissolved or extended plume
24
will be treated basically in the same manner; the water will
25
be withdrawn for treatment and a discharge made to a surface
APEX REPORTING
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12
water with p6ssible recharge.
2
The main thing to understand is that in this area
3
here, the concentrations are of a significantly higher level
4
that we felt that we had to identify that area as a separate
5
area to be addressed.
6
This is a slide which is for alternative numbers 7 .
7
and 7A.
if the alternative which
And before I describe th~t,
8
I described as MM3 would only have wells pumping at location 1
9
and location 2.
That would be in the concentrated plume.
10
That would be the withdrawl points under management migration
11
number 3.
12
Alternative 7 and 7A begins the withdrawl here and
13
at four
locations, Savage Well, downstream of the Savage
other
14
Well,
The remaining part of the plume
and two wells here.
15
would be left to what would be natural attenuation purposes.
16
There were three other alternatives considered in
17
the feasibility study in the proposed plan.
The proposed plan
18
lists 9 and 9A, this would have cleanup contained in twenty to
19
eighty five years at a cost of 21 million to 16.3 million, and
20
actually the 21 million would go with the eighty five years.
21
And then 10 would have MCOs, maximum contaminant
22
levels, or the aquifer cleaned up the drinking waters and that
23
would be attained in ten to thirty years, crossed for a thirty
n
24
year period and that is 44.3 million.
25
And then 11 is the same as the preferred
~
APEX REPORTING
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13
alternative, MM11A.
The difference is in the limitation of
2
treatment.
The difference between whether an alternative has
3
an A, is that ultraviolet oxidation is added as a treatment
4
technology in place of air stripping.
When an alternative
5
does not have an A,
the treatment technology is strictly air
6
stripping.
The ultraviolet dxidation represents a cost.
7
savings as compared to air stripping for treating a portion of
8
the aquifer.
That wat~r which is more efficiently treated
9 with ultraviolet
10 costs.
11 This
12 treatment at the
oxidation thus represents a reduction in
would be alternative 9 and 9A, there would be
head of the plume for the concentrated plume
13
locations 1 and 2 shown on the map.
And then all other
14
withdrawl points would be down close to. the river.
The
15
contamination that was not captured here would have to flow
16
through the aquifer to be c~ught by these wells located here.
17
The contamination, again,
not captured by the shaded area in
18
green would be left for natural attenuation, that
19
contamination in the groundwater would not be captured and
20
treated.
21
And then 10 is the most aggressive alternative
22
that's being presented.
This represents capture and treatment
23
of wells in locations 1 and 2 and then capture at thirteen
24
other locations throughout the aquifer, the line from here to
25
there.
There would still be an area of contamination of
APEX REPORTING
Registered Professional Reporters
-------
14
groundwater which would be left for natural attenuation.
The
2
number of wells and the amount of pumping total almost
3,000
3
gallons a minute.
It means that you are withdrawing a great
4
volume of water.
A greater volume of water speeds the cleanup
5
of the aquifer.
6
I would like to end with this
one.
For those
7
of you at the last meeting, this is a much shorter
8
presentation.
9
Comparing MMI1A to the other alternatives, no
10
action is not protective of human health.
11
The limited action alternative, which was number
12
2, will not restore groundwater in a reasonable time and
13
institutional controls may be difficult to enforce over longer
14
periods of time.
15
And number 3,
it would take much longer to reach
16
MCLs.
It would not control the spread of high concentrations
17
of contamination and would cost nearly as much as MMlIA.
18
MMI1A requires less time and cost to restore the aquifer than
19
alternatives 7, 7A, 9 and 9A.
20
And then 10, which is again the most aggressive,
21
is not necessary because the alternative are expected adequate
22
to go into the near future.
23
MMllA thus represents a balanced approach that is
o
24
capturing the highest concentrations of contamination in the
25
aquifer.
over a
It is allowing natural attenuation to occur
(,
APEX REPORTING
Registered Professional Reporters
-------
pretty good portion of the aquifer.
15
And it is also being
3
concentrations of over 600 parts per billion.
protective at the end of the plume where they do have high
2
4
5 turn you
6
7
8
9
10
"
12
13
14
15
16
17
18
19
20
21
22
23
24
25
This brings to close my presentation.
back over to Dan who will allow comments.
APEX REPORTING
Registered Professional Reporters
(617)426-3077
-------
..
16
E!JQ!i~_~QIDIDgo1~
2
MR. COUr::iHL IN:
Thanks, Dick.
3
I will now read your names and
if you would come
4
to the middle and present us with your comment, please tell us
5
your name and who you represent and then provide the comment.
6
Again, we thank you very much for coming.
It's a
7
good turnout for an afternoon.
We know this is important to
8
all of you, it's important to us as well.
And I w':'Ltl d
9
encourage anybody that wishes to say something to feel
free to:.
10
stand up and say it, we do want to hear what you have to say.
11
First, Senator Charles Bass, please.
12
SENA TOF~ BASS:
Thank you very much.
13
I want to thank you for the opportunity to appear
14
here today and give us the opportunity to make comments on the
15
EPA's plan to ameliorate the Savage Well hazardous waste
16
pr,:.bl em.
17
For the record, my name is Charles Bass.
I
18
represent New Hampshire in the State Senate from District 11,
19
Milford and eighteen other towns comprise my district.
20
Obviously, the Savage Well situation
is n.:)t .:.ne
21
that is new to me.
We've been aware of this for some period
22
of ti me.
.:ame
And I guess it's time that this whole situation
23 tCI a head and was r escll ved and I'm glad that we have the
24 .::.ppor tun it y, as I said, tr=- appear here today.
25 It' s my understanding that as part elf this whcll e
()
(.'
APEX REPORTING
Registered Professional Reporters
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17
process, there are two major
events.
The first, which is what
2
we are considering here today is the proposed cleanup plan
3
which you 50 ably described
And I guess the second
to us.
4
part of this process is the discussion of the settlement of
5
the cost of paying
It's my
for this proposed cleanup.
6
understanding that that portion of the discussion will
occur
7
at a later time and it is my hope that
if the opportunity
8
presents itself, we, as members of the public,
will have an
9
opportunity to make comments for the record on the issue of
10
who should pay
I
for the cost of cleaning up this problem.
11
will only make one brief comment on that matter.
12
As far as this report is concerned,
I was frankly
13
rather pleasantly surprised that EPA didn't choose the most
14
expensive and costly alternative because I didn't see that
15
there was any particular incentive for EPA to do anything
16
differently.
I certainly think that the MMIIA proposal is
17
reasojnable.
18
However,
Your
I would make one observation.
19
report itself indicates that there really is no immediate
20
health threat from this particular spill
or this hazardous
21
waste problem.
I think it would make more
So, as a result,
22
both economically and also in terms. of planning, to
sense,
23
make a commitment on a much more limited basis for a period of
24
time, say the MM2,
for a period of time to really determine
25
what the extent of the problem was, institute the
APEX REPORTING
Registered Professional Reporters
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,~
10
institutional controls and 50 forth and then move to something
2
a little bit greater if you weren't satisfied after a period
3
of time as to how that progress was
and then move up
occurring
4
from there.
5
The plan that you have here calls for a fifteen
6
million dollar expenditure, and although there have been
7
cleanups made in the past of underground hazardous waste
8
problems, we're by no means certain that the MMI1A will do
9
what you say it will do.
more
than it needs to do
It may do
10
or it may do
less and it certainly puts an unreasonable
11
potential
economic burden on this area to achieve those
12
results.
13
As far as the proposed settlement
I
is
concerned,
14
think that your own tables indicate that
the major source, or
15
maps indicate that
the major source of this pollution is
your
16
from a bankrupt company that
And I hope
no longer exists.
17
that at the appropriate time that it would be clear that the
18
harm is divisible, that it will be possible to assess a
19
percent of responsibility to those parties involved, and limit
20
the liabilities of those parties that are involved on the
21
periphery 01 this problem to that portion that they were
22
responsible
for.
23
I'm also hopeful
that our Congressional
24
delegation,
o
our two senators and our congressmen
from this
25
area will become involved in this issue over the coming months
,
APEX REPORTING
Registered Professional Reporters
-------
1. '3
to give the EPA the benefit of their position on this because
2
this issue is of extreme significance and importance to this
3
': .:,mmLIn i t Y .
4
And I appreciate again the opportunity to speak~~
5
MF:. COUGHLIN:
Thank you very much.
6
PaLII Mer c i er,
pl'ease.
7
MF.: . MEF:C I EF.: :
and I represent
Paul Mer ': i er,
8
Hitchiner Manufacturing.
9
I have a question that I would like put into the
10
pLlb Ii,:
is, since the TCA, whid1 is the 1,1,1
r e,: ,:,r d
and that
11
trichloroethane at the Savage Well is within drinking water
12
limits, would the TCA contamination at the well have closed
13
the Savage Well back in
1 '383'7-'
14
Th an k y':'LI.
15
MF.~ . COUGHL IN:
Dick, do you have any question on
16
his questi,:.n?
17
I just wanted to make sure that we understand .what
18
quest i .:,n
was.
y,:,ur
19
MF:. GOEHLEF:T:
Paul, do you mean at the Savage
20
Well?
21
MR. MERCIEF::
Well, the Savage Well was closed
22
down in 1383 because contamination was high.
Sin,:e the TCA
23
portion was within drinking water standards,
and back in 1983
24
by the way, those standards were 1,000 ppb, they're still
25
within drinking water standards at the current 200 ppb; would
APEX REPORTING
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20
the Savage Well
have been closed down because of TCA
2
contamination.
3
MR. GOEHLERT:
If it was just TCA alone?
4
MR. MERCIER:
Correct.
5
MR. COUGHLIN:
we understand the
All right,
6
question.
I just wanted to make sure that we knew what it
7
was.
8
Just let me explain that comment.
It is a public
9
hearing and we're taking comment
here and we're not here to
'0
information back and forth.
I don't want to seem
swap
So,
'1
that
I want that
I don't want to answer questions here.
12
understood.
respond to these questions in the
We will
13
administrative record which is part of the Record Of Decision:
14
Thank you, Paul.
15
Linda Rychwa.
16
MS. RYCHWA:
Hi.
17
I'm also a Milford resident
for over twenty years.
18
And I'm also a Hitchiner employee.
And I would like a
19
question for
record, also.
20
I would like to know why the EPA hasn't considered
21
an option that would place a treatment at the Savage Well t~at
22
would allow the town of Milford to drink the water from the
23
well.
24
Also,
o
under the EPA's goal, the goal
is to allow
25
the town to drink the watei safely sometime in the future, why
'0
APEX REPORTING
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:1
not now~
The water will be just as clean
coming
from the
2
treatment plant
now
as it will
in thirty or sixty years,
3
whatever EPA is proposing.
Why wait and waste all the water
4
and dump it
into the ground or the river?
5
Thank you.
6
(Applause)
7
MR. COUGHLIN:
you.
Thank
8
Dennis Patschke.
9
MR. PATSCHKE:
my name is Dennis Patschke.
Yes,
10
I work at Hendrix.
I haven't moved into
Although
11
Milford yet,
and I was considering being a
I'm working on it
12
small
But all this is kind
business operator
in the future.
13
of on
hold because it's to my experience that when the main
14
bread winning industry of the local community is taken
away,
15
the ripple affect
I've already gone through
is so profound.
16
this in the steel industry of Pennsylvania where the town went
17
literally bankrupt, social
services, medical services that
16
were lost, vocational schools were lost and it was all because
19
there couldn't have been a reasonable compromise with the
20
industry at the time.
And it looks to me like almost the same
21
thing is happening again here.
And it seems like a clean
22
Savage Well is not much compensation when half the town's
23
population can no longer thrive there and the next generation
24
moves on.
25
. Thank you.
APEX REPORTING
Registered Professional Reporters
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8
9
10
11
.
12
13
14
. .
(Applause)
2
MR. COUGHLIN:
Thank you.
3
Greg Babich.
4
MR. BABICH:
My name is Greg Babich.
5
I'm also an employee at Hitchiner and a resident
6
of Amherst.
7
I have a couple of questions h~re to bring up that
are related, with some comments to follow.
It was said in the meeting, the last public
meeting,
that EPA used nine criteria for establishing and
selecting a remedial action.
80 two questions in regard to
that, of the criteria, one of the nine criteria that Congress
established for selecting remedial action requires that the
state accept the EPA's proposed alternative and also that
15
another of the criteria requires. that acceptance of the EPA
16
remedy be also by the community, which is the Milford area.
17
80, two questions that I have are, will the EPA
18
modify its proposed remedy to obtain state acceptance and will
19
the EPA modify its remedy to obtain community acceptance in
20
the Milford area.
That was not addressed in the proposal at
21
the public meeting.
And there were some concerns brought up
22
the state at that meeting that were not addressed by the EPA
23
concerning the impact on state lands where the corn fields are
"
24
and also the state fish hatchery.
concerns were brought
Also,
25
up by the community in regards to use of the water for
<,
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drinking water which at this time is not an immediate need for
2
the .:.:.mmunity.
3
It seemed to be the EPA's stance that
thei r .:.ne
4
and only assumption and objective was to make the water whol~
5
for drinking purposes.
6
These two issues are very important considering
7
the, and given the power that the EPA holds in making
a
environmental decisions such as this on
the .:leanLlp.
!~
And I just wanted to make a comment that the
1()
environmental impact
just concern clean water, corn
de.es n.:.t
1"1
fields and fish, but also the environmental
impal:t is c.n all
1;!
.:. f Ll S ,
all of us as part of the environment as part of this
1:1
': .:.mmLIn i t Y ,
OLlr 1 i ves and
in this town and this state.
14
livelihood, quality of
businesses is all
1 i fe,
i mpa.: t
.:.n 1.:,,: al
15
really hinging on what
.:c.mes
out of this total decision.
16
We are now at a point now where two of the four
1i'
PRPs that are left as being viable aI's both companies that
1tl
were b.:.rn
and raised in New Hampshire and in this area,
19
neither one of which caused this problem, neither did the town
20
of Milford cause this problem.
in my
So, it would be unfair,
21
judgment,
for the EPA to propose that the two remaining PRPs
22
be held responsible for this cleanup, particularly given the
23
fact that there's no certainty
for the success of the proposed
24
method of the clean up.
25
I would strongly urge that the EPA work closely
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24
with the community and the PRPs that still exist,
in ,:(:,mi ng '-'p
2
with a reasonable alternative that will address all the
3
environmental impacts within the community, within the people
4
of the community,
itself.
along with the natural environment
5
Thank
y':lll.
6
MR. COUGHLIN:
Thank YClll.
7
Charles Hayward, please.
8
MR. HAYWARD:
I would like to stand here because
9
it's hard
for me to get around.
10
I'm not
you how to do it
going to be here to tell
11
c,r what t,:, d,:,.
is do it and do something.
What I'm saying
12
Last
year,
I had my 140 acre farm sold and by the laws of the
13
EPA,
I sold it to could be made to help clean it up.
wh.:,ever
14
N':lw,
I can't sell it and I can't do anything with it until
15
something happens.
16
I think maybe it's so that somebody ~ould release
17
that farm or at least my 140 acres so I
sc.mething with
': an d,:.
18
it and not come back on somebody
I think it's
I sell
it tCI.
19
terrible that they can come back on something that I tried to
20
do with it and sell and get
I ,:,wn it and
some money out of it,
21
I can't do a thing with it.
nc,b,:.dy el se
I ': an ' t far m it,
22
wants to farm it.
If I sell it, then the EPA says if you sell
23
it to them, they can be held liable for it or part of it.
24
Then the banks closed up and wouldn't lend them money and I
25
can understand that.
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And all
I'm asking
is, somewhere along the line
2
and soon,
I hope that somebody will
get a release 50 we can do
~
something.
4
(Applause)
5
MR. COUGHLIN:
you.
Thank
6
Avis Rosenfield.'
7
MS. ROSENFIELD:
My name is Avis Rosenfield.
8
I represent Hitchiner Manufacturing.
9
I'm not a resident of Milford with the exception,
10
however, of
being an employee at Hitchiner and
for the
looking
11
future of my life being at Hitchiner.
I would like to see
12
Hitchiner and other companies in this area prosper.
And I
13
don't see how that's going to happen if there is not an
14
expedient resolution to this matter,
just as the previous
15
gentleman stated.
16
Other than bein~ politically expedient, what is
17
the engineering justification for the two wells at the very
18
dilute ~nd of the plume?
That would be my first question.
19
Additionally,
even a nontechnical person can see
20
that these wells will be pumping such dilute amounts of PCE
21
that nothing significant would be captured.
That's a r~ther
22
large expense without much benefit.
I would like to know,
23
again, what would be your justification for doing that?
24
Seeing that in the past there have been a number
25
of Superfund sites across the United States, what have been
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. 13
:5
your successes as of
late?
Have they been bio, have they
been
2
strippers, have they been in situ situations?
What have they
3
been and what technology do you consider current and would you
4
be imposing something or
would you be working with companies
5
to make sure that it is current technology and reasonable?
6
Thank
you.
7
MR. COUGHLIN:
Thank you.
8
David Godbout.
9
MR. GODBOUT:
I'm David Godbout from Hitchiner
10
Manufacturing.
11
I have a question.
If, as it seems apparent, the
12
EPA is unilaterally going to decide what the remedial
action
is going to be, why won't you discuss who is going to be
14
ordered to pay for it?
15
Thank you.
16
MR. COUGHLIN:
Thank you.
17
Leon Stillwagon.
18
MR. STILLWAGON:
Yes,
I'm. Leon Stillwagon.
19
I'm an employee of Hitchiner Manufacturing and a
20
resident of Amherst for fifteen years.
21
I would like to make a comment
first, and then I
22
have a couple of questions about PRPs.
It's a great
23
abbreviation.
It could stand for Positively Responsible
24
Party.
~
It could stand for Probable Responsible Party.
It
c
25
could stand for and does, ~otential Responsible Party.
~
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My questions are in line with that.
My first
2
question is, what information does the EPA have ~oncerning the
3
hazardous waste practices of the dozens of other companies and
4
individuals located at
the site who could have contributed to~
5
the contamination?
potentially
We fbcused
in on four
6
responsible parties and made a lot of that.
But these
7
contaminants are very common chemicals that
are used
8
throughout many industries and many businesses.
I would like
9
to know who the other PRPs might be?
Why hasn't the EPA
10
pursued any of these other PRPs?
And,
does the EPA intend to
11
name any of these additional PRPs that I've asked for?
12
Thank
you.
13
MR. COUGHLIN:
Thank you.
14
Steve Checkoway.
15
MR. CHECKOWAY:
My name is Steve Checkoway.
16
I'm a Hitchiner employee and a Milford resident~
17
I just have a couple of quick questions for the
18
record.
Why hasn't the EPA adopted a phased approach to
19
installing the treatment wells?
And, will the EPA in the
20
future consider a phased approach?
21
Thank you.
22
MR. COUGHLIN:
you.
Thank
23
Jim Hendrix, please.
24
MR. HENDRIX:
My name is Jim Hendrix.
25
I'm a resident of Amherst for all my thirty three
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10
11
.
12
13
14
15
16
17
18
19
20
21
22
23
24
:8
years.
2
I would just like to,
I don't know if you people
3
are the decision makers that sit before us, but I would like
4
the decision makers on the financial responsibility for the
5
cleanup to just think for a minute about,
you
know,
I'm going
6
to assume that you all have families and,
you live
you know,
7
in a nice home and a nice community and a nice town
somewhere
8
in
I would like you to just think for a minute about
America.
9
the EPA
in and making a decision what we, as laypeople,
coming
believe is very unfair in
making a decision to financially
wipe your community, your
home,
your ability to make a living
and your way of
life, just wipe it economically and
financially off the map.
I would just like you to keep that
in mind.
Thank you.
(Applause)
MR. COUGHLIN:
Thank you.
Frederick Lofgren.
MR. LOFGREN:
I'm Frederick Lofgren.
I'm the Chief Financial Officer for Hitchiner
Manufacturing Company.
I have a few comments to make.
And being a
financial
person,
I'm sensitive to Mr. Goehlert's reduced
v
budgets, so I will also give you a transcript of what I'm
25
about to say.
But I think it's something that everybody ought
q
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1.
:::'3
to have an opportunity to hear.
2
Hitchiner Manufacturing Company wants it
t c, be a
3
matter of public record that first,
Hitchiner is not
4
responsible for the tetrachloroethylene, or PCE,
': ,:,nt ami nat i ,:,n
5
which is emanating from the OK Tool Company site and which is
6
the principal cause of the contamination of the Savage Well
7
aquifer.
Hitchiner has never used PCE in its production
8
process and, as everyone knows, PCE is a carcinogen.
9
Hitchiner is prepared to construct and operate a
10
well and treatment plant at the Hitchiner
facility to clean up
11
the relatively small area of concentrated
12
1,1,1-trichloroethane,
or TCA, which is adjacent to the
13
Hitchiner plant.
14
The small
n,:,t ': aLlse
am':'Lln t c. f
TCA at the site did
15
the closing of the Savage Well.
And even t'~day, as
16
Mr. Mercier pointed out, the concentrations of TCA in the
17
Savage Well are well below current dri~king water standards.
18
TeA is nc.t
a carcin,:,gen.
19
Hitchiner generally supports the proposed remed~
20
for the site which the EPA has selected, although we have some
21
technical and some phasing concerns which we will -- ~hich
22
will be addressed in a written technical brief sometime before
23
the August 10th deadline.
24
Hitchiner insists that the issue of fairness in
25
deciding who's going to pay for the cleanup is as important or
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perhaps
than just how it's going to be
even more so
done.
2
The well
and aquifer problem was caused by OK
Tool
3
Company.
OK Tool Company should bear the major share of the
4
cost.
Tool
Since
the EPA has allowed the assets of the OK
5
Company to be disbursed to its past and present owners,
6
fairness dictates that Superfund monies should be used to pay
7
for OK Tool's share of the costs that can not be recovered
8
from OK Tool Company.
9
Four local
Hitchiner, Hendrix Wire and
companies,
10
Cable,
New England Steel Fabricators and ourselves, originally
11
agreed
a study of the Savage Well site and share
to conduct
12
the cost equally.
cause
It was obvious in
1985 that a primary
13
of the contamination at the site was the handling of PCE at OK
14
Tool Company.
Nevertheless, the four companies agreed to
15
conduct the study to determine the extent of the problem and
16
what should be done to deal with it.
17
Hitchiner joined in the effort to study the site
18
and working closely with the EPA as required by the Superfund
19
law and we did this because we believed that it was the fair
20
and reasonable thing to do as responsible members of our
21
community.
That study has be~n completed and you've given
22
some of the results here.
It has confirmed what we knew all
23
along,
source of the contamination which
that the principal
~
24
closed the well and which will require remediation at the site
25
came from OK Tool.
OK Tool
And yet, as the study progressed,
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A
31
Company sold its business, closed its Milford plant, stopped
2'
paying its share of the investigation
costs
and was allowed to
3
distribute the profits from the sale of the company to its
4
former owners.
To complete the study, Hitchiner paid OK Too~.
5
Company's share.
6
In early 1990, New England Steel Fabricator~ filed
7
for bankruptcy protection and has gone out of business.
The
8
investigation was completed by Hitchiner and Hendrix.
9
The study also disclosed that there is a
10
relatively small
area of TCA contamination adjacent to the
11
Hitchiner plant.
It's important to understand that the
12
concentration of
TCA in the groundwater outside of the
13
Hitchiner property, or a very short distance from it,
is below
14
the cleanup standards which the EPA will be working to.
15
In other
is a
words,
the only area whereTCA
16
problem and requires remediation is adjacent to the Hitchiner'
17
plant itself.
weeks ago to
Hitchiner publicly offered several
18
bear 100 percent of the costs of remediating this area of TCA
19
contamination.
20
And I again,
I would like to say that Hitchiner
21
generally supports the EPA's proposed remedy at the si~e~
,But
22
I would like to mention a few technical
concerns in
that
23
regard.
24
While there's a growing national debate as to
25
whether the methods currently used for remediating Superfund
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sites are working,
there is general agreement that the most
2
concentrated areas of contamination
should be and can be
3
contained.
But perhaps they can not be cleaned up to drinking
4
water standards.
Both the EPA's remedy and Hitchiner's
5
proposal provide
and treatment of the
for containment
6
extracted groundwater at the OK Tool plant and in the TCA area
7
adjacent to Hitchiner.
8
The EPA proposed plan, despite being more
9
expensive than is necessary,
will not under any circumstances
10
provide a water supply for the town of Milford in the
11
foreseeable future.
an enormous amount of
In other
words,
12
money is going to be spent
to reduce the contamination in the
13
aquifer simply to do it in a shorter period of time with no
14
water from the site being available to the town.
15
The Hitchiner/Hendrix proposal
calls for
16
implementing containment at the OK Tool and Hitchiner
17
locations.
All the technical evidence strongly suggest that
18
additional
steps out in the middle of. the aquifer and at the
19
eastern end of the aquifer ought to be deferred or phased so
20
that it can be determined whether containment at the western
21
end of the plume is effective.
If it's not effective, it
22
significantly alters what can be done at the eastern end of
23
the plume in the foreseeable future.
24
It's becoming more and more common around the
25
country for Superfund remedies to be selected and imposed
on a
~
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11
: .
12
~~
~~
site only to find within a relatively short period of time
2
that they are ineffectiv~ and something else needs to be done.
3
We do not
believe that this community can afford to spend huge
4
sums of money at the site, especially in the face of growing
5
evidence that Superfund remedies that seem like a
idea on
good
6
paper do not work when they are built in the field.
7
For this simple reason, Hitchiner strongly
8
believes that the remedy at this site should be phased.
If,
9
after containment
is achieved and a period of time of
monitoring the site has demonstrated its effectiveness,
Hitchiner believes that EPA should then proceed to install
wells in the middle portion of the plume to capture and remove
13
contamination between the containment area and the midpoint of
14
the plume.
15
Hitchiner has proposed, along with Hendrix, to pay
16
for and operate one of those large mid plume wells located at
17
the Savage Well.
we have
Since making our proposal in May,
18
heard the town's concerns as th.y were expressed at the
19
July 11th meeting that the treatment plant at the Savage Well
20
could produce usable water, at least
for emergency backup
21
purposes and could be easily connected to the town water
22
system.
23
Hitchiner is quite willing to explore that
option
24
to the extent it is practicable to
if the
do so.
In fact,
25
town wishes to pursue that option,
Hitchiner, after the
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34
treatment plant is built at the Savage Well site,
is willing
2
to give the Savage Well
to the
property, which it now owns,
3
town, or
only to
to lease it to the town at no cost,
subject
4
whatever technical
limitations the government may
and legal
5
impose upon us.
6
In connection
with this modification of our.
7
earlier offer,
actually as part of our earlier offer,
8
Hitchiner would be willing to increase the pumping rate of the
9
Savage Well, which would include treatment at the well head,
10
from 300 to
That's an amount which
500 gallons per minute.
11
would equal the earlier output of the well to the municipal
12
public water supply system.
13
In another matter, EPA has proposed two small 50
14
gallon per minute wells to be located at the far easterly end
15
of the plume.
have environmental engineering
While we will
16
consultants make some formal
I simply want
comments on this,
17
to point out that those wells add cost for virtually no
18
benefit at the site.
The level of contamination in the water
19
at that point in the point is near to the cleanup level and is
20
at the lower limit of detection capability.
Pumping 100
21
gallons per minute of water for an indefinite period of'time
22
would simply mean that significant amounts of water would be
23
spent to pump enormous quantities of water while attempting to
24
remove nearly undetectable amounts of contamination.
The
25
levels are so low in this part of the aquifer that as the
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water discharges to the river,
the level of contamination
2
becomes truly nondetectable.
We think the wells are simply
3
not required.
4
The EPA proposal, unlike Hitchiner's proposal,
.
5
calls for a second mid plume well, which would be located
6
somewhere
The PCE
in the vicinity of the Savage Well.
7
contamination emanating from OK Tool
Company is the basis, no
8
doubt,
for EPA proposing this second well.
And it is as plain
9
as it can be that the liability for the cost of that well
10
should be imposed on OK Tool Company.
11
If EPA,
does not succeed in
for whatever reason,
12
compelling OK Tool to pay for
the contamination at its own
13
property and for treatment in the mid plume area, then EPA
14
should use the Superfund, which was created for this purpose,
15
to pay for this second mid plume well as well as all of the
16
costs at
the OK Tool Company.
17
If the EPA continues to believe that the two wells
18
located at the end of the plume serve any useful
purpose, then
19
it should require that OK Tool Company or the Superfund defray
20.
the cost of those wells, too.
most of the
In fact,
21
contamination down there, if not all of it is PCE anyway,
22
which Hitchiner never used.
23
In summary, Hitchiner has always felt that it has
24
a responsibility to this community.
it's
And in this case,
25
taken the lead in trying to deal with the problem which it did
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-:..c::,
no:.t 0: ause.
\ /
2
To the argument that Superfund rules of
:-0 0: all ed
3
joint and several liability should be applied in a
4
deva:-tatingly
Hito:hiner and
harsh fashion by EPA to compel
5
Hendrix to pay for the problem caused by OK Tool,
I would
6
offer just this brief, unlegal
r espc.nse.
The .:entl.lry 01 d
7
principle of joint and several
liability was applied to
8
situations where several parties are involved in an accident
9
injury and it's impossible to determine the relative
or an
10
share of the responsibility.
almost picture i-f four
YO:'l.1 can
11
cars come together at
an intersection without anybody being
12
able to determine why they met in the middle, this is the kind
13
of situation that's required to be used.
when YO:'l.l
Ho:.wever ,
14
are able to divide the responsibility, you must
At the
d.:. so.
15
Savage Well
To.:. I
site, nothing could be clearer than that OK
16
Company caused the PCE releases that closed the Savage Well.
17
In light of that fact,
it would be grossly unfair
18
and contrary to the law to try and impose on Hitchiner and
19
Hendrix liability for contamination at this site that they
20
clearly did not cause.
The offer made by these two companies
21
to pay all of the costs of the containment well
at the
22
Hitchiner property and all
of the costs of the treatment
23
facility at the Savage Well
far exceeds what their legal
"
24
liability could possibly be at this site.
25
Hitchiner and Hendrix did not cause the problem
,
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~i
requiring remediation of the Savage Well and the surrounding
2
aquifer.
That problem was clearly caused by OK Tool Company.
3
Nevertheless, Hitchiner continues to be prepared to put its
4
community responsibilities ahead of other,
more narrow
5
interests and it has always hoped that the other potentially
6
responsible companies would do the same.
7
Since I can see Mr. Coughlin watching his watch,
8
I'll just wrap up.
9
As you can see from my remarks, we're offering
10
general support for EPA's approach at this site.
We've worked
11
closely with the EPA over the last several years as the
12
Superfund process contemplated private companies would do.
13
And there haven't been any more cooperative companies,
I
14
think, than you could find with Hitchiner and Hendrix.
We
15
stand ready to continue to do more than should be strictly
16
required of Hitchiner, to pay more than its fair share and to.
17
work with EPA towards the end of cleaning up the aquifer.
18
As we've said before, however, it would be unfair
19
to attempt to impose a grossly disproportionate share of the
20
cost, of the liability at this site on Hitchiner
21
Manufacturing.
And we will resist by all means available t~
22
us.
23
We will submit specific comments on items I've
24
outlined today before the public comment period
We
closes.
25
urge EPA to deal with the only real issue which separates us,
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38
mixed funding.
EPA should determine, consistent with the
2
mandate of Congress, as expressed in Section 122 of the
\/
3
Superfund law, that if it can not
Company to
compel OK Tool
4
pay its fair share at this site, the Superfund must be used to
5
pay for OK Tool's share of the remedy.
6
Thank
you.
7
(Applause)
8
MR. COUGHLIN:
Thank you.
9
Lee Mayhew.
10
MR. MAYHEW:
We are also forwarding a copy of this
11
letter to your office so you will have it for your files.
12
Writer's correspondence to the Board of Selectmen
13
formally notifies the Regional Office of criteria acceptable
14
to the town of Milford, and that the town, as former owner of
15
the subject well,
formally and officially requests to be a
16
party to the resolution,
remedy, negotiation process.
17
The position of the current and pa~t Boards of
18
Selectman has been that any solution to the Savage Well
issue
19
must be balanced and cause no harm to the town, its taxpayer~
20
and its tax base.
Additionally, the solution must pose no
21
threat to the viability, marketability and financial soundn~ss
22
of Hitchiner Manufacturing Company, Hendrix Wire and Cable and
23
other parties.
24
As you are aware, there are only two functioning
25
companies left of the original potentially responsible
"
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33
parties, those being Hitchiner and Hendrix.
As such,
it i:
2
even more imperative that
any remediating program be one which
3
is fair and proportionate to the alleged involvement and
~
impact
Where there is
of the companies upon
the Savage Well.
5
proven
responsibility for contamination, there must be a
6
apportionment of costs.
Where there is responsibility
proper
7
but no apparent source of funds
agency or
for remediation,
8
Superfund monies must
A so called deep pocket
be committed.
9
solution shall not be acceptable.
10
The only solution acceptable to the citizens of
11
Milford and its Board of Selectmen is one which is impeccably
12
and holistically fair to all members of the community.
13
As has been mentioned in prior correspondence, the
14
Board of
Selectmen is aware that there will be discussion and
15
concerns
over the Savage Well and this aquifer as a water
16
We are also cognizant that circular places a high
source.
17
priority on a principal drinking water supply which has become
18
contaminated.
we would be remiss if we did not
However,
19
remind EPA that the Savage Well site is not currently used as
20
a drinking water source.
The property is not owned by the
21
town, having been sold to Hitchiner Manufacturing Company with
22
the approval
town meeting.
of the voters at a special
23
In addition, adequate water supplies are currently
24
available to replace the supply formerly provided by the
25
Savage Well.
New Hampshire regulations may proscribe future
APEX REPORTING
Registered Piofessional Reporters
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40
use of the aquifer as a municipal supply because the current
2
and foreseeable future use of the land that
is contributory to
3
the aquifer includes incompatible uses such as agriculture,
4
': ommer ': i al and
Therefore, remediatio~.
industrial operations.
5
of the aquifer to high human health criteria may not be
6
apprc'pr i ate.
7
F"urther
we will present
in this correspondence,
8
data regarding the availability of water supplies which we
9
believe the agency has not given sufficient and credible
10
"r"eview t.:, in
fashioning a fair and mitigated proposed
11
settlement.
12
We must p,:,i nt
this time, as we have in the
,:,ut at
13
past, how difficult it is for us and other interest groups to
14
give a comprehensive and thorough review to the agency's plans
15
when
is wi thhel d fr.:.m the muni.: i pal i ty and
so much information
16
the general public.
to receive comments as
The reqLlirement
17
they relate to community acceptance can not be properly served
18
without a complete release of information as to allocation
19
process and parameters, decision making rules, authority and
20
eligibility for use of federal
Wi thc'Llt thi s
Superfund monies.
21
data, we are assuming that the agency could decide its course
22
of action without taking all
We
factors into consideration.
23
have not been able to obtain any information to dispel I this
24
c ,:,ncer n.
25
We are concerned with the potential
fc.r major
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p
~1
e,: ,:,n ,:,m i ':
and financial impact to the town without ~ balanced
2
sol LIt i c,n.
In the remaining and functioning companies, we have
3
al m':lst
1 i vel i h,:,,:.d
1300 employees who face the loss of their
4
should a balanced solution not
Of these 1300
be devel c.ped.
5
employees, over 200 are resident~ of the town of Milford.
If
6
these people become unemployed due to the financial
failLlre ,:,f
7
the companies, vis a vis a Savage Well
s,:.luti,:,n, the
8
hClr I" end':ILIS
impact is spread across the entire town.
9
The welfare budget, which all have been aghast at
10
as it has
increased this past year, would be increased again
11
by a minimum estimate of $180,000 for services.
The tc,wn will
12
SLI f fer
real estate
an estimate, worst case scenario, loss of
13
tax of $818,846, and we would note that the balance of the
14
taxpayers of the town of Milford would have to assume this
15
lost tax burden.
16
The only alternative to this assumption would be
17
the reduction of services.
The town of Milford and the school
18
department have been operating on relatively tight,
relatively
19
flat budgets over the last year or ye~r and a half.
20
In 1985, after the Savage Well
frclm
wa s I" em,:,ved
21
our system's capacity, the towM's analysis of Milford's
22
average daily pumping demand versus our total capacity,
23
without the Curtiss Well, number one, would fall short of
24
meeting the state's standards by approximately twenty seven
25
per.:ent.
APE X F.:EPOPT I NG
Pegistered Professional Reporters
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42
As a result of this, the town of Milford and the
2
State Water
other long term
Supply Division
looked at
3
alternatives for the town.
The State advised the town that
4
long term alternatives for supplying water to Milford were
5
very limited and serious consideration should be given
to out
6
of town alternatives.
Four options were identified by the
7
State, the most viable being construction of a water main arid
8
booster pump station to connect Milford's water system to the
9
Penechuck Water Works.
As such, State officials steered the
10
town in this direction of
finding a safer and more reliable
11
source of drinking water.
This was accomplished in June of
12
'87 with the Penechuck Water Works.
This agreement offers the
13
town of
Milford up to two million gallons of water a day.
14
It is important to note that
our decision was
15
based on
source
reliability, water quality, ability to
cost,
16
meet long term demand requirements, ability to implement th~
17
complexity and safety of the operation of the system.
The
18
ability to flexibly meet long term quantity and quality was
19
and is a key
The Penechuck agreement assures the town
factor.
20
that a safe, portable water source is available for several
21
years.
22
On numerous occasions most recently outlined in
23
the agency's proposed plan and dated July of 1991, the EPA has
24
alluded to the fact that Milford's current water supplies are
25
adequate for the near
future or the short term.
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o
4~
In addition, the EPA goal of restoring the Savage
2
Well to drinking water standards and making it available as a
3
future water supply has always also been stated.
The purpose
4
of the
following discussion is to document that Milford's
5
existing water supplies are not only adequate for the near
6
future, but will last well into the next century.
7
Since EPA advocates the use of worse case
8
scenarios,
the following analysis assumes that Milford's
9
population will expand at an annual growth rate of 3.1 percent
10
over a fifty year period.
This rate of growth reflects the
11
population expansion that
1980s, the
occurred during the
12
largest growth period in the state's history.
13
Today,
Milford has the ability to obtain 4.25
14
million gallons of water
from
a day.
This supply is obtained
15
the community's existing wells and reflects the maximum
16
capacity available from the existing Penechuck water line.
In
17
~rojections of future water
use, the current ratio of gallons
18
to people in 1990 was kept constant throughout the projection,
19
table l(a) which will be in the documents we provide you,
20
outlines a fifty year scenario and demonstrates that Milford's
21
current water supplies are more than adequate through .the year
22
2037.
The above analysis is useful in demonstrating that
23
Milford's water supply is more than sufficient even under the
24
worst case scenarios.
25
But, eventually the reality of real world events
APEX REPORTING
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44
must enter into this discussion.
The use of
an occurrence of
2
a sustained growth of 3.1 percent
over a
fifty year period is
3
absurd.
The fact that New Hampshire has currently experienced
4
one of the worst
further,~
recessions ever to visit
the state,
5
acknowledge that this type of growth will
never occur.
It is
6
also
important to note that over the past decade, when Milfbrd
7
grew at such an unprecedented rate, the community's a~erage
8
daily water use fluctuated a mere 40,000 gallons a day over
9
that ten year period.
10
It must also be pointed out that another well
11
could be located in the Curtiss Well
field with a capacity of
12
700 gallons per minute.
This would provide an additional
13
672,000 gallons of water a day.
In fact, the U.S.G.S. of this
14
portion of
the aquifer indicates a potential yield of an
15
additional
In addition,
six million gallons of water per day.
16
Penechuck Water Works currently has an eleven million gallon a
17
day reserve capacity along with another million gallons a day,
18
we will soon be obtaining from an groundwater source in
19
Amherst.
20
It is clear from the evidence presented that
21
Milford not only has adequate water supplies to serve -our
22
needs to the year 2037, but well beyond.
It may well be the
23
goal of EPA to restore the Savage Well to drinking water
24
standards, but the timing of this cleanup
process
should not
25
be hastened in order to supply our community with additional
APEX REPORTING
Registered Professional Reporters
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45
~ater.
This fact is of particular importance when
discussing
2
the migration management
alternative that is proposed.
And we
3
should do an analysis of the time, the cost and everything
4
over the phased approach.
5
It is therefore incumbent upon the EPA to ~eigh
6
the fact that Milford does nQt need the Savage Well at this
7
time and should temper any final action with this in mind; the
8
economic
viability of our community rests upon it.
9
The town of Milford and its Board of Selectmen
10
wants EPA to recog~ize our deep
concern
in fashioning a cost
11
effective and reasonable remedy for the Savage Well site as
12
required by EPA's own regulations.
13
We are aware that two of the PRPs, Hitchiner
14
Manufacturing Company and Hendrix Wire and Cable are prepared
15
to pay for a significant portion of the cleanup, even though
16
the most contaminated area is not on their property.
We
17
believe that it would be wrong and not in the spirit of
18
current
legislation to expect them to pay for the entire
19
remediation but rather, Superfund monies must be used
to cover
20
costs of
respl~nsibility and what
the aforementioned companies'
21
they are prepared to commit to.
22
Milford has always dealt with its problems in a
23
cooperative and reasonable manner.
This community and its
24
members have not shirked responsibility and we are not doing
25
so at this time.
We do insist on fairness and that the agency
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understands the needs of the community as a whole and
do not
2
proceed with a functionally myopic solution.
This is a
3
community issue and we wish to deal with it
manner.
in that
4
It would be a crime to damage
resources
our community
and our
5
with an unworkable solution.
6
Thank you.
7
(Applause)
8
MR. COUGHLIN:
Thank you.
9
Scott Higgins.
10
MR. HIGGINS:
I'm Scott Higgins.
11
I'm a resident of Milford and an employee at
12
Hendrix.
13
I want to touch base on a couple things.
14
Reviewing the proposal
that you set forth, talked about DNAPLs
15
and, out
text, PCE, TCA may exist below the water
of your
16
table as DNAPLs.
easily
Because current technology can not
17
locate free phase DNAPLs,
the existence is based on
18
circumstantial
evidence and the amount of DNAPLs is not
19
possible to be determined.
If pockets of free phase DNAPLs
20
are slowly dissolving and contaminating surrounding
21
groundwater, then they will continue to be a long term source
22
of contamination.
23
It also says EPA estimates that groundwater would
24
be restored drinking water standards in l~ss than thirty years
25
if no free phase DNAPLs exist.
If free phase DNAPLs exist,
':
APEX REPORTING
Registered Professional Reporters
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4~
drinking water standards might not be met within the
2
foreseeable future for reasons of technological
3
impractibility.
into it, on the concentrated
Then you go back
4
plume,
the EPA has not determined that free phase DNAPLs exist
5
in the plume or, that it is technically impractical.
Back and
6
forth,
one.
two different ways, it can only be
7
On the costs,
that
you said in the last
session
8
the costs were
figured to have a measurement error of minus
9
30, plus 50 based on thirty years.
just be talking
We may not
10
thirty years,
And if .DNAPLs
we may be talking a
lot longer.
11
do exist, the costs will continue to the two viable parties
12
left for the next hundred year~ or more.
13
Faster is not better especially if DNAPLs exist.
14
Talking about PRPs out of your proposal, NHDAS,
15
inspection of OK Tool
plant found a degreasing tank had been
16
directly connected to a drain in the plant floor.
Later on,
17
groundwater flows eastward from the OK Tool building.
The
18
remaining principal PRPs, Nesfab isn't
even
in the plume, yet
19
it gets named as a PRP.
The
I'm looking for the fairness.
20
analogy I put down here is my neighbor murders his wife and
21
then commits suicide, under my understanding of what the EPA
22
has put out as a PRP,
I am responsible and I have t6 pay.
23
That's what I see out of it.
24
Thank
you.
25
(Applause)
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48
MP. COUl3HL IN:
Thank
you.
2
MauY"een Paiche.
3
MS. PAICHE:
I'm MauY"een Paiche.
4
I'm an attoY"ney heY"e repY"Esenting OK Tool,
In,:. ~s
5
it e~dsts t.:.day.
I have a bY"ief statement to make.
6
The contamination of the Savage Well was
7
d i 5': oveY" ed
Since that time, the entiY"e Savage Well
i n 1 '383 .
8
site including the manufactuY"ing operations of all companies
9
in the vicinity have been undeY" the caY"eful
watch and contY"ol
10
of the New HampshiY"e DepaY"tment
of EnviY"onmental SeY"vices and
11
the EPA.
12
In the eaY"ly to mid '80's the oY"iginal owneY"s of
13
OK T.:,,:,l
companies including OK
began looking to sell
seveY"al
14
T,:,,:,l .
The foY"meY" owners made the puY"chase of OK Tool the
15
Y"equiY"ement of any deal.
The cuY"Y"ent owneY" of OK Tool
16
puY"chased it in September of 1987, some fouY" yeaY"s afteY" the
17
contamination was discoveY"ed.
18
HoweveY", at the time of the sale the only
19
disclosure made was that there weY"e allegations that
a mi nc,r
20
contamination pY"oblem may exist at the site and that
Llpc'n
21
further examination, the company would be cleared.
On t h':,se
22
Y" epr esentat i c,ns,
the cuY"rent owner bought OK Tool and the
23
.::tther .:.::tmpany.
24
At the time of the purchase, the plan was to shut
25
d'Jwn OK T.:,,:,l
because it was not profitable and was unable to
APEX PEF'ORTING
Pegistered PY"ofessional Reporters
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v
~
4'3
employ any significant number of Milford residents.
The
2
operations of OK Tool
Williams &
ceased in July of
1987.
3
Hussey,
a division of OK Tool, was sold in December of 1987
4
and the manufacturing operations ceased there in February of
5
1988.
6
The new owner sold the product line and
7
manufacturing equipment to outside interests.
A significant
8
portion of the monies
from the sale, almost $300,000, was
9
given to the group of potentially responsible parties
10
including Hitchiner, Hendrix and New England Steel Fabricators
11
to cover OK Tool's share and
the EPA remedial investigation
12
and feasibility study.
The balance of the money was used to
13
maintain the building as well as to support engineering arid
14
legal
At the current time, the only asset
costs at the site.
15
of OK Tool
is the land and building on Elm Street here in
16
Milfc.rd.
17
From the studies at the site, it appears that
18
prior
manufacturing operations and waste management practices
19
of OK Tool may have contributed to the contamination of the
20
Savage Well aquifer.
The same studies establish that the
21
manufacturing operations and waste management practic~s of
22
Hitchiner and Hendrix also contributed to the contamination.
23
To the extent that OK Tool contributed to the contamination,
24
it was done under the direction and control
of the former
25
shareholders, managers and operators of the company.
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(617)426-3077
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50
It appears that instead of buying a company with
2
an insignificant problem,
owner bought a company
the current
3
with an apparently larger problem.
4
The site remedial investigation
indicates a source
5
of PCE contamination in the vicinity of the OK Tool
facility
6
north of Elm Street and other possible PCE sources to the
7
south of Elm Street.
8
The feasibility study reports an additional PCE
9
source in
the vicinity of monitoring well
MW20 which is
10
located down gradient of the Hendrix
A source is a
facility.
11
release of contaminants to the soil
The PCE
and groundwater.
12
released to the Savage Well aquifer may have included both
13
nonaqueous phase PCE solvent
and trace concentrations of
14
dissolved PCE solvents.
15
According to the remedial investigation,
16
groundwater
flow direction figures,
contour,
elevation and
17
groundwater
flow from the OK Tool Company building to
does not
18
the south of Elm Street where the Hitchiner Manufacturing
19
Company facility and Hendrix Wire and Cable facility are
20
located.
21
According to the remedial investigation, the
22
groundwater elevation contours and flow direction figures were
23
developed while Hitchiner and Hendrix had their production
24
wells in
full operation.
25
Further, the changes in groundwater
flow
u
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Registered Professional Repc.rters
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~
5
6
~
I
51
directions during operation of the former Savage Well would
2
result in an easterly groundwater
making it
flow direction
3
less likely for PCE contaminated groundwater to flow from the
OK Tool
facility to the Hitchiner and Hendrix facilities.
Therefore, dissolved PCE migrating with groundwater from the
OK Tool Company facility source should not result in
contaminating the groundwater at the Hitchiner Manufacturing
8
Company and Hendrix Wire and Cable Company facilities~
9
The 1985 hydrogeological study report of the
10
Savage Well
site reported that Hitchiner had used TCA in their
11
process and
also used PCE in the past.
Many New England
12
facilities used PCE as a solvent and industrial degreaser
from
13
the 1950's to the late 1970's before changing to the less
14
toxic TCA in the late '70'5 and early '80's.
15
Hitchiner Manufacturing has indicated that their
16
records today include the purchase of two fifty five gallon
17
drums of PCE.
if dissolved in
Just one gallon of PCE,
18
groundwater, can contaminate up to 100 million gallons of
19
groundwater at a concentration of five part~ per billion,
20
which is the EPA drinking water standard for PCE.
21
Based on the remedial
investigation and
22
feasibility study reports and DES information, it appears that
23
Hitchiner and Hendrix have PCE co~~aminated groundwater on
24
their property south of Elm Street that may be due to their
25
past operations or waste management practices.
APEX REPORTING
Registered Professional Reporters
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52
We were surprised to see that the other PRPs
2
claimed that OK Tool was the only participant
of contamination
3
at this site.
Clearly, the scientific studies and other site
4
information
For many
indicates that that is not the case.
5
both Hitchiner and Hendrix discharged water into.a
years,
6
stream which traveled off their properties.
7
Hitchiner has had a history of fines and problems
8
with the State regarding waste disposal
Hitchiner
practices.
9
in fact paid the consequences of contaminating cows
in a
10
neighboring property.
Also, Hitchiner discharged waste for
11
many years into an unlined, waste water lagoon on their
12
property known as Lake Louise.
13
According to the available records, OK Tool had
14
been shipping its chemical waste off the property to
15
appropriate disposal sites in accordance with state and
16
federal laws since the early 1980's.
In addition, the company
17
ceased using or purchasing PCE in 1984.
18
Clearly, the current ownership did not participate
19
in and had no control over the prior manufacturing and
20
management practices that may have contributed to the problem.
21
In fact, the current owner of OK Tool, along with Hitchiner
22
and Hendrix, have filed a lawsuit against the past owners and
23
operators of the OK Tool Company seeking contribution from
24
them for the damages they have done to the aquifer.
Any
25
assistance that the EPA could provide in that endeavor would
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Registered Professional Reporters
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~~
greatly increase the likelihood of causing the people who are
2
actually responsible
for the problem to pay for its
3
remediation.
4
Lastly,
a remedy
OK Tool would urge EPA to select
5
that will
The result
not bankrupt the remaining companies.
6
would only put hundreds of Milford employees out
of work.
7
Thank you.
8
(Applause)
9
MR. COUGHLIN:
Thank you.
10
Dan Coolidge.
11
MR. COOLIDGE:
My name is Dan Coolidge and I'm
12
counsel
for Hendrix.
13
I had not planned to make a statement,
so I
14
apologize as I
But I
don't have any prepared notes here.
15
wanted to make a couple of comments.
We have heard it stated
16
that both Hitchiner and Hendrix have contributed to the
17
contamination based upon the RIfFS study.
And I'm not sure
18
that's altogether a fair statement.
19
It is a fair statement and a matter of public
20
record that the outfall
from Hendrix contained both PCE and
21
TCA.
it contained
It's also a matter of public record that
22
those contaminants at levels that were less than the levels in
23
the water it was pumping out of the ground.
in
fact it
That
24
was pumping contaminated water,
from an up
contaminated
25
gradient source,
out of the ground, using that water for
APEX REPORTING
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. (617)426-3077
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54
cooling and putting it out
into its discharge stream.
They
2
didn't put those chemicals in there, they were in the water.
3
It was also stated that water
flow south
doesn't
4
of Elm Street.
ago,
South of Elm Street up until about a year
5
there were two production wells, one at Hitchiner and one at
6
Hendrix, each pumping large volumes of water, which anybody in
7
this room
when you pump
is permitted to do.
That water,
8
water,
And it appears that it was
it sucks it from somewhere.
9
sucking it
from across Elm Street.
10
We've heard it pointed out that there are levels
11
of contamination found at Hitchiner and Hendrix.
I
Well,
12
would point
out that the levels of contamination of PCE found
13
at OK Tool,
which is in the record, were very often levels of
14
15,000 parts per billion.
The levels of contamination found
15
in the groundwater at the Hendrix facility in the order of 0
16
to 100 parts per billion,
and indeed is the same level as the
17
water all
around the area.
18
There's no indication of a source at Hendrix;
19
there's an indication that Hendrix has suffered contamination
20
from an up gradient source.
So,. to point out that there is
21
contamination, no one denies that there's contamination in the
22
groundwater.
There's contamination in the groundwat~r
23
underneath the police station,
I don't think anybody is gl~ing
24
to suggest that it came from the police station.
25
It's been pointed out that there is contamination
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Registered Professional Reporters
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~~
of PCE found at NW20,
down
gradient
from Hendrix.
Well, NW20
2
is also down gradient
And indeed, the levels of
from OK Tool.
3
contamination of PCE between Hendrix and NW20 dropped
4
precipitously.
that
There's no indication, none whatsoever,
5
the contamination at NW20 is flowing, by merely being down
6
gradient, is coming
Now, don't believe that
from Hendrix.
7
misconception.
8
It's a little disingenuous,
I suspect, to be
9
pointing at the moat in the eye of Hendrix and perhaps
10
Hitchiner when there is a mountain of contamination that's
11
coming from OK Tool and
I just don't want to leave the
12
impression here that anybody has been playing fast and
loose
13
with the facts here on the part of Hitchiner or Hendrix;
14
certainly not on the part of Hendrix.
15
The fact is, there is no evidence in the PI that
16
would indicate that there is contamination that is emanating
17
o~ sourced from Hendrix, absolutely no evidence,
nothing.
18
There is speculation that becau~e they have used
some
19
chemical, there isn't a person in this
room
who probably has
20
not used some chemical,
and the mere fact that the chemical
21
has been used does not lead to the fact that it was al~o
22
released into the environment.
23
The amounts of chemicals that have been used by
24
Hendrix and by Hitchiner and by all of the companies has. also
25
been disclosed to the EPA as part of a 104-E request.
You'll
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(617)426-3077
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~b
find that the amounts of chemicals are rather small on the
2
part of Hendrix.
3
I just did not want to leave any of these
4
misimpressions on
the record.
~
5
Thank
you.
6
(Applause)
7
MR. COUGHLIN:
Thank you.
8
That's it for the people who signed up.
Is there
9
anybody else that would like to make comment?
Please feel
10
free to
come
to microphone.
And if you could please give us
11
your
name and spell it for us 50 we can make sure we get it in
12
the record correctly, and also who you represent.
13
MR. BEZANSON:
and I'm
My name
is Bruce Bezansc.n,
14
an employee of Hitchiner Manufacturing Company.
It's spelled,
15
B-E-Z-A-N-S-O-N.
16
I just
it true
have one small question.
Isn't
17
that the total
the EPA's proposed remedial alternative
cost of
18
is going to be between thirty and forty five million dollars
19
over the next twenty to thirty years?
or more
20
Thank you.
21
MR. COUGHLIN:
Thank you.
22
Anybody else?
please
If you do have comments,
23
feel free to step up and let us hear them.
We do want to hear
24
everything you do want to say.
25
(No response)
APEX REPORTING
Registered Professional Reporters
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~~
~.:
MR. COUGHLIN:
Qkay.
If not, we will close up
2
this portion of the hearing and we're going to reconvene
3
tonight at 7:00 and take any other additional
comments of
4
those who come to that particular part of the hearing.
5
(The public hearing adjourned at 5:00 p.m.)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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58
5_~-5_~_I_~_Q__-~_s_~_~_I_Q_~
2
COMMENCED [7:05 p.m.]
3
MR. COUGHLIN:
evening.
Good
4
My name is Dan Coughlin.
I'm Chief of the
5
New Hampshire Superfund Section at EPA in
We have a
Boston.
6
real good turn out and we appreciate that.
7
As you know, we're here tonight
to conduct an
8
informal
for the cleanup
public hearing on the proposed plan
9
of the Savage Municipal
I essentially am
Well Superfund sit€.
10
gc'ing to
serve as the Hearing Officer for this hearing.
11
Present with me tonight are,
on my right,
12
Dick Goehlert, he's the Remedial Project Manager for EPA, and
13
on my left, Dick Pease from the New Hampshire Department of
14
Environmental Services.
15
The purpose of this hearing is to formally receive
16
public
EPA's proposed plan of the Savage site as
comment on
17
well as the other altern~tives that we've considered in the
18
remedial investigation and feasibility study.
On Thursday,
19
July 11th, EPA held a public information meeting in which we
20
presented the results of those studies, RI and FS as we call
21
them, and presented the proposed cleanup plan.
The pro~osed
22
cleanup plan looks like this.
There are copies available as
23
you come up the stairs out back if you don't have one.
I
24
would encourage you to get one before you leave, certainly..
25
The public
period began on Friday,
comment
APEX REPORTING
Registered Professional Reporters
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59
July 12th and will run till Saturday, August 10,
1391.
2
Before beginning, let me describe for you the
3
format for
I'm going to ask Dick Goehlert,
the hearing.
First
4
to give us
a brief overview of EPA's proposed cleanup plan.
5
After Dick has given his overview, we will accept
6
oral
on the
comments
from anybody who wishes to make a comment
7
record.
That record will be taken, we're transcribing
8
everything in its entirety and we'll take that back and put
9
together a complete copy and become a part of the
10
administrative record for the Savage Municipal Well
Superfund
11
site.
12
So that everybody has an opportunity to comment,
13
I'm going to ask that you keep your comments to a maximum of
14
fifteen minutes.
to run
If you think your
comments are going
15
over the fifteen minute period, please summarize them for the
16
purpose of
the oral presentation and then give them here
17
tonight in the written form or mail them to us during the
18
cOmment
have an
period.
Again,
that's so that everybody will
19
opportunity.
We have a lot of people here and we want to make
20
sure that everybody has an opportunity to offer whatever input
21
they would like to.
22
If I find that your comments are wandering a
23
little bit,
Again,
I may attempt
to focus you a
little bit.
24
there are a lot of people that want to give comments.
This
25
will not be an attempt
for me to try to limit on what you want
APEX REPORTING
Registered Professi~nal Reporters
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60
to say but
rather to make sure we accomplish what we want to
2
do at this particular hearing and that's to get all the
3
comments
wants to comment on the proposed
from everybody that
4
plan and on the alternatives that we're presenting
for the
5
clean up the Savage Municipal
Well Superfund site.
6
The hearing is an opportunity for EPA to listen to
7
your
concerns regarding the studies that we did on the Savage
8
site as well as the proposed plans and the alternatives
9
investigated.
The purpose of the hearing is to receive public
10
comment.
information
The purpose is not to engage in an
11
exchange as we. did during the public information hearing.
12
Those of
you who wish to make comments should indicate so by
13
filling out an index card, which are available out back, you
14
should have
filled them out when you came in, but if you would
15
like to make a comment,
I would ask that you go back and get a
16
card and
forward them as we go along.
fill it out and they will
17
here.
call on you in the order in which you signed
I will
18
those cards.
19
After all the comments have been heard,
I will
20
close the hearing.
And if anybody would wish to submit
21
written comments during the public comment period, which ends
22
August 10th,
I would encourage you to do so, but remind you
23
that they must be postmarked no later than August 10th.
They
24
should be mailed to our office in Boston and the address
is on
25
the third page of that proposed plan, which I showed you
()
APEX REPORTING
Registered Professional Reporters
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'-I
'0
i:,l
p"( ev i '~'Ll sly.
2
The summary of tonight's hearing and EPA's
3
to your comment,
both written and given here tonight
"r esponses
~
will be part
the Savage site.
,:,f the F::ecord
Of De,: i si on f,:,r
5
The Record Of Decision is a legal
in whid1 EPA
d ':": umen t
6
describes its selected remedy for that site and the basis
f,:,r "
7
that remedy.
8
SO," I thank you 2'111
I he,pe YOLI have
fClr c omi ng.
9
plent>' of
we d,:,
': omment S for LIS,
I'm sure you d,:,.
BLtt bef,:,re
10
':.ta"(t,
f,:.r havi ng LIS
I would like to thank the Hampshire Hills
11
here tonight, it makes
nice comfortable setting and
f c.r a
12
makes the hearing that
much easier for all of us.
13
So, with that, Dick, perhaps you can give your
14
presentati':ln.
15
16
17
18
19
20
21
22
23
24
25
APE X REPOF~T I NG
Registered Professional Reporters
-------
'-~
~h..
E[2Q222Q_El~o_Q~~[~i~~
2
MR. GOEHLERT:
I would like to make one
3
suggestion,
to me at
if you
want to mail comments,
mail
them
4
this dddress.
the Milford Town
And obviously we're not at
5
Hall, but we are on a low budget now and we didn't revise the
6
overheads.
i
Much of what
you'll see now was said approximately
8
two weeks
we're going
Briefly,
this is the process
ago.
9
through and we are at the hearing.
The next step is the
10
Record Of Decision
a response
and a summary and the
with
11
response and summary is
the responses to the comments that are
12
given both during the comment period and tonight.
And there
13
will be negotiations to facilitate and implement the final
14
decision of EPA, that is known as remedial action.
There are
15
two portions of that remedial
action, construction and
16
operational
maintenance.
17
Briefly, these are again the results of the
18
remedial
and the
investigation, site contaminants, the extent
19 site risks. These are also in the proposed plan.
20 A question as t,~ why a cleanup, this was begun at
21 the last informational meeting and there have been several
22
calls to me as well as some letters written in.
And again,
23
the reason for
the cleanup is to protect residents to exposure
24
to unsafe groundwater, to restore the aquifer drinking water
25
standards and those drinking water standards are known as
APEX REPORTING
Registered Professional Reporters
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v
-~
maximum cont~minant
l~vels.
We believe the aquifer c0uld b~
2
needed for
drinking
~ater
in the future.
And we
also believe
3
the aquifer
can be suitable for drinking water.
J
This is the extent of contamination and
it goes
5
from by the OK Tool, Hitchiner, Hendrix facilities,
basically
6
parallel to Elm Street and
across back over to Elm Stre~t ~ll
7
the way down to the river,
back over
other side of the river
8
there.
1000,
The number on each
of these contours of 10,
100,
9
represents parts per billion of contamination, ahd this
is of
10
total
in the aquifer.
volatile organic contamination
11
The portion in the light blue down at the end of
12
the plume is is consi"dered to be below the maximum
contaminant
13
levels and if you were to sink
a well down in here and
14
withdraw water,
it would be considered safe for drinking.
15
Anywhere
line, approximately above th~ 5 contour,
above this
16
if you were to sink
area,
that would be
a well
in any of that
17
considered unsafe drinking water.
18
Before putting
you the
on an overhead
showing
19
components
thii map shows the
of the preferred alternative,
20
locations of
the six production wells that would provide
21
withdrawl
two one here and One
of groundwater here, here,
22
here,
and two here on the other side of the river.
23
The volumes of water to be withdrawn from the
24
aquifer total
80 that would be
1100 gallons per minute.
25
approximately 400 gallons per minut~ at the head of the
APEX REPORTING
Registered Professional Reporters
-------
04
contaminant right
in
there, approximately 600 gallons
':; minl...lte
2
'-.Ii t hdr awn
and approximately 100
fl' ,:,m
the middle of the plume,
3
gallon5 a Ininute withdrawn from the end ,:,f the plume c.n the
4
other side of the river.
. ..
Therl?
'~OL\ 1 d
be an amount of
5
,:,:,ntami nat i ,:.n
is not covered by the shaded green
which
6
p.:,j'. t i e.n 5 her e
f ':.1' t... eat ment. and
which would noi be captured
7
would undergo what is
Ea,: h...) f
known as natural attentuation.
8
the alternatives that tPA studied included natural
9
attentuation as part of the remedy.
10
The preferred alternative,
i f ,:lny 0 f YC'LI
have
11
9,:,t t en ,:,ver
there,
1;.:, the 1 ibrary
to see the documents over
12
the preferred alternatives had a number and some letters, MM
13
stands for management
of migration and the alternative number
14
ItA and basically this is what
I've just described using
was
15
the rnap.
one Llsi ng ai i'
There would be two treatment plants,
16
stripping, one using
in the 10': at i c,n
ultraviolet oxidation
17
near Ok Tool and the Hitchiner
and there would be
fa.: i 1 i ties,
18
one treatment plant in the middle of the plant presently
19
I,:,,: at ed near
Llltr.:3violet
or at the existing Savage Well
LISi ng
20
c,:>;i dat i ,:,n.
21
An important point to be made is that all
22
alter-natives,
including the prefer-red alter-native, would have
23
to have institutional controls over the plume to prevent the
24
use of the groundwater- until the groundwater is safe to use,
25
that is for drinking water- pur-poses.
MMIIA has a minimization
APEX F.:EPOPTING
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~-"
of wetlands and what impacts, as do all alternatives.
!"J.:,?
2
believe tl"'Flt they"e m,"\y be wells ,))' pipes,
the plants,
(;.ne .:0 f
3
treatment plants would have to be located
() f
in the
flood plai-'
4
t; he l..,Iet 13nd.
': ..:.t! 1 c!
Pumping of the water
from the aquifer
5
impact the water table which would impact
'...et lands.
6
These items will
be carefully considered in design
7
and every effort will be made to minimize any impact
of that
8
nature.
will
There will also be site
m,:,ni t ':,," i ng.
131' ':'Ltndwi.."1 tel'
9
be tested on a periodic basis, both on the site where
10
contamination is and
where contamination has not yet reached
11
or where ~ampling is necessary to be protective of people
12
using drinking water
from bedrock wells.
13
c,:,st,
this is it's present worth, cost, we have
14
SLimmed all
mi 11 i c,n
the costs to today's dollars, would be 15.5
15
d,:,llars.
16
I would like to briefly go through the other
17
alternatives.
I will go through this overhead and the present
18
the maps that go along with each of the treatment
19
alternatives.
20
Plan number 1, the management migration number
1
21
is n,:, a,: t i I:,n.
No action is required by the national
22
contingency plan which is the regulation under which we study
23
these sites and remediate these sites.
The n,:. a,: t i ,:.n
24
alternative was carried
as a
forward as a requirement of that
25
contingency plan.
APEX F.:EPOF.:TING
Registered Professional
(617)426-3077
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i~ E.
If we did nothing, the MCL,
t he ma~; i mllin
2
c ,:.nt ami nant
levels would not be attained in over a hundred
3
C,:,st
<3.1 ternat i ve fc,l'"
of monitoring under a no action
years.
4
thiyty years is estimated at
$764,000.
5
A limited action plan or management
mig'l'"ati,:,n 2
6
includes natural attenuation
N,:,w,
and institutional controls.
7
the difference between number 1 and number 2 is that number 1,
8
is we do nothing except monitor.
Number 2 is we have
9
institutional controls on the
land wherever contamination is
10
above the maximum contaminant
Agai n, oatllral
levels allowed.
11
attenuation would mean you would have the aquifer
rest,:,red, t,:,
12
drinking water quality
hltndred years.
in ,:,ver a
13
Cost of the monitoring, because the monitoring
14
''''Olll d be
would be 1.2
in,: r ea sed ,:,ver
what we dc.
in n.:. a.:ti.:.n,
15
million d,:,llars
,:,ver
a thirty year time period.
16
And then 3 is treatment of the concentrated plume
17
,:.nl y.
And then 7 and 7A is treatment of the concentrated
18
plume and treatment of a portion of the plume downstream.
19
Before I get any further, let me point out what we
20
mean by the concentrated plume.
There is an area in here
21
which we have designated a concentrated plume.
The I"emaining
22
portion of the contamination is considered to be dis~olved.
23
The concentrated plume and the dissolved or extended plume
24
will be tl"eated basically in the same manner; the water will
25
be withdrawn for treatment and a discharge made to a surface
APEX F.:EPORT I NG
Registered Professional Reporters
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~;
water with possible recharge.
2
The main thing to understand is that
in this area
3
here, the concentrations are of a significantly higher level
4
that we felt that we had to identify that area as a separate
5
to be addressed.
area
6
This is a
for alternative numbers 7
slide which is
7
and 7A.
if the alternative which
And before I describe that,
8
I described as MM3 would only have wells pumping at location 1
9
and location 2.
That would be in the concentrated plume.
10
That would be the withdrawl
migration
points under management
11
number 3.
12
Alternative 7 and 7A begins the withdrawl here and
13
at four
locations, Savage Well, downstream 0' the Savage
other
14
Well,
The remaining part of the plume
and two wells here.
15
would be left to what would be natural attenuation purposes.
16
There were three other alternatives considered in
17
the feasibility study in the proposed plan.
The proposed plan
18
lists '3 and 9A,
this would have cleanup contained in twenty to
19
eighty five years at a cost of 21 million to 16.3 million, aad
20
actually the 21 million would go with the eighty five years.
21
And then 10 would have MCOs, maximum contaminant
22
levels, or the aquifer cleaned up the drinking waters and that
23
would be attained in ten to thirty years,
a thirty
crossed for
24
year period and that is 44.3 million.
25
And then 11 is the same as the preferred
APEX REPORTING
Registered Professional Reporters
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68
alternative, MMllA.
The difference is in the limitation of
2
treatment.
The difference between whether an alternative has
3
an A,
is that ultraviolet oxidation is added as a treatment
4
technology in
When an alternative
place of air stripping.
5
does not have an A,
the treatment technology is strictly air
6
stripping.
The ultraviolet oxidation represents a cost
7
savings as compared to air stripping for treating a portion of
8
the aquifer.
That water which is more efficiently treated
9 with ultraviolet
10 CClsts.
11 This
12 treatment at the
oxidation thus represents a reduction in
would be alternative 9 and 9A, there would be
head of the plume for the concentrated plume
13
locations
And then all other
1 and 2 shown on the map.
14
withdrawl
The
points would be down close to the river.
15
contamination that was not captured here would have to flow
16
through the aquifer to be caught by these wells located here.
17
The contamination, again,
area in
not captured by the shaded
18
green would be left for natural attenuation, that
19
contamination
in the groundwater would not be captured and
20
treated.
21
And then 10 is the most aggressive alternative
22
that's being presented.
This represents capture and treatment
23
of wells in locations 1 and 2 and then capture at thirteen
24
other locations throughout the aquifer,
the line from here to
25
there.
There would still be an area of contamination of
APEX REPORTING
Registered Professional Reporters
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69
groundwater which would be left for natural attenuation.
The
2
number of wells and the amount of pumping total almost
3,000
3
gallons a minute.
It means that you are withdrawing a great
4
volume of
A greater volume of water speeds the cleanup
water.
5
of the aquifer.
6
I would like to ~nd with this
one.
For thos~
~
I
of you at
the last meeting, this is a much shorter
8
presentation.
9
Comparing MMI1A to the other alternatives, no
10
action is
not protective of human health.
11
The limited action alternative,
which was number
12
~
~,
restore groundwater in a reasonable time and
will not
13
institutional controls may be difficult to enforce over longer
14
periods of
time.
15
And number 3,
it would take much longer to reach
16
MCLs.
concentrations
It would not control the spread of high
17
of contamination and would cost
nearly as much as MMI1A.
16
MMI1A requires less time and cost to restore the aquifer than
19
alternatives 7, 7A, 9 and 9A.
20
And then 10, which is again the most aggressive,
21
is not necessary because the alternative are expected a~equat~
22
to go into the near future.
23
MMI1A thus represents a balanced approach that is
24
capturing the highest concentrations of contamination in the
25
aquifer.
over a
It is allowing natural attenuation to occur
APEX REPORTING
Registered Professional Reporters
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pretty good portion of the aquifer.
And it
is also being
~t:)
3
concentrations of over 600 parts per billion.
protective at the end of the plume where they do have high
2
4
This brings to close my presentation.
5
turn you back over to Dan who will allow comments.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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E~Qlif_h2mm~Qi~
2
MR. COUGHLIN:
if you
As you give you comments,
3
would,
in the
as Mr. Barss i~ doing,
come up to the microphone
4
middle and tell
affiliated with.
us who
you're
5
MR. BARSS:
evening.
Good
6
My name is Lloyd
Barss.
7
I'm a concerned employee of Hitchiner
8
Manufacturing.
9
My comment
to come in the form of a
is going
10
question and that would be,
quite simply, why has the EPA
11
allowed seven years to pass without beginning
any containment
12
pumping and treatment of the PCE hot spot at the OK Tool?
It
13
was clear from the state study in 1984 that, at a minimum,
14
such pumping and treatment would be required.
15
That's my comment.
16
(Applause)
17
MR. COUGHLIN:
Thank you.
18
Jack McDonald.
19
MR. MC DONALD:
I also am a concerned
Yes,
20
employee at Hitchiner.
21
I have a question.
Is it not true that after
22
you've arbitrarily made your decision regarding the .cleanup
23
methods, costs and allocation of same, that the potential
24
responsible parties do not have any recourse to judicial
25
review?
APEX REPORTING
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72
MR. COUl:3HL IN:
Let me explain the
format again for
2
ever ybc1dy.
We are
This is not a question and answer
sessi.,:.n.
3
taking comments for the record.
The comments will be answered
4
in the responsiveness summary that we produce when we produce~
5
the record of decision.
6
Charles Sullivan.
7
MR. SULLIVAN:
My name is Charles Sullivan.
8
I've been here in Milford with my family since
9
1 '357 .
I have never worked at Hitchiner Manufacturing, Hendrix
10
Wire and Cable or any other company in this town.
I'm.here as
11
a taxpayer of the town of Milford tonight and very concerned
12
about this pollution problem.
And we all want to help solve
13
it and solve it in a fair way to all concerned.
14
I d.j n,:,t
feel what I hear and read is really being
15
fair to the two companies that are left here, Hitchiner
16
Manufacturing and Hendrix Wire and Cable.
17
I would like to take YClu. back
just for a moment,
18
please, to the late '60's and early '70's.
I had the
19
privilege of being a Selectman for the town of Milford.
At
20
that time, we had some very serious droughts in our
t.jwn.
21
Bob Courage was the Superintendent of Public Works.
22
Hitchiner Manufacturing was also having a very
23
serious problem being on our well system.
They were I clsi ng
24
water pressure.
A gentleman named Frank Doyle was the
25
Engineer at that time.
We met with Frank Doyle several times
APEX REPORTING
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-""
i.;J
and he was concerned about the loss of water pressure and came
2
up with the idea that Hitchiner Manufacturing will put in a
3
well of their own, recylce the water and stay on our town
4
water as an emergency use.
I understand that well at that
5
time is g.:.ne,
Hitchiner
but a new well has taken its place.
6
Manufaeturing paid for this full
expense, nothing to do with
7
the town whatsoever.
8
N,:.w, all
fre.m what
indications show at this time,
9
I hear and what
I see, there are two companies left here that
10
are supposed to take. the brunt of all this problem.
The .:.t her
11
companies are still owned, one of them is still owned by
12
people who bought it at the time of the pollution.
Therefcore,
13
when you buy something, you buy the problems.
14
15 here.
16 CC'LII d
And I feel that we don't want to be a ghost town
We don't want to lose 1,000 jobs in our town, and this
happen, it could even be made that these companies will
17
decide they no longer want to stay her~ in Milford.
1 , 000
18
jobs. would cause a lot of hardship, losing of homes,
goi ng con
19
welfare,
And certainly those of us that"
moving out of town.
20
are left are going to be straddled with heavy taxes, and lord
21
knows we're payi ng .:,ur share ri ght
now.
22
And I feel that the money that we pay in taxes
23 that we should be entitled to a Superfund. After all, whc,
24 pays the Super hind? We do with c,ur internal revenue. Who
25 pays EPA? Taxes.
APEX REPORTING
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74
I think at this time we ought to be able
to:. so:olve
2 the pro:lbl em here.
3 want to:. g.:, do::own.
4 a st rltggl e now.
And give us some money,
hel p liS.
We dcon' t
Don't bury us before our time.
We're having
And feel this way here,
if we work together,
5
Hitchiner and Hendrix Wire and Cable are two great
': ompan i es,
6
they are the backbone of our
t clwn .
Don't put them down.
Help
7
us.
Help them and help us.
8
Thank YClli.
9
(App I altSe)
10
MR. COur:3HL IN:
Thank YCllt.
11
Dio:k Bickf,:ord.
12
MR. BICKFORD:
Gc.c,d even i n g .
13
My name is Dick Bickford.
14
I'm a concerned employee of Hitchiner's.
15
My comments take the form of a couple of
16
quest i .:ons.
What has the EPA done to ensure that
01< T CII:' 1
17
Company assets will be available to help pay f~r their fair
18
share of the cleanup costs?
And secondly, what about New
19
England Steel Fabricators and its owner/operators?
20
MR. COUGHLIN:
Thank yc.u.
21
Steven Turner.
22
MR. TURNER:
I yield to the next speaker.
23
MR. COUGHLIN:
Okay.
24
Paulina Cox.
25
MS. COX:
I'm Paulina C,:)x.
APEX REPORTING
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u
,'.;
,",CO
I -'
I'm a concerned employee of Hitchiner
2
Manufacturing Company.
3
I just wanted to make a comment that I hope that
4
the EPA will be fair in their assessment of who pays for the
5
.: I eanup.
everything I've heard from all the meetings
See,
6
that I've been to make it clear that OK Tool
c au sed m.::.s t ':' .f.
7
the contamination, therefore, should pay for
,:.f the
mc.st
8
.: I eanLlp.
I just want to implore EPA to be fair.
9
(Applause)
10
MR. COUGHLIN:
Thank y':'u.
11
Al Di x.;:.n.
12
MR. DIXON:
Evening.
13
My name is Al
Town Manager of the town of
Di x.:.n,
14
Littleton, New Hampshire.
15
I'm down here tonight on behalf of ~he town of
16
Littleton Bo~rd of Selectmen.
We'd like to go on record in
17
this case because of the potential impact the resolution of
18
this matter may have and could have on Hitchiner Manufacturing
19
in our community.
20
Hitchiner is what we refer to as a very
21
responsible corporate citizen in our community and has been
22
since 1984.
I think I should echo the sentiments expressed
23
here tonight by Charles Sullivan,
former Selectman of Milford.
24
That's one of the primary reasons why I'm" here tonight,
25
because the people of Littleton and the town officials are
APEX REPORTING
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75
impressed with the sense of social responsibility demonstrated
2
by Hitchiner.
And we desire to do all we can within our power
3
to help them remain a financially stable company in Littleton
4
and the state of New Hampshire.
5
In the north country,
jobs, tax base and good
6
industry are very important. . We've watched Hitchiner
7
Manufacturing grow from thirty five employees in 1984 to a
8
little over 300 today.
They contribute about 6.8 million in
9
annual payroll and an associated two million dollars in
10
employee benefits.
In 1989
This is significant
to us.
11
unemployment in Littleton was less than five percent.
As of
12
June of
1991, the total is 10.6 and rising.
13
We hope that the resolution of this case, as we
14
seek the resolution and remedial action that is applied, will
15
not result in the loss in the employment and the benefits of
16
the employees of Littleton ~nd of Milford, which we
17
understands totals approximately 1300 statewide.
18
We would request that the parties seeking to
19
resolve the Savage Well aquifer remediation consider a
20
balanced approach.
In that balance, I think we should take a
21
look at the technology, the technology applied and the '~ost
22
can have a significant impact on the companies involved.
The
23
time in which the remediation is desired to be accomplished
24
also can have a significant impact.
25
Lastly, I guess, we'd like to have you consider a
~
APEX REPORTING
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[j
\/
--
i l
mixed funding.
Obviously,
as you've heard tonight and as you
2
well knc.w
there are some companies that are
fr.:.m the re.:,:.rd,
3
n,:. l.:.nger
in the area to partake in the funding of this
4
si t Llat i .:,n.
c ,:,nsi der --
So, we hope that the Superfund will
5
the Superfund program and those who administer it, will
6
,:c.nsider a mixed fLtnding appr':'ach that will take intc.
7
consideration the absence of the parties that are not here to
8
deal
with their responsibility, which they are very much a
9
part .:,f.
10
Thank you for your time and,
I hc.pe. we. can
again,
11
all work together to keep the companies in New Hampshire that
12
are viable here and employing our people.
13
Thank you.
14
(Applause)
15
MR. COUGHLIN:
Thank yc.u.
16
Bill Paradise.
17
MR. PARADISE:
My name is Bill Paradise.
18
I'm a resident of Amherst and I'm an employee of
19
Hendrix Wire and Cable.
20
I find myself frustrated by the EPA's public
21
meetings and find them to be disingenious, particularly the
22
July 11th meeting.
The EPA holds a public meeting to explain
23 its reasons for selecting the parti.:ular .: 1 eanup remedy and
24 invites the public tc. ask quest i c.ns and provide c.:.mments.
25 Ostensibly, I i mag.i ne the EPA is also attempting to gun
APEX REPORTING
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78
support for
its selected remedy.
2
However,
the issues involved with the aquifer and
3
the proposed cleanup methods are highly technical.
They
4
involve a broad range of scientific disciplines and are
5
shrouded in spe.:ialized jargon and acronyms.
Expecting the
6
general public to formulate insightful or informed questions
7
and comments concerning the technical merits of various
8
cleanup technologies and the characterization of the Savage
9
Well aquifer is akin to having National
Aeronautic and Space
10
Administration ask for public questions and comments
11
concerning alternative guidance systems for the space shuttle.
12
Indeed, even the EPA, after five years of study
13
and hundreds and thousands of dollars worth of consultants can
14
offer nothing or
little more definitive than the aquifer may
15
or may not
be cleaned up in thirty to a hundred plus years.
16
The public can, however, make intelligent
17
judgments concerning the cost benefit ratios of different
18
alternatives.
however, in order
Like everything else in life,
19
to formulate judgments of relative value, one must know the
20
costs, an issue the EPA steadfastly refuses to discuss.
. 21
Shrouding the supposed costs in net present value figures that
22
are minus thirty and plus fifty percent over thirty years or
23
fifty years or a hundred years does very little to address the
24
true costs associated with the undertaking, without even a
~
25
breath of who or how this enormous moving target is going to
APEX REPORTING
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7'3
be funded.
2
The value of the differing cleanup strategies must
3
be weighed against the cost to the community's
e,:cln,:omi ':
4
viability.
Only then can the EPA ask for meaningful questions
5
and comments and only then can the public make informed
6
judgments concerning the value and tradeoffs associated with
7
alternative strategies.
8
The EPA's refusal
to discuss the cost and tunding
9
side of the cleanup equation is a disservice to the community
10
that purport to serve and smacks of little more than the
"
political expedience of the EPA going through the motions of
12
holding public meetings that they are required by law to
13
c':lndLI.:t.
14
(ApplaLlse)
15
MR. COUGHLIN:
Thank y':'!..I.
16
T,:,m Pet er s,:,n.
17
MR. PETERSON:
I would jus~ like to reiterate what
18
some of my fellow employees at Hitchiner Manufacturing have
19
been talking about all along, and that's the issue of
20
fairness.
21
The question I have is, does the EPA really feel
22
that it's fair that Hitchiner Manufacturing and Hendri~ Wire
23
pay for the cleanup of the Savage Well when it's clear that OK
24
Tool caused the majority of the contamination?
25
(Applause)
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80
MR. COUGHLIN:
TI'1ank y':'u.
2
MR. FARH~AS:
Attila Farikas,
Savage F~':'ad,
3
Mil f .:,r d .
4
I'm also an employee of Hitchiner Manufacturing.~~
5
I just got back from vacation and took all your
6
papers with me to read and I was too busy enjoying nature t6
7
get through all of it.
I did read a paper by, I did some
8
super fi I: i al
': al cuI at i c,ns.
9
I'm a little concerned about some of the outlying
10
well
It seems to me that at the pollution levels
I,:,,: at i I:.ns.
11
that are indicated in the aquifer and also at the level~ that
12
y,~u were planning to pump the aquifer, you'd be recovering
13
less than one cubic inch of the pollutant, of the PCE
14
pollutant per day.
15
Now, it seems to me that initial capital costs of
16
laying in all the pipe and buying up right of ways to send the
17
pipe back to the reclamation plant is going tobe quite high.
18
And al s.::o,
to do it on these remote sites is going to be also
19
high, mainly because you're going to have to send people out.
20
there to monitor it and so on.
21
22 work?
23 caused
Is it really cost effective to do this type of
And my guess is that your car, driving to this meeting,
much more pollution than that one cubic inch per day
24
that it would cause at those particular sites that you're
25
hoping to reclaim.
APEX REPORTING
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81
I do agree with the right of Hitchiner and
2
Hendrix,
that it might make a lot more sense to phase these
3
wells in one at a time and see really are you recovering what
4
you're planning to recover
and then evaluate do you really
S
need those remote wells before you go to all
that expense of
6
putting that in.
7
I also detect a lot of paranoia at this meeting
8
and it's mainly due to what the gentleman
from Hendrix said,
9
that
I got the impression
we don't have enough information.
10
that both Hitchiner and Hendrix is assuming you are going to
11
stick them with the whole bill for that cleanup, which I
12
personally feel would be totally unfair, and it really would
13
be appreciated if you came out and said that that would not be
14
the case.
I know this is up for negotiation and all that, but
1S
it definitely does sound like you're just dodging the issue.
16
And I think it would be a lot more credit to the
17
EPA and give a lot more credibility to any of these cleanup
18
claims if you could talk more openly.
I understand you have
19
legal problems and so on and some people get en your back and
20
telling you you're not doing enough, but it really makes
21
communication very difficult between us if we don't know. what
22
you're really up to.
23
I would like to reiterate that it would not be
24
fair to stick these two companies with cleaning up the whole
2S
site.
Because I think it doesn't take a rocket scientist to
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82
look at your diagrams and figure out where the pollution is
2
.: c,mi ng
fr .:.m.
3
Thank
y':'l.l.
4
(Applause)
5
MR. COUGHLIN:
Thank
y':'l.l.
6
Gary Daniels.
7
MR. DANIELS:
For the record, my name is
8
Gary Daniels.
9
I'm a State Representative from Milford.
10
I appreciated the opportunity to sit through the
11
in f.:.r mat i .:.nal
While the meeting was
meeting two weeks ago.
12
overall informative, I came away with a certain amount of
13
skepticism.
If the EPA is interested in our opiriion and takes
14
into consideration those opinions in formulating their
f i na I
15
decisions, why were the opinions reviewed today, those that
16
the EPA had previously presented,
and not any of the new ideas
17
that came forward two weeks ago.
Why isn't alternative MM5, a
18
proposal, sent to you by Hitchiner and Hendrix considered
19
viable enough to be reviewed at this meeting~
It i s my
20
understanding that, as of the time I talked to Hitchiner this
21
morning, that they had not received any correspondence ,from
22
you concerning that proposal.' Why not?
What about the idea
23
that someone had two weeks ago of filtering the water at the
24
well head?
There is no mention of that.
2S
If you are truly seeking constructive opinions
':y
APEX F.~EPORTING
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83
from the public, why don't you present the total cost
in a
~
~
manner that the general public can understand rather than
3
leaving us trying to figure out how a cost of
1.4 million per
4
year times thirty years comes out to 15.5 million?
~
~
(Applause)
6
MR. DANIELS:
out two
This confusion was brought
7
weeks ago at the meeting,
packet
and yet your informational
8
that you hand out today shows no effort to resolve this
9
confusion.
10
It is my understanding that the Hitchiner/Hendrix
"
proposal
would consist of three wells: one pumping at 150
12
gallons per minute at the OK Tool
property which OK Tool or
13
the EPA would pay for, one on the Hitchiner property pumping
14
at 250 gallons per minute which Hitchiner would pay for, and
15
one downstream,
most likely at the Savage Well site, pumping
16
300 gallons per minute which both Hitchiner and Hendrix would
17
pay for.
18
Considering the correspondence from the EPA on
19
record at the library states that there is,
"no absolute
20
guarantee of ultimate success",
I would recommend that the EPA
21
accept the Hitchiner/Hendrix proposal.
By law, if the EPA can
22
not get OK Tool to pay for their share of the contamination
23
cleanup, Superfund money must be used.
Within the
24
Hitchiner/Hendrix proposal, the two companies are willing tCI
25
pay in excess of their share of contamination, yet at a price
APEX REPORTING
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84
that they can afford and continue to operate.
2
In no way, no way, should Hitchiner or Hendrix be
3
forced to pay more than the proven percentage of contamination
4
that each company caused.
. .
5
It should be obvious to you by the number of
6
testimonies that have come before you today in the
form of
7
questions that while your rapport may be good with the town,
8
it is not with the people.
you did not
At the public meeting,
9
want to discuss liability or who would clean up what, yet the
10
livelihood of most of the people that have come before you
11
today hinge on those decisions.
12
I urge you to open up to the public, answer their
13
questions and eliminate the vagueness that shrouds this issue.
14
I also urge you to accept the Hitchiner/Hendrix proposal on
15
their terms, not yours; they know what they can afford and
16
still consider the welfare of their employees.
17
Thank you.
18
(Applause)
19
MR. COUGHLIN:
Thank you.
20
That's the last of the cards I have.
Is there
21
anybody else who would like to speak?
If you would tell us
22
your name and spell it for us please so we can get you
23
properly logged in the record.
24
MR. MC NAMARA:
My name is Mike McNamara,
25
M-C--N-A-M-A-R-A.
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85
I'm a resident of Milford, New Hampshire and I
2
have two concerns.
I'm a concerned resident as well as a
3
concerned employee of Hitchiner Manufacturing.
I have two
4
questions, one as a resident and one as an employee of
5
Hitchiner Manufacturing and the affiliated company,
Hendrix.
6
As a resident, I'd like to know why isn't it made
7
public that OK Tool has been ninety five or maybe even a
8
hundred percent guilty with polluting this well?
The last
9
meeting I went to, it was very clear to me that OK Tool was
10
the culprit and we're just beating around the bush and wanting
11
to charge somebody that's sitting there making bucks.
Okay,
12
that's fine, we'll pass the buck.
13
Now, as an employee of Hitchiner Manufacturing,'
14
I'm concerned for my own job and my own well
being, as well as
15
many in this community, I'd like to ask one question and
16
basically it's a very good question, why isn't EPA willing to
17
discuss with the PRPs and the public h6w the EPA expects the
18
cost in remedial action to be apportioned?
And the way I'm
19
reading this is, where's the cost?
As a
Is it Superfund?
20
resident, I ask is it Superfund or is it directly out of my
21
tax pocket?
22
Thank you for your time.
23
(Applause)
24
MR. COUGHLIN:
Thank you.
25
Is there anybody else that would like to make a
APEX REPORTING
Registered Professional Reporters
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BE,
': ,:,mmen t ?
There's a lot of you out there and we'd like to have
2
each and everyone of you who has a comment to give us, we'd
3
like to have it.
4
Yes,
sir.
5
MR. SALSBURY:
My name is Kieth Salsbury and I
6
w.:.r k f ,:,r
the town of Milford.
7
What I was wondering about, the gentleman brought
8
Lip bef.:.re,
is the EPA knew about this pollution and stuff back
9
in
1983 when it first started, why did it take so long to
,:c,me
10
up with
to do anything about it.
a 5.:,1 ut i ,:,n
11
That's my question.
y':'LI.
Thank
12
MR. COUGHLIN:
y':'LI.
Thank
13
Anybc,dy el se?
Yes, sir.
14
MR. FARH:'AS:
This is a question and I haven't had
15
a chance to read this document that was handed out at the last
16
meeting,
d':II:ument
so I couldn't ask at the last meeting.
Y.:,ur
17
dn page 6 does state that arsenic, chromium, beryllium, nickel
18
and lead were the only metals detected in groundwater levels
19
exceeding drinking water standards.
I get the impression th~t
20
none of these remedial actions address cleaning up the heavy
21
metals in the water.
What's the sense of cleaning up .the
22 aquifer from the v,:.latile ': c'mp':'l,Inds i f it's just going t.:. be
23 pc.tabl e because the metals are still in there.
24 Can YC'L! please answer this? I mean, this
25
information wasn't available to us until you handed these out
APEX REPORTING
Registered Prc.fessional Reporters
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87
at the end of the meeting last time.
2
MR. COUGHLIN:
Again, we aren't answering
?
-'
questions at this part of meeting.
We're taking public
4
comments and we will address those comments and your questions
5
in the responsiveness summary.
6
I do believe this handout was handed out before
7
the first meeting.
8
MR. FARH~AS:
I got it in the middle of the
No;
9
meeting because there weren't enough to g6 around, so I didn't
10
get to read it until after the meeting.
Even if you get it at
11
the meeting,
if you listen to what's going on, you don'~ have
12
time to read it during the meeting.
13
MR. COUGHLIN:
I understand.
14
MR. FARH~AS:
Thank yc.u.
15
MR. COUGHLIN:
Thank y.:tu.
16
Anybc.dy el se?
Yes, si r .
17
MR. SULLIVAN:
Charles Sullivan.
18
I just want to end,
I think, I personally have got
19
the feeling here tonight of how the people, the workers, and
20
the taxpayer feel.
And I'm going to end mine for good when I
21
say we know that the EPA is a very powerful committee.
You
22
come. in and tell us we have a problem.
You do not ask us how
23
we're going to clean it up or what we're going to do about it.
24
But you come in here and tell us, you're going to do it.
25
Now, I ask you, find that Superfund, help us, and
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88
you've got us on your side.
2
(Applause)
3
MR. COUGHLIN:
Thank yc.u.
4
MR. TURNER:
Steve Turner.
I fill ed .:.ut .:)ne ':. f '.~
5
yc.ur .:ards.
6
I'm on the Planning Board here in Milford and I:
7
guess I'm the pseudo town statistician.
I've done a number of
8
fiscal impact studies, not only for Milford, but for other
9
communities in southern New Hampshire.
I confess I haven't
10
done my homework on this issue, I don't have any hard numbers
11
t,:. gi ve y,:.u, but
I can talk in terms of the ballpark here.
12
My concern is with the taxation issue if these
13
companies are burdened financially to the point where they
14
would have to leave town.
One of the more recent cases of a
15
': .:,mmer .: i a 1
Mark Flugie~, the Town
.:,:)n.:ern coming
i n t ,:) t c.wn ,
16
Planner, and myself went through the analysis on this company
17
and basically we came down to the issue of roughly that
18
company would handle 600 single family detached units in town.
19
Now, again, I don't have the numbers, but if each
20
one of the two companies involved here handles the same
21
amount, 600 single family units for a total '';If 1200, r.';Iughly
22
that's a fourth of our housing unit count in town, a fourth.
23
So, the translation of all that, in the ballpark
24
now, not hard numbers, but basically we're talking about a
25
thirty percent increase in taxation if those two companies had
APEX F~EPORTING
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9
v
Sg
to leave
town.
2
Norm Marrison, our Chairman of the Planning Board,
3
is here as well.
I think he can verify that as a Planning
4
Board, not
only the Planning Board but the Board of Selectmen,
5
all the town boards,
I think are doing an outstanding job of
6
trying to take care of Milford; we do our homework,
we review
7
all applications very carefully.
I think the whole town can
8
be proud of everything that the boards do.
Every decision we
9
make, we're thinking about those people that are on the edge,
10
you know,
push them a little bit and what's going to h~ppen to
11
all these people who are just barely able to handle the
12
taxation burden.
13
So, my bottom line, and just keep this thirty
14
percent
when you negotiate with these
figure in mind,
somehow,
15
potentially responsible parties, please be careful.
I just
16
can't underline to you how important it
to all
is, not only
17
the employees of these companies,
but to all the citizens of
18
Milford.
19
Thank you.
20
(Applause)
21
MR. COUGHLIN:
Thank you.
22
MR. BABICH:
a resident of
I'm Greg Babich,
23
Amherst and a concerned employee of Hitchiner.
24
I have a couple concerns and questions I'd like to
25
bring up.
The first one, in regards to the down gradient
APEX REPORTING
Registered Professional Reporters
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':;'0
treatment system, if this proves effective in cleaning the
2
drinking water
particularly in the area of the
standards,
3
Savage Well as it exists today, but the OK Tool site can not
4
be cleaned up and continues to contaminate the aquifer, will
5
the state or the EPA eventually look to approve the Savage
6
Well as a drinking water source?
7
A second concern,
of dis,:ussi,:.n
there's been a lot
8
in regards to who is going to pay for all this.
I think it
9
would be assumed by everyone here that Hitchiner and Hendrix
10
are potentially responsible and since you classified them'as
11
PRPs in your report, so one question to leave in your minds
12
there and hopefully you'll address this in your statement,
is
13
by what logic is the EPA going to use to try to force
14
Hitchiner and Hendrix to pay for the cleanup of PCE at the
15
site when they have not used this chemical in their
pr c.dLI': t i c.n
16
pr.:II:esses.
17
Thank YC1u.
18
(Applause)
19
MR. COUGHLIN:
Thank yc.u.
20
MR. HAMLIN:
I'm Jim Hamlin with Hitchiner
21
Manufacturing.
22
I'm curious about something.
I would like ,to know
23
if you folks here are the ones that are going to make the
24
ultimate decision on this issue.
It would be pretty hard, I
25
think, to convey t~e flavor of this meeting to your bosses or
1..\
APEX REPORTING
Registered Professi~nal Reporters
-------
'1
v
'31
whoever you are going to write this down and address it to.
I
2
think it's fairly clear,
if you haven't noticed, the sentiment
3
of the people here.
And that it would be best for all
4
concerned if you accept the Hitchiner and Hendrix proposal.
S
(Appl aLlse)
6
MR. COUGHLIN:
Thank YC'LI.
7
MS. LOVEJOY:
Paula L,:,vej':'y.
8
I'm an employee of Hitchiner and I am also a
9
resident and I drink a lot of water.
10
My brother and my father both were employed by OK
11
Tool and I believe that they were all found, the four
12
companies were found responsible for pollutants before the
13
company was sold.
knl:owi ng
I find it very hard to believe,
14
that this well was going to have to be cleaned up, that they
1S
were allowed to sell and nobody wants to go to the family that
16
ended up with the money and say,
We' r e
you're responsible.
17
~ccepting responsibility for our behalf and I think it's only
18
fair, which everybody else feels too, that you're
19
responsible -- I was brought up to be responsible for
my ':own-
20
actions.
And I don't think they should be sitting on property
21
that could be sold to help pay for their share if you're going
22
to turn around, because you don't want to do that, and make us
23
all out of jobs, because why wouldn't Hitchiner want to close
24
their door and just leave.
If they're not in business at the
2S
time,
they're not going to have to pay; right?
APEX REPORTING
Registered Professional Reporters
-------
92
(Applause)
2
MR. COUGHLIN:
Thank you.
~
3
. MR. RICHARD I:
Rozario Richardi,
a Selectman of
4
Milford.
5
Hitchiner and Hendrix has been two good companies
6
and they've been real good with Milford.
And the only thing
7
I'm going to say is I hope that when you come to a solution,
8
that you use
sense.
common
9
(Applause)
10
MR. COUGHLIN:
Thank you.
11
MR. ROULE:
My name is Rene Roule.
12
I'm an employee at Hendrix.
13
I've been around this area for thirty two years.
14
I worked seven years at Hitchiner and twenty five at Hendrix
15
and I'm very concerned about what's ~oing on here.
From what
16
I can see here, the water in the ground is not going to hurt
17
~nybody except you can't drink it.
I've been doing a lot of
18
traveling camping around between here and Florida and west to
19
Arkansas,
and I think I can tell by the placement of my
20
fingers, you can drink the water, most of the time you can't
21
drink it,
I carry it with me.
22
When I came here thirty years ago, whoever told
23
you you would have to buy water in the store.
I say thirty
24
years from now I don't think we'll be able to drink any water
25
in the ground.
APEX REPORTING
Registered Professional Reporters
-------
~
~
~~
~~
I would suggest right now that you accept the plan
2
at Hendrix and Hitchiner until you find out if you can get
3
something better to clean up the water instead of just
4
guessing at it.
~
J
Thank
you.
6
(Applause)
~
I
MR. COUGHLIN:
Thank you.
6
Anybody else?
9
(No response)
10
MR. COUGHLIN:
coming
Okay, we appreciate your
11
tonight.
I know you don't like
We appreciate your
comments.
12
to hear that
answer
your questions now and we won't
we can't
13
answer your questions and that sort of thing.
That's just the
14
way the process is run.
We
We will respond
to your comments.
15
will consider them carefully as we write our Record Of
16
Decision and the responses will be there.
We understand what.
17
you're saying and we understand your
concern about Hitchiner
18
and Hendrix and we understand you're
jobs
concerned
about your
19
and community, et cetera.
It's not our desire to put any of
20
you out of a job and it's not our desire to put any company
21.
out of business.
I hope you'll believe that.
22
I will remind you that if you do wish to submit
23
written comments, and I would encourage you to do so, you have
24
until August 10th.
Please send them to the address on page 3
25
of the proposed plan.
Make sure they're postmarked by August
APEX REPORTING
Registered Professional Reporters
-------
'34
10th.
2
One 1 ast
chance for a comment, anybody else?
3
(N.:. resp.:.nse.)
4
MP. COUGHLIN:
On.:e again,
we thank Y':'LI f.:.r
': ,:.mi ng
5
and we appreciate your comments.
6
(The public hearing concluded at 8:30 p.m.)
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
APEX F~EPORTING
Registered Professional Reporters
-------
'35
CERTIFICATE OF REPORTER AND TRANSCRIBER
J
')
c.
This is to certify that the attached proceedings
:1
before: DANIEL COUGHLIN. Chief. New Hampshire Superfund Sect.
c;
4 in the Matter of:
,.
.1
PUBLIC HEARING RE:
6
SAVAGE MUNICIPAL WATER SUPPLY
SUPERFUND SITE
7
8
9
Place:
10
Mi 1 f,:,rd,
New Hampshire
Date:
11
July 2'3, 1991
12 were held as herein appears,
and that this is the true,
13
accurate and complete transcript prepared from the notes
14 and/or recordings taken
of the above entitled proceeding.
15
16
17 Stephen Madi
Reporter
08/05/91
Date
18 Laura Madi
19 Transcriber
08/05/91
Date
20
21
22 :
23
24
25
APEX REPORTING
Registered Professional Reporters
-------
ATTACHMENT C
-------
greeing that prostitution is
in the Queen City - de-
"extremely high" Reed's
,hat 100 prostitutes were
,e city. '
! day tha~ they spoke, se-
,ester women were arrested, ,
~~~~=ed~~::~ Beware: AlasltaIl W at~r Too' Cleari:~:,::
~ wearing rubber gloves, as By PAUL HARVEY quirement.". ' ., ,Now... .'P' ~ ~ ~i
~ly do. Anchorage, Alaska, has some' ,; . So Anchorag~ is in ,trouble because,: " This p.ractice also ~se~ the amount; , "
llcs aside. I t does seem of the best drinking water Its waste water IS too clean! ':'", of organic waste pounng Into Cook In- . ; ,
s remarks focused atten- " anywhere. It may be some ot And because Congress is unlikely to~', let. Anchorage, to comply ~th wha~ l
' problem marvelously. At. the cleanest, po"", on Earth.. do the ..n,'ble Wng, the city of An- " . the b.....ue...... demands, "poDuUng , .;:{
ast. they heightened pub- ' But Alaska wanted to be a chorage is (orced ~ do something that, , " its own harbor ~th thousands of ~ "
. --J' Fi 'state." ' , ' sounds utterly foolish. " pounds of orgaruc waste. , . ;?
.ss. 1m nnegan, Alaska Is now a state. "', '", '."., Anchorageisp~rpose~ypoUutingits: 'I'venotyet\mentionedthefactthat.i ,". j)
And the federal government in ;, ' water. Anchorage IS bUYIng from can- , before beina allowed to dump the:! 1
:,ons' '" , Washington, in its infinite wisdom, de-, neries bones and fish viscera which or.:, ground-up fish .Iudge into the city's 'I" ; ~ : I
crees that "municipalities must re. :, dinarily go into fertilizer and is dump- , waste-water system, it must first be ',i: . I '
move at least 30 percent of the or,anic ing this garbage into the city' ,;, ,;, hauled to and from a reduction plant in: " "':
' bead of GUD Owners of material from its sewage.". , waste-water system - so that 30 per- ":,,: Seward at an added cost of 2 to 5 cents i i. "
Ishire for daring to back That's an order! , , " 'I: cent of it can be removed.. thus to meet" a pound. , ," . . ! " i' J
t I th I t The National Clean Water kt, as '. . federal government requirements. . :';' And with all these accommodations. i I
'onen D e as carn- amended in 1987 by the Congress, spe-, ' To ~emove 3.0 percent of the o~ganlc ';' the city mIght yet 111n afoul of the A-' ,
. cities that cities with only primary sew- ,matenal from Its present ~ater, An-, ',' lice-in-Wonderland federal law. Come,) , . , . .. ' .
ot bitter. Rubega. told The age treatment plants mu~t remo~e at cho~~g.~,:-:o~~ ~ave ~ ~~il.d_~ ~eco_~d- ':: breaku~ time, or when fall floods )-Ilt, iJ :}::; f', \
ler. WeU may King hope least 30 percent of orgamc material,. . a..'Y w~wwbe .....~.~en. p.an. G, G COSo ot u there will be so much clean water pour~1 ': ,:. ' ;
:a's friends are similarly. from theirsewage. , at least $100 ~on. ,,:,' :~!~ I. Ing into Anchorage sewers that they'U ~ " .'
!/here personal vendettas Anchorage has no organic material',j " .: In~.~ead the city of Anchorage is ",-..,:" . have to truck in garbage from landfills ;
in Its water. ',' . " " "~:" dumpmg 5,000 pounds of ground-up IJ',~ and dump that garbage into the storm I
ned. what goes around ," Nonetheless, Carla Fisher otthe En.,:,i fish parts Into its waste water a day SO! ~ drains, thus to keep the runoff dit1d :
,es around. " , vironmental Protection Agency says -,,; '~' that 30 percent of it can be removed -;'1,; enough so that the 30 ~rcent remtfval j
--Jim Finnegan the 30 oercent 1111," i" "a flat-out re- , ~, :'",: thus to comDly with the federal law. . "~ ,requirement can be mtL , ",~, ::; .
.. . , , " :',: .',',',' .,',:",,, "',.-~, ',," ,. ':, '" ',,;,::' .~..
iif/~i~
.RBONNEAU "in the broad
, sense," he
ver have been elected to
, event, Swett may look at it
Sure, Abraham Lincoln did
IOU can't fool all of the pea- ,
time. " ,
Ie never said that you
'I. --Jim Finnegan
nt
"q'
. '
tator 01' the Philippines; Saddam Hussein; arms dealer
Adnan Khashoggi; and the Medellin d111g cartel. Accord-
ing to Time, within the bank was a "black network"
of 1,500 which functioned as a "global intelligence opera-
tion and a Mafia-like enforcement squad," kidnapping, '
beating and perhaps murdering to protect the secrets ot '
BCCl's involvement in fraud, bribery; money launder- ,',
ing, gun111nning and narcotics. ' " ,
In Miami, prosecutors are looking into BCCI ties to '
Cent111st Savings & Loan, whose collapse could cost U.S. '
taxpayers $2 billion. Centrust owner David Paul raised
big bucks, for Democrats, including Sen. John Keny. .
the lead senator in investigating BCCI. .
Most interesting is a charge by an ex-BCCI official 'to
an ex-Senate investigator that BCCI brought millions
into Washington to bribe U.S. officials, with particular' ,
"targets" in Congress. To do what, is unrevealed. Accord-
ing to a story quoted by AP, the head of the criminal
division at Justice is also investigating an "array of of-
fenses involving BCCI and possibly linking international
terrorists and dnig barons to powerful people in the U.S.
government.",
ot to'irst American." " ;, :,' ,;., "", ., .
In scandals of such magnitude, there comes a moment
whe~ the rats decide the ship is sinking and the great ,
scramble begins, when folks who have only been touched,
or mildly tainted come forward - to declare themselves
on the side of the "good guys," and spill their guts about" ,
' old comrades and ex-patrons. We appear, after years of .
back-room investigation, to have reached that moment '."J
Regulators, prosecutors, investigators in the executive, :.'.::
and legislative branches have caught the scent, all the ;,
media are now in the hunt, the pack of hounds is grow-
. Ing geometrically; the hares are on the run.
, ,
The BCCI scandal will take years to unfold. But, al- i. ~ - ,
ready, with ex-U.S. Presidents and prime ministers, ex-; : - '.
senators and defense secretaries, Gulf sheiks and Saudi,: '
intelligence officers, Third World despots and d111g : .'
dealers, arms traffickers and Mideast terrorists involved,
we are surely seeing the first great scandal of The New ,
' World Order. A certain result will be that Americans will '
see that order as irredeemably corrupt and ask again:, '
Exactly who and what is the United States defending in:: .
these nether regions of the world? , ~, :.
:)
;!
, J' ,
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, ,
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-------
I) 9/17' . 91
09/17.'?1 13: 45
09:30 FAX 206 ~~2 01~8
US EPA PA DIll, BOSTON I'IA
R£GIO~AL .~DYr~
J03
Unlt8d Steel
I!mInmmema/ "~n
.g~
41 004.'005
.
~n10
1 a60 Slm Avenue
SecII. WI+. 88101
AlU1c8
IGIftO
Oregon
Waal1lnQtan
&EPA
Sep~ember 13, 1991
Reply To
Attn Of:
50-143
Honorable Warren Rudman
U.S. Senate
Hart S.na~. ot~ico Building
Washiniton, D.C. 20S10
DQ&~ Senator Rudman:
~is le~~ar is in response ~o inquiries from your
gonsti~u8nt& reqardini Paul Harvey's ar~1cl. a~ou~ the city of
Anchorage. .
Hr. Harvey' 8. article i. accura1:. in 8't:atinq that 01 t1e8 such
a. Anchoraq., whi~ provide prim~ treaaant, muat: remClve a
minimum o~ 30% ot ~. orqanic material trom their ..wa~.. This
requirement was established. by Congress, no~ t:!t8 Environmental
Protection Agency CEPA), in section 301(h) of 1:he Clcum Water
Act: Amendments o~ 1987.
,
The a~ic18 &180 ac~~tely s~t.. that Anchora98 ~y
occasionally have dittioul~y moetin~ the percent ~~oval
~equirem.n1: c!urinq tallilS or the year when the in:fluent 1:0 their
treatment plant is 18.. -concentrated (i..., in the aprinq, when
snowmel1: a.nd rain water leak into 'the tr.atm.n~ system). Thi8
is beg.use the 18.8 concentrat.~ a solution i., ~. mora
di~~icult it ia to ramov. a tixad pe~cantaqe ot the pollutant..
Data submittad by the cii:y, however, shows that they hava bean
achieving' 30t :oemoval or J:)8ttar for ove~ a. yaar, including..
durinq sprinq. . . .
Paul Harvey tnakaa several state=ent8, however, that are
clearly in error., Obviously, he is WZ'onq wh.n h. states t:hat
"AnQhoraqe has no organic:: ma~er1al in its vater. n Thi.
stat:ement may apply to the c:1:t:y IS c!rinkinq water, but all
sewage contain. orqanicm~tar1al.
Accord.inq to 1:h.. city's con8ultant, M%'. Harvey i. also in
error in statinq t:hat the city i8 ~uyin9' tish wasta trom
processing plant.. The city is accaptinq :fiSh waste, but it is
at the request of the processors. This is not, as Mr. Harvey
contends, "purposely pollutinq" the city's watBJ:' in orc:ier t.o
raee't ~ederal requ1.ramen-ca. By that J.oC;1c, any city that
accepts do~estic and in~ustr1al wasta into its sewer systQ~ i.
-------
oa,.n.lIl
09/17'91 13:~6
09:30 FAX zoe ~~2 Ol~9
us EPH PH LO I I), EOSTOt,j MH
PEGIO~AI:. .olDlIn
J0.J
:aJ 005 I 005
.,
u
Ancboraqe has been approachin~ the problem o~ the percent
removal require=ent froDi two diractions.. On8, they are
attemptinq to locate pipe sections rec81vinq exceoaive
infiltration and inflow (fresh water leaJc1nq into 'the sewer
trom ground-witter or illeg-ally connect.~ roof dra1ns, eta.) and
corrcu:t:i.ng- the problam. f1 tits source.. And two, they Are
exp1Qr1n~ ways to more ettectively treat the diluted wast.s in
the treatment plan~ in order to meet the statutory removal
requirements.. As indicated above, these measures hava been
8uccc~stul in tha't the requir8ments have been m.t over the past
year.. Even with futura qt."cwth, Anc::hora98 will be &1>1. 'to .
main1::.in 30' raoval ot orqan1c material thrcuqh up;1:'a41n; its
primlLry treatment plant, without bavinq to construct a $100
mi11ion ..con~.ry treatment plant.
~he Paul Harvey account ot the Ahchoraqa situation makes
~Qod reading, and tends to confirm the werst fears of. the
unin1~CJrm.c:i agout how certain 90vernmant rul.. are appliec1. .
Non.tn.leaa, Mr. Harvey's account is simply not ~ased on all
the 1:acts. Reqion 10 has been workin'i wi tb the. c11:y ot
Anchoraq. on thia issue tor Bo~e time, and is contidant the
tedeI~al requirements can ba applie4 in a tasMen that can De
met by the c::i~, without resorting' to soma nonsensical play
such as dumpi'nq orqan1c ma~.rial into storm ~a1ns (whiCh,
incidlantally, WQuld not Bolva their proJ)lem, as their storm
5eWe:l:"II are aeparata from thai. aan.itary s.wers).
L.
4
Thank you for brinqinq your concern to our a:ttentlen.
Please let me know if we can provide additional information on
this issue.
Sincerely,
Ptt~ I
Dana A. Rasmusseft V
aevional Admi~i.~ator
,.
-------
ATTACHMENT D
-------
Figure 1
Savage Municipal Water Supply Site Groundwater Contamination
u
@
<)
Legend
Drawing Not to Scale
"-'
1 OK Tool
2 Hitchiner Manufacturing
3 Hendrix Wire & Cable
4 New England Steel Fabricators
..
,
I
..-I
Hitchiner-Hendrix
Discharge Stream
Iii ~~~~~a~~~u~~~:ter
J
Total VOC Groundwater
Contamination Plume
(concentrations in parts
per billion) .
Savage Municipal Water Supply Superfund Site
-------
SAVAGE MUNICIPAL WATER SUPPLY SUPERFUND SITE
APPENDIX E
-------
()
Savage Municipal Water Supply
L.
"
v
NPL Site Administrative Record
Index
.
Compiled: July 12, 1991
ROD Signed: September 27, 1991
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
~
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
-------
Introduction
This document is the Index to the Administrative Record for the September 27, 1991 Record
of Decision (ROD) for the Savage Municipal Water Supply National Priorities List (NFL) site.
Section I of the Index cites site-specific documents and Section II cites guidance documents used by
EP A staff in selecting a response action at the site.
The Administrative Record is available for public review at EP A Region I's Office in Boston,
Massachusetts, and at Wadleigh Memorial Library, 21 Nashua Street, Milford, New Hampshire.
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
-------
Section I
-------
1.0
2.0
3.0
ADMINISTRATIVE RECORD INDEX
for the
Savage Municipal Water Supply NPL Site
(ROD Signed: September 27,1991)
Pre-Remedial
1.6
Hazard Ranking System (HRS)
1.
"Hazard Ranking System," EPA Region I (June 10, 1983).
Removal Response
2.1
Correspondence
1.
Memorandum from Pi- Yun Tsai and Clara Chow, EPA Region I to John
Moebes, EPA Region I (February 18, 1983). Concerning analytical results of
the Savage Municipal Well and the trailer homes well.
Memorandum from Pi-Yun Tsai and Clara Chow, EPA Region I to Richard
Leighton, EPA Region I (March 9, 1983). Concerning the analytical results of
the February 17-22, 1983 well sampling.
2.
2.9
Action Memoranda
1.
Memorandum from Lester A. Sutton, EPA Region I to EPA Headquarters
(March 9, 1983). Concerning the request to initiate an immediate removal action
at the site.
Memorandum from RD. Van Cleave, EPA Headquarters to Steve Novick, EPA
Region I (March 29, 1983). Concerning authorization to proceed with
immediate removal action at Milford Trailer Park.
Memorandum from William N. Hedeman Jr., EPA Headquarters to Lee M.
Thomas, EPA Headquarters (March 29, 1983) with the anached fact sheet.
Concerning Region I's request for an immediate removal action at the site.
2.
3.
Remedial Investigation (RI)
3.1
Correspondence
1.
Lener from Merrill S. Hohman, EPA Region I to Herbert Whiting, State of-New.
Hampshire Department of Environmental Services (August 9, 1985).
Concerning notification that Savage Municipal Water Supply is a proposed
Superfund Project to be funded by EPA or a potentially responsible party.
Memorandum from Paula S. Cappello, HMM Associates, Inc. to Charles
Purfort, EPA Region I (November 23,1988). Concerning ttansmittal of the
pages to be replaced in the October 1988 "Project Operations Plan," HMM
Associates, Inc.
Lener from James B. Zeppieri, State of New Hampshire Department of
Environmental Services to Robert Scharmen (May 19, 1989). Concerning
analysis of the water sample taken on April 14, 1989.
2.
-------
Page 2
3.1
Correspondence (cont'd.)
4. Letter from James B. Zeppieri, State of New Hampshire Depanment of
Environmental Services to Richard A. Goehlen, EPA Region I (May 19, 1989).
Concerning notification that additional groundwater sampling will be done
during the last week in May 1989.
5. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 21,1989). Concerning the topics of discussion
at the May 22, 1989 meeting.
6. Letter from Richard A. Goehlen, EP A Region I to Richard C. Cote, HMM
Associates, Inc. (July 10, 1989). Concerning the groundwater monitoring wells
to be sampled during the "Phase IT Groundwater Sampling Program."
7. Letter from Richard A. Goehlert, EP A Region I to Richard C. Cote, HMM .
Associates, Inc. (July 18, 1989). Concerning the installation of piezometers and
staff gages to identify levels of groundwater. .
8. Letter from Richard A. Goehlen, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (August 1, 1989). Concerning rock well installation.
9. Letter from James B. Zeppieri, State of New Hampshire Depanment of
Environmental Services to Richard A. Goehlen, EPA Region I
(February 16, 1990). Concerning data gaps in the groundwater contour
mapping of the northern side of the Souhegan River.
10. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane, .
Graf, Raulerson & Middleton (Attorney for the PRP Group) (April 18, 1990).
Concerning piezometer installation on the Hayward property and the attached
groundwater contour map.
11. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) ,
(December 24, 1990). Concerning funher review of surface water ponions of
the Remedial Investigation, reevaluation of seismic refraction data, and the
attached "Comments on Surface Water Chapter and Appendices."
12. Letter from Bradley W. Schwab, Environmental Science & Engineering, Inc. to
Richard A. Goehlen, EPA Region I (March 20, 1991). Concerning explanation
of the changes made in the Revised Health Risk Assessment and the attached
"Appendix I - Alternative Exposure Scenarios," Environmental Science &
Engineering, Inc. (March 20, 1991).
13. Letter from Bradley W. Schwab, Environmental Science & Engineering, Inc, to
Richard A. Goeblen, EPA Region I (April 2, 1991). Concerning the transmittal
of the pages to be insened into the March 20, 1991 "Baseline Health Risk
Assessment, II Environmental Science & Engineering, Inc.
14. Cross-Reference: Letter from Richard A. Goeblen, EPA Region I to Gregory
H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for the PRP Group)
(April 26, 1991). Concerning confnmation that the PRP Group will be unable
to meet the May 15, 1991 deadline for the Feasibility Study Report, that an .
extension until May 22,1991 is acceptable, and that changes to the Remedial
Investigation Repon are minimal [Filed and cited as entry number 4 in 4.1
Correspondence].
15. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 18, 1991). Concerning transmittal of the Final
Remedial Investigation Report and notification that the PRP Group objects to
many of the changes that were required by EP A Region I.
16. Memorandum from Ken Brown; EP A Region I to Richard Willey, EP A
-------
Page 3
3.2
Sampling and Analysis Data
1. Memorandum from John A. Golden Jr., NUS Corporation to David J. Newton,
EPA Region I (January 20,1986). Concerning explanation of the attached
laboratory results for acetophenone and methyl styrene analysis of groundwater
samples collected on May 22, 1985.
2. Memorandum from John A. Golden Jr., NUS Corporation to David J. Newton,
EPA Region I (February 27,1986). Concerning transmittal of the attached CLP
sampling results from the O.K. Tool Company, Inc. monitoring wells and test
pit. .
3. Letter from James B. Zeppieri, State of New Hampshire Department of
Environmental Services to Richard A. Goehlert, EPA Region I
(August 17, 1989). Concerning transmittal of the attached analysis of
groundwater samples taken during Round n sampling obtained by HMM
Associates, Inc. and split with State of New Hampshire Department of
Environmental Services. .
4. Letter from Richard A. Goehlert, EP A Region I to Richard C. Cote, HMM
Associates, Inc. (August 17, 1989). Concerning the review of the proposed
surface water and sediment sampling and the attached Letter from Kenneth
Finkelstein, U.S. Department of Commerce National Oceanic and Atmospheric
Administration to Richard A. Goehlert, EPA Region I (August 7, 1989). .
5. "Split Sample Survey," Roy F. Weston, Inc. (August 29, 1989).
6. Letter from Shawne M. Rodgers and Joseph D. Mastone, Roy F. Weston, Inc.
to Dennis Gagne, EPA Region I (September 6, 1989). Concerning transmittal
of the attached validation on the inorganic analytical sample collected by Roy F.
Weston, Inc.
7. Letter from Vicki Maynard and Joseph D. Mastone, Roy F. Weston, Inc. to
Dennis Gagne, EPA Region I (September 12,1989). Concerning transmittal of
the attached validation on the organic analytical sample collected by Roy F.
Weston, Inc.
8. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlert, EPA Region I (October 3,1989). Concerning the proposal to perform
additional soil sampling at the site and the attached sampling map.
9. Letter from Richard A. Goehlert, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (October 18,1989). Concerning review of the October 3,1991
proposal to perform additional soil sampling at the site.
10. Letter from Richard A. Goehlert, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group)
(October 26,1989). Concerning transmittal of the attached results of the Phase
II Groundwater split sampling.
11. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (November 1, 1989). Concerning the response to
EPA's comments on the October 3, 1989 proposal to perform additional soil
sampling at the site.
12. Letter from James B. Zeppieri, State of New Hampshire Department of
Environmental Services to Richard A. Goehlert, EPA Region I
(January 22,1990). Concerning the attached results of the November and
December 1989 and January 1990 samples split with HMM Associates, Inc.
The maps associated with the record cited as entry number 13 are oversized and may
be viewed, by appointment only, at EPA Region I in Boston, Massachusetts.
13. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EP A Region I (February 6, 1990). Concerning transmittal of the
attached draft results of the pump test of the Hitchiner Manufacturing Company
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..
Page 4
3.2
Sampling and Analysis Data (cont'd.)
14. Letter from James B. Zeppieri, State of New Hampshire Department of
Environmental Services to Richard A. Goehlen, EPA Region I
(February 14, 1990). Concerning the attached January 1990 split sample
results.
15. "Comparison of Savage Well Split Sampling," Roy F. Weston, Inc.
(January 26, 1990 - Revised February 16, 1990).
16. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (February 20, 1990). Concerning a summary of the
additional soil sampling done at the site.
17. Memorandum from Patricia Bickford, State of New Hampshire Department of
Environmental Services to James B. Zeppieri, State of New Hampshire
Department of Environmental Services (February 28, 1990). Concerning
clarification of testing done to samples numbered 140725,140726,140565, and
140566. .
18. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (March 28, 1990).
Concerning transmittal of the attached results from the split samples taken from
the bedrock wells.
19. Letter from James B. Zeppieri, State of New Hampshire Department of .
Environmental Services to Richard A. Goehlen, EPA Region I (May 21, 1990).
Concerning fourth quanerly groundwater sampling round results.
20. "Revised Data Validation Letter Repon - Organic Case 11934," Camp Dresser &
McKee (November 27, 1989 - Revised September 24, 1990).
21. Lener from Richard A. Goehlen, EPA Region I to Mark O. Hueburger, HMM
Associates, Inc. (November 6, 1990). Concerning review of the third quarterly
sampling round submined October 16,1990.
22. Memorandum from Mark O. Hueburger, HMM Associates, Inc.to Richard A.
Goehlen, EPA Region I (February 25, 1991). Concerning December 1990
quarter sampling and the anached analytical results from the recent groundwater
sampling round at the site.
Analysis of the State of New Hampshire split sampling is located in Appendix 35 of
the June 1991"Remediallnvestigation Report," HMM Associates, Inc. which is filed
and cited in 3.6 Remedial Investigation (RI) Reports. Other split sampling data may
be viewed, by appointment only, at EPA Region I in Boston, Massachusetts.
3.3
Scopes of Work
1.
Memorandum from Roben 1. Flatley, HMM Associates, Inc. to Savage
Municipal Water Supply File with attached "Table I Target Compounds to be
Identified During the Savage Well Air Investigation - Phase II" and "Figure 1
Phase II Sampling Locations" (September 28, 1988). Concerning the Scope of
Work for the Phase II Air Investigation at the site.
Memorandum from Mark Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EP A Region I (March 22, 1990). Concerning the scope of work for
additional hydrology studies to be conducted at the site;
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Page 5
3.4
Interim Deliverables
Repons
1.
Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (October 13, 1989). Concerning transmittal of the
attached "Draft Subtask SE - Surface Water and Sediment Sampling - Phase n,"
HMM Associates, Inc.
"Draft Baseline Health Risk Assessment Repon," Buonicore-Cashman
Associates (October 31, 1989).
"Savage Well Treatability Study - Phase I - Technology Assessment," HMM
Associates, Inc. (October 1989). .
2.
3.
The reports cited as entries numbers 4 to 8 are oversized and may be viewed, by
appointment only, at EPA Region I, Boston, Massachusetts.
4. "Savage Well Treatability Study - Air Stripping Computer Modeling Data -
Volume I," HMM Associates, Inc. (October 1989).
5. "Savage Well Treatability Study - Air Stripping Computer Modeling Data -
Volume n," HMM Associates, Inc. (October 1989).
6. "Savage Well Treatability Study - Air Stripping Computer Modeling Data - .
Volume Ill," HMM Associates, Inc. (October 1989).
7. "Savage Well Treatability Study - Air Stripping Computer Modeling Data-
Volume N," HMM Associates, Inc. (October 1989).
8. "Savage Well Treatability Study - Granular Activated Carbon Computer
Modeling Data," HMM Associates, Inc. (October 1989).
9. "Ecological Risk Assessment," The Cadmus Group, Inc. (August 1, 1990).
10. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (November 1, 1990). Concerning transmittal of the
attached "Revised Draft of RI Section 3.2 - Surface Water Hydrology."
11. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (February 25, 1991). Concerning transminal of the
attached updated "Revised Draft of RI Section 3.2 - Surface Water Hydrology"
and the Response to EPA's comments Dated December 12,1990 on the
November 1, 1990 "Revised Draft of RI Section 3.2 - Surface Water
Hydrology."
12. "Baseline Health Risk Assessment," Environmental Science & Engineering, Inc.
(March 20, 1991).
13. Cross-Reference: "Appendix I - Alternative Exposure Scenarios,"
Environmental Science & Engineering, Inc. (March 20, 1991) [Filed and cited as
an attachment to entry number 12 in 3.1 Correspondence].
14. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Rich~d A.
Goehlert, EPA Region I (May 3,1991). Concerning the transminal and
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Page 6
3.4
Interim Deliverables (cont'd.)
Comments
15. Letter from Richard A. Goehlert, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (March 7, 1990).
Concerning the following attached comments on the October 31, 1989 "Draft
Baseline Health Risk Assessment Report," Buonicore-Cashman Associates.
A. Comments Dated February 14, 1990 from Margaret McDonough, EPA
Region I on the October 31, 1989 "Draft Baseline Health Risk Assessment
Report," Buonicore-Cashman Associates.
B. Comments Dated December 19, 1989 from The Cadmus Group, Inc. on
the October 31, 1989 "Draft Baseline Health Risk Assessment Report,"
B uonicore-Cashman Associates.
C. Comments from EP A Region I on the October 31, 1989 "Draft Baseline
Health Risk Assessment Report," Buonicore-Cashman Associates. .
16. Comments Dated April 16, 1990 from Thomas F. Speth, EPA Risk Reduction
Engineering Laboratory on the October 1989 "Savage Well Treatability Study,"
HMM Associates, Inc.
17. Comments Dated April 16, 1990 from Jeffrey Q. Adams, EPA Risk Reduction
Engineering Laboratory on the October 1989 "Savage Well Treatability Study,"
HMM Associates, Inc. .
18. Letter from Mark C. Rouralis for Gregory H. Smith, McLane, Graf, Raulerson
& Middleton (Attorney for the PRP Group) to Richard A. Goehlert, EPA
. Region I (January 18, 1991). Concerning notification that the PRP Group has
no comments on the August 1, 1990 "Ecological Risk Assessment," The
Cadmus Group, Inc.
19. Comments Dated March 29, 1991 from Richard A. Goehlen, EPA Region I on
the March 20, 1991 "Baseline Health Risk Assessment," Environmental Science
& Engineering, Inc.
20. Comments Dated May 14, 1991 from Richard A. Goehlen, EPA Region Ion the
May 3, 1991 fmal Remedial Investigation revisions from HMM Associates, Inc.
Responses to Comments
21. Response Dated March 20, 1991 from Environmental Science & Engineering,
Inc. to the March 7, 1990 EP A Region r Comments on the October 31, 1989
"Draft Baseline Health Risk Assessment Report," Buonicore-Cashman
Associates.
22. Cross-Reference: Response Dated February 25, 1991 from Mark O. Heuberger,
HMM Associates, Inc. to the December 24, 1990 EPA Region I Comments on
the November 1, 1990 "Revised Draft of RI Section 3.2 - Surface Water'
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3.7
Page 7
3.6
Remedial Investigation (RI) Repons
Repon
1.
Cross-Reference: Portions of the Draft Remedial Investigation Repons were
submitted to EPA Region I in sections as Interim Deliverables and are flIed and
cited in 3.4 Interim Deliverables.
The maps associated with the record cited as entry number 2 are oversized and may
be viewed, by appointment only, at EPA Region I in Boston, Massachusetts.
2.
3.
4.
5.
6.
"Draft Remedial Investigation," HMM Associates, Inc. (November 14, 1989).
"Draft Remedial Investigation," HMM Associates, Inc. (February 5, 1991).
"Final Remedial Investigation - Volume 1," HMMAssociates, Inc. (June 1991).
"Final Remedial Investigation - Volume 2 - Appendices 1-15," HMM
Associates, Inc. (June 1991).
"Final Remedial Investigation - Volume 3 - Appendices 16-29," HMM
Associates, Inc. (June 1991). .
"Final Remedial Investigation - Volume 4 - Appendices 31-36," HMM
Associates, Inc. (June 1991).
"Final Remedial Investigation - Volume 5 - Plates 1-6," HMM Associates, Inc.
(June 1991).
7.
8.
Comments
9. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson, & Middleton (Attorney for the PRP Group) (April 11, 1990).
Concerning explanation of the following attachments:
A. Comments Dated April 9, 1990 from Richard Willey, EPA Region I on the
November 14,1989 "Draft Remedial Investigation Repon," HMM
Associates, Inc.
B. Comments on the November 14, 1989 "Draft Remedial Investigation
Repon," HMM Associates, Inc. .
10. Comments Dated August 9, 1991 from Mark C. Rouvalis, McLane, Graf,
Raulerson & Middleton (Attorney for the PRP Group) and Thomas S. Burack,
Sheehan, Phinney, Bass & Green (Attorney for the PRP Group) on the changes
that the PRP Group were required to make to the February 5, 1991 "Draft
Remedial Investigation," HMM Associates, Inc. .
Responses to Comments
11. Response Dated July 12, 1990 from Mark O. Heuberger, HMM Associates, Inc.
to the April 11, 1990 Letter from Richard A. Goehlen, EPA Region I to Gregory
H. Smith, McLane, Graf, Raulerson, & Middleton (Attorney for the PRP
Group) transmitting comments on the November 14,1989 "Draft Remedial
Investigation Repon," HMM Associates, Inc.
Work Plans and Progress Repons
1.
Cross-Reference: "Work Plan for Remedial Investigation/Feasibility Study-
Volume I: Technical Scope of Work," Camp Dresser & McKee Inc.
(June 20, 1986) [Filed and cited as the attachment to the record cited as entry
number 1 in 10.7 EPA Administtative Orders].
"Health and Safety Plan," HMM Associates, Inc. (April 24, 1987).
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Page 8
3.7
Work Plans and Progress Repons (cont'd.)
3.
"State Oversight Suppon of Field Investigations for the Remedial
Investigation/Feasibility Study - Project Operations Plan," State of New
Hampshire Department of Environmental Services (August 1988).
"Project Operations Plan - Volume I," HMM Associates, Inc. (October 1988 -
Updated November 23, 1988).
"Project Operations Plan - Volume II," HMM Associates, Inc. (October 1988).
4.
5.
The maps associated with the record cited as entry number 6 are oversized and may
be viewed, by appointment only, at EPA Region I in Boston, Massachusetts.
"Project Operations Plan - Air Investigation - Subtask 2D," HMM Associates,
Inc. (October 1988). .
"Revised Work Plan - Ecological Risk Assessment," The Cadmus Group, Inc.
for CDM Federal Programs Corporation (January 2, 1990).
The records cited as entries number 8 through 30 are modifications to the
October 1988 "Project Operations Plan," HMM Associates, Inc.
6.
7.
8. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (July 26, 1989). Concerning an addendum to the
Monitoring Well Installation Program section of the October 1988 "Project
Operations Plan," HMM Associates, Inc.
9. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (August 14, 1989). Concerning an addendum to the.
Monitoring Well Installation Program section of the October 1988 "Project
Operations Plan," HMM Associates, Inc.
10. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (August 31,1989). Concerning the revised surface
water and sediment sampling program of the October 1988 "Project Operations
Plan," HMM Associates, Inc.
11. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (October 3, 1989). Concerning the revised locations
for the deep bedrock wells.
12. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlert, EPA Region I (October 3, 1989). Concerning an addendum to the
Monitoring Well Installation Program section of the October 1988 "Project
Operations Plan," HMM Associates, Inc.
13. Memorandum from Richard Willey, EPA Region I to Richard A. Goehlen, EPA
Region I (October 16, 1989). Concerning comments on the proposed
modifications to the October 1988 "Project Operations Plan," HMMAssociates, .
Inc.
14. Memorandum from Richard A. Goehlen, EPA Region I to Richard C. Cote,
HMM Associates, Inc. (October 18, 1989). Concerning comments on the
proposed modifications to the October 1988 "Project Operations Plan," HMM
Associates, Inc.
15. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (November 1,1989). Concerning responses to the
October 18,1989 EPA comments on the proposed modifications to the
October 1988 "Project Operations Plan," HMM Associates, Inc.
16. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (November 21, 1989). Concerning the wells denoted
in the October 1988 "Project Operations Plan," HMM Associates, Inc. for
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Page 9
3.7
Work Plans and Progress Repons (cont'd.)
17. Letter from Richard A. Goehlen, EP A Region I to Richard C. Cote, HMM
Associates, Inc. (December 7, 1989). Concerning review of the
November 21, 1989 submittal regarding the first quarterly sampling round.
18. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (December 7, 1989). Concerning the submittal of the
proposal for additional monitoring well locations.
19. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group)
(December 11, 1989). Concerning the request that five house wells be sampled
to determine whether or not drinking water has become contaminiued.
20. Letter from Richard A. Goehlen, EP A Region I to Richard C. Cote, HMM
Associates, Inc. (December 13, 1989). Concerning review of the
December 7, 1989 letter detailing additional monitoring well locations.
21. Letter from Richard A. Goehlen, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (December 13, 1989). Concerning notification that several
wells need to be sampled again for the first quarterly sampling round.
22. Memorandum from Richard C. Cote, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (December 21, 1989). Concerning the proposed
aquifer pump test in conjunction with the shutdown and restart of the Hitchiner
Manufacturing Company production well. .
23. Letter from Richard A. Goehlen, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (January 3, 1990). Concerning clarification of the location of
the additional monitoring wells.
24. Memorandum from Mark O. Heuberger for Richard C. Cote, HMM Associates,
Inc. to Richard A. Goehlen, EPA Region I (January 23, 1990). Concerning the
technical scope of work for the soil column flushing studies at the site.
25. Letter from Richard A. Goehlen, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (February 5, 1990). Concerning review of the
January 23, 1990 technical scope of work for the soil column flushing studies at
the site.
26. Memorandum from Mark O. Heuberger for Richard C. Cote, HMM Associates,
Inc. to Richard A. Goehlen, EPA Region I (March 6, 1990). Concerning the
proposed wells to be sampled in the second quarterly sampling round.
27. Letter from Richard A. Goehlen, EPA Region I to Richard C. Cote, HMM
Associates, Inc. (March 22, 1990). Concerning review of the March 6, 1990
submittal concerning the second quarterly sampling round.
28. Memorandum from Mark Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (April 13, 1990). Concerning the acknowledgement of
EPA's comments on the January 25, 1990 "Soil Column Flushing Study Scope
of Work, If HMM Associates, Inc.
29. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EP A Region I (May 17, 1990). Concerning the attached table
summarizing the laboratory analytical results for the second quarterly sampling
round.
30. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (January 22, 1991). Concerning the proposed
approach for responding to EP A 's request for reevaluation of the seismic
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4.0
.
Page 10
Feasibility Study (FS)
4.1
COJTespondence
1. Letter from Richard A. Goehlen, EP A Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (March 28, 1991).
Concerning a panial summary of the March 26, 1991 meeting and the additional
sampling that needs to be done at the site.
2. Letter from Charles M. Losinger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (April 10, 1991). Concerning preliminary analysis of
MM-9A, MM-9B, and MM-lO as three additional cleanup alternatives.
3. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (April 22, 1991).
Concerning the analysis of the extraction of contaminated water at three locations
at the site as an alternative cleanup method.
. 4. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (April 26, 1991).
Concerning confmnation that the PRP Group will be unable to meet the
May 15, 1991 deadline for the Feasibility Study Report, that an extension until
May 22, 1991 is acceptable, and that changes to the Remedial Investigation
Repon are minimal.
5. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (May 6, 1991).
Concerning sampling information from the eastern portion of the study area and
transmittal of the attached sampling map and April 29, 1991 Letter from James
B. Zeppieri, State of New Hampshire Department of Environmental Services to
Richard A. Goehlen, EP A Region I.
6. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, Mclane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (May 10, 1991).
Concerning guidance regarding future changes to the remedy.
7. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson & Middleton (Attorney for the PRP Group) (May 15, 1991).
Concerning the review of the cost estimate revisions for the treatment plant
operators, long term monitoring~ and the metals removal. .
8. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EP A Region I (May 24, 1991). Concerning the response to the
May 15, 1991 Letter from Richard A. Goehlen, EPA Region I to Gregory H.
Smith, McLane, Graf, Raulerson & Middleton (Attorney for the PRP Group)
and the attached revised cost estimates for the Feasibility Study.
9. Letter from Paul F. Killian, Kate Schweitzer, John J. Hagopian, Roy F. Weston
to Scott Clifford, EPA Region I (June 4, 1991). Concerning the request for
information in order to complete evaluation of chromium data.
10. Letter from Richard A. Goehlen, EPA Region I to Gregory H. Smith, McLane,
Graf, Raulerson, & Middleton (Attorney for the PRP Group) (June 19, 1991).
Concerning confmnation of the July 11, 1991 Public Meeting and the
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4.2
Page 11
Sampling and Analysis Data
1.
Memorandum from Deborah A. Szaro, EPA Region I to Richard A. Goehlen,
EPA Region I (May 23, 1991). Concerning the hexavalent chromium results for
the soil samples taken from the site and the following attachments:
A. Lener from Paul F. Killian, Kate Schweitzer, John J. Hagopian, Roy F.
Weston, Inc. to Dennis Gagne, EPA Region I (May 22, 1991).
B. Telephone Notes Between Paul Killian, Roy F. Weston, Inc. and Gary
Hawonh, State of New Hampshire Depanment of Environmental Services
(May 21, 1991).
C. Telephone Notes Between Paul Killian, Roy F. Weston, Inc. and Gary
Hawonh, State of New Hampshire Depanment of Environmental Services
(May 22, 1991).
D. Memorandum from Deborah A. Szaro, EPA Region I to Richard A.
Goehlert, EPA Region I (April 25, 1991).
E. Letter from Gary Hawonh, State of New Hampshire Depanment of
Environmental Services to Deborah A. Szaro, EP A Region I
(May 16, 1991).
Memorandum from Bradley W. Schwab, Environmental Science & Engineering,
Inc. to Deborah A. Szaro, EPA Region I (June 11, 1991). Concerning the
attached chain of custody forms and information regarding hexavalent chromium
sampling.
Letter Repon from Paul F. Killian, Kate Schweitzer, John 1. Hagopian, Roy F.
Weston, Inc. to Scott Clifford, EPA Region I (June 18, 1991). Concerning the
comparison of hexavalent chromium soil sample results and the attached:
A. "Table I: Comparison of Cr (VI) Data."
B. Chain of Custody Forms.
C. Sampling Locations for Cr (VI) Sampling.
Letter Repon from Paul F. Killian and John J. Hagopian, Roy F. Weston, Inc.
to Scott Clifford, EPA Region I (Revised June 18, 1991). Concerning the
revalidation of hexavalent chromium soil sample results and the anached:
A. Letter Repon from Paul F. Killian, Kate Schweitzer, John J. Hagopian,
Roy F. Weston, Inc. to Dennis Gagne, EPA Region I (Revised
June 18, 1991).
B. "Chromium Data (VI) from AMRO Laboratory."
Memorandum from Deborah A. Szaro, EPA Region I to Richard A. Goehlen,
EPA Region I (June 20, 1991). Concerning the review of the PRP's hexavalent
chromium results for the soil samples taken from the site. .
Letter from Richard A. Goehlen, EPA Region I to Maria N. Borduz, Amro
Environmental Laboratories (June 25, 1991). Concerning questions on the
analysis of soil samples tested for chromium VI.
Letter Repon from Bradley W. Schwab, Environmental Science & Engineering,
Inc. to Daniel Coolidge, Sheehan, Phinney, Bass, and Green (June 28, 1991).
Concerning results of the chromium soil sample results. .
Letter from Maria N. Borduz, Amro Environmental Laboratories to Richard A.
Goehlen, EPA Region I (June 28, 1991). Concerning the reply to the
June 25, 1991 questions on the analysis of soil samples tested for chromium VI.
Letter Repon from Paul F. Killian, Kate Schweitzer, John J. Hagopian, Roy F.
Weston, Inc. to Scott Clifford, EPA Region I (Revised July 3, 1991).
Concerning the comparison of hexavalent chromium soil sample results and the
attached:
A. Chain of Custody Forms.
B. Sampling Locations for Cr (VI) Sampling.
C. "Table I: Comparison of Cr (VI) Data."
2.
3.
4.
5.
6.
7.
8.
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Page 12
4.2
Sampling and Analysis Data (cont'd.)
10. Letter Repon from Paul F. Killian and John J. Hagopian, Roy F. Weston, Inc.
to Scott Clifford, EPA Region I (Revised July 3, 1991). Concerning the
revision of the validation of hexavalent chromium soil sample resultS and the
attached:
A. Letter Repon from Paul F. Killian, Kate Schweitzer, John J. Hagopian,
Roy F. Weston, Inc. to Dennis Gagne, EPA Region I (Revised
July 3, 1991).
B. "Hexavalent Chromium Results."
C. "Chromium Data (VI) from AMRO Laboratory."
11. Cross-Reference: Comments Dated July 3, 1991 from Richard A. Goehlen,
EPA Region Ion the hexavalent chromium soil sample resultS in the June 1991
"Final Feasibility Study," HMM Associates, Inc. [Filed and cited as entry .
number 14 in 4.6 Feasibility Study (FS) Repons].
12. Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (July 10, 1991). Concerning analysis of contaminant
levels within the capture zone and treatment time estimates for the concentrated
plume.
13. Memorandum from Margaret McDonough, EPA Region I to Richard A.
Goehlen, EPA Region I (September 12, 1991). Concerning the hexavalent
chromium soil samples and the attached "Table 1 - Noncarcinogenic Risks from
Potential Future Residential Exposure to Hexavalent Chromium at OK Too1."
4.4
Interim Deliverables
Repons
1.
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 5,1990). Concerning transmittal of the attached
"Draft Feasibility Study - Section 1.0 - Introduction." .
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 5,1990). Concerning transmittal of the attached
"Draft Feasibility Study - Section 2.0 - ~dentification and Screening of
Technologies. "
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EP A Region I (September 21, 1990). Concerning transmittal of the
attached "Draft Feasibility Study - Section 3.0 - Development and Screening of
Remedial Alternatives."
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (January 22,1991). Concerning transmittal of the
attached "Draft Feasibility Study - Section 4.0 - Detailed Analysis of
Alternatives. "
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (May 24, 1991). Concerning transmittal of the attached
"Draft of Final Revisions for Feasibility Study - Section 1.0 - Introduction."
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (May 24, 1991). Concerning transmittal of the attached
"Draft of Final Revisions for Feasibility Study - Section 2.0 - Identification and
Screening of Technologies."
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 5, 1991). Concerning transmittal of the attached
"Draft of Final Revisions for Feasibility Study - Section 3.0 - Development and
Screening of Remedial Alternatives."
2.
3.
4.
5.
6.
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Page 13
4.4
Interim Deliverables (cont'd.)
8.
Memorandum from Mark O. Heuberger, HMM Associates, Inc. to Richard A.
Goehlen, EPA Region I (June 7,1991). Concerning transmittal of the attached
"Draft of Final Revisions for Feasibility Study - Section 4.0 - Detailed Analysis
of Alternatives."
Comments
9. Comments Dated November 24,1990 from Richard A. Goehlen, EPA Region I
on the June 5, 1990 "Draft Feasibility Study - Sections 1 and 2," HMM
Associates, Inc.
10. Comments Dated June 13, 1991 frOm Richard A. Goehlen, EPA Region Ion the
May 24, 1991 "Draft of Final Revisions for Feasibility Study - Sections 1
and 2," HMM Associates, Inc. and additional comments on Applicable or
Relevant and Appropriate Requirements (ARARs)
11. Comments Dated June 18, 1991 from Richard A. Goehlen, EPA Region Ion the
June 7, 1991 "Draft of Final Revisions for Feasibility Study - Section 4," HMM
Associates, Inc. with the attached Comments from Charles B. Holtman, State of
New Hampshire Office of the Attorney General on the Applicable or Relevant
and Appropriate Requirements (ARARs).
12. Comments Dated June 19, 1991 from Richard A. Goehlen, EPA Region Ion the .
June 5, 1991 "Draft of Final Revisions for Feasibility Study - Section 3," HMM
Associates, Inc.
13. Comments Dated June 23,1991 from Richard A. Goehlen, EPA Region Ion the
June 7, 1991 "Draft of Final Revisions for Feasibility Study - Section 4," HMM
Associates, Inc.
4.6
Feasibility Study (FS) Repons
Repons
1.
Cross-Reference: Portions of the Draft Feasibility Study Repons were
submitted to EPA Region I in sections as Interim Deliverables and are filed and
cited in 4.4 Interim Deliverables.
"Draft Feasibility Study," HMM Associates, Inc. (February 1991).
"Draft Feasibility Study Addendum," Haley & Aldrich, Inc. (May 24, 1991).
"Final Feasibility Study - Volume 1," HMM Associates, Inc. (June 1991).
"Final Feasibility Study - Volume 2 - Appendices," HMM Associates, Inc.
(June 1991).
"Feasibility Study Addendum," Haley & Aldrich, Inc. (June 1991).
2.
3.
4.
5.
6.
Comments
7. Comments Dated April 2, 1991 from Richard A. Goehlen, EP A Region I on the
February 1991 "Draft Feasibility Study," HMM Associates, Inc.
8. Comments Dated Apri121, 1991 from Richard A. Goehlen, EPA Region Ion
the February 1991 "Draft Feasibility Study," HMM Associates, Inc.
9. Comments Dated April 22, 1991 from Richard A. Goehlen, EPA Region I on
the February 1991 "Draft Feasibility Study," HMM Associates, Inc.
10. Comments Dated Apri129, 1991 from Richard A. Goehlen, EPA Region Ion
the February 1991 "Draft Feasibility Study," HMM Associates, Inc.
.11. Comments Dated Apri129, 1991 from Richard A. Goehlen, EPA Region Ion
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5.0
Page 14
4.6
Feasibility Study (FS) Reports (cont'd.)
12. Comments Dated May 17, 1991 from Richard A. Goehlert, EP A Region I on the
Applicable or Relevant and Appropriate Requirements (ARARs) for the
February 1991 "Draft Feasibility Study," HMM Associates, Inc.
13. Comments Dated June 21,1991 from Richard A. Goehlert, EPA Region Ion the
May 24,1991 "Draft Feasibility Study Addendum," Haley & Aldrich, Inc.
14. Comments Dated July 3, 1991 from Richard A. Goehlert, EP A Region I on the
hexavalent chromium soil sample results in the June 1991 "Final Feasibility
Study," HMU Associates, Inc.
15. Comments Dated August 9, 1991 from Mark C. Rouvalis, McLane, Graf,
Raulerson & Middleton (Attorney for the PRP Group) and Thomas S. Burack,
Sheehan, Phinney, Bass & Green (Attorney for the PRP Group) on the changes
that the PRP Group were required to make to the February 1991 "Draft
Feasibility Study," HMM Associates, Inc. The following are attached:
A. Letter from Bradley Schwab, Environmental Science & Engineering, Inc.
to Richard A. Goehlert, EP A Region I (March 20, 1991).
B. Letter from Daniel S. Coolidge, Sheehan, Phinney, Bass & Green
(Attorney for the PRP Group) to Richard A. Goehlert, EPA Region I
(April 27, 1991).
C. Letter from Gregory H. Smith, McLane, Graf, Raulerson & Middleton
(Attorney for the PRP Group) to Richard A. Goehlert, EPA Region I
(June 4, 1991).
D. Letter from Timothy M. Cosgrave, Environmental Project Control to
Richard A. Goehlert, EP A Region I (January 7, 1991).
E. Letter from Environmental Project Control to Richard A. Goehlert, EP A
Region I (December 11, 1990).
F. Letter from Bradley W. Schwab, Environmental Science & Engineering,
Inc. to Daniel S. Coolidge, Sheehan, Phinney, Bass & Green (Attorney
for the PRP Group ) (June 28, 1991).
G. Memor::mdum from Mark O. Heuberger, HMM Associates, Inc. to Richard
A. Goehlert, EPA Region I (April 29, 1991).
H. Pages and Tables from the February 1991 "Draft Feasibility Study," HMM
Associates, Inc.
4.9
Proposed Plans for Selected Remedial Action
1.
"EPA Proposes Cleanup Plan for the Savage Municipal Water Supply Site,"
EPA Region I (July 1991).
Record of Decision (ROD)
5.3
Responsiveness Summary
1.
Cross-Reference: Responsiveness Summary is an attachment to the
September 27, 1991 "Record of Decision," EPA Region I [Filed and cited as
entry number 1 in 5.4 Record of Decision (ROD)].
The following citations indicate documents received by EP A Region I during the
formal public com-nent period.
2.
3.
Comments Dated July 12, 1991 from William B. Rotch, Milford Cabinet and
Wilton Jourr.al on the July 1991 Proposed Plan.
Comments Dated July 16, 1991 from A Milford Tax Payer on the July 1991
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Page 15
5.3
Responsiveness Summary (cont'd.)
4. Comments Dated July 19, 1991 from Heidi Gramatikas on the July 1991
Proposed Plan. .
5. Comments Dated July 20,1991 from Gordon D. Estabrook, Jr. on the
July 1991 Proposed Plan.
6. Comments Dated July 20, 1991 from Mary Roy on the July 1991 Proposed
Plan.
7. Comments Dated July 23,1991 from James T. Lawson on the July 1991
Proposed Plan.
8. Comments Dated July 25,1991 from Frederick F. Marston, Jr. on the July 1991
Proposed Plan.
9. Comments Dated July 25,1991 from Nancy E. Gersky on the July 1991
Proposed Plan.
10. Comments Dated July 26,1991 from Bruce Bezanson on the July 1991
Proposed Plan.
11. Comments Dated July 26, 1991 from Richard Mace, Sr., Richard Medlyn, Peter
Leishman, John Ruonala, and Rosario Ricciardi, Town of Milford on the
July 1991 Proposed Plan.
12. Comments dated July 27, 1991 from William W. Cleaves on the July 1991
Proposed Plan. .
13. Comments Dated July 27, 1991 from Ahma B. Estahook on the July 1991
Proposed Plan.
14. Comments Dated July 29, 1991 from Gary L. Daniels on the July 1991
Proposed Plan. .
15. Comments Dated July 30, 1991 from William B. Rotch, The Milford Cabinet
and Wilton Journal on the July 1991 Proposed Plan and the two attached
editorials.
16. Comments Dated July 31,1991 from Suzanne L. Fournier on the July 1991
Proposed Plan.
17. Comments Dated August 1, 1991 from Stephen H. Taylor, New Hampshire
Department of Agriculture on the July 1991 Proposed Plan.
18. Comments Dated August 5,1991 from Linda Mossey on the July 1991
Proposed Plan and the attached newspaper article.
19. Comments Dated August 5, 1991 from the Town of Milford Board of Selectmen
on the July 1991 Proposed Plan and the attached site maps.
20. Comments Dated August 8,1991 from David Godbout on the July 1991
Proposed Plan and the two attached articles.
21. Comments Dated August 8,1991 from Arthur Duguay on the July 1991
Proposed Plan.
22. Comments Dated August 8, 1991 from Dana S. Wallace on the July 1991
Proposed Plan. . .
23. Comments Dated August 9, 1991 from Maureen E. Raiche, Devine & Nyquist
(Attorney for OK Tool Company, Inc.) on the July 1991 Proposed Plan and the
following attachments: .
A. Letter from Peter 1. McGlew, Aries Engineering to Maureen E. Raiche,
Devine & Nyquist (Attorney for OK Tool Company, Inc.)
(August 6, 1991).
B. Section 1, Page 1 of "Repon of Findings - Hydrogeologic and Water
Quality Investigations," Roy F. Weston, Inc. for Hitchiner Manufacturing
-------
5.3
.
Page 16
Responsiveness Summary (cont'd.)
24. Comments Dated August 9,1991 from Richard C. Nelson, Merrill & Broderick
(Attorney for Gary W. Frye) on the July 1991 Proposed Plan and the following
attachments:
A. Letter from James R. Mitchell, University of New Hampshire Cooperative
Extension to Gary W. Frye (August 8, 1991).
B. Letter from George W. Hamilton, University of New Hampshire
Cooperative Extension to Gary W. Frye (August 8, 1991).
25. Comments Dated August 9, 1991 from Mark C. Rouvalis, McLane, Graf,
Raulerson & Middleton (Attorney for Hitchiner Manufacturing Company, Inc.)
on the July 1991 Proposed Plan and the following attached exhibits and
documents supporting those comments:
A. Letter from Jeffrey S. Lawson for Timothy M. Cosgrave and John A.
Cherry, Environmental Project Control to Richard A. Goehlert, EP A
Region I (December 11, 1990).
B. Letter from Timothy M. Cosgrave, Environmental Project Control to
Richard A. Goehlert, EP A Region I (January 7, 1991).
C. Letter from Gretchen R. Rich and Lawrence P. Smith, Haley & Aldrich to
Gregory H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for
Hitchiner Manufacturing Company, Inc.) (August 9, 1991). ..
D. Letter from Jeffrey T. Dawson, Environmental Project Control to Gregory
H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for Hitchiner
Manufacturing Company, Inc.) and Daniel S. Coolidge, Sheehan,
Phinney, Bass, & Green (Attorney for Hendrix Wire and Cable Company)
(August 6, 1991).
E. "Summary of Selected Publications on Groundwater Pump and Treat
Remedies, Including DNAPL Issue."
F. "Evaluation of Groundwater Extraction Remedies - Volume 1 - Summary
Report," EPA Headquarters (September 1989).
G. "Groundwater Issue," EPA Headquarters (October 1989).
H. "Guidance on Remedial Actions for Contaminated Groundwater at
Superfund Sites - Interim Final," EP A Headquarters (December 1988).
I. "Basics of Pump-and- Treat Groundwater Remediation Technology," EP A
Headquarters.
1. "GrouJ!dwater Contamination: Pump-and Treat Remediation,"
Environmental Science & Technology (June 1989).
K. "PollutlI1ts in Porous Media," B. Varon, G. Dagan, and J. Goldshid.
L. "The T:ouble With DNAPLs," Roy F. Weston, Inc. (November 1990).
M. "Subsurface Contamination by Dense Non-Aqueous Phase Liquid
(DNAPL) Chemicals," Stan Feenstra and John A. Cherry (May 1988).
N. Letter from Richard Mace, Sr., Richard Medlyn, Peter Leishman, John
Ruonala, and Rosario Ricciardi; Town of Milford to Julie Belaga, EPA
-------
5.4
Page 17
5.3
Responsiveness Summary (cont'd.)
26. Comments Dated August 9, 1991 from Thomas S. Burack, Sheehan, Phinney,
Bass, & Green (Attorney for Hendrix Wire and Cable Company) on the
July 1991 Proposed Plan and the following attached exhibits and documents
supporting those comments:
A. Letter from Jeffrey T. Dawson, Environmental Project Control to Gregory
H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for Hitchiner
Manufacturing Company, Inc.) and Daniel S. Coolidge, Sheehan,
Phinney, Bass, & Green (Attorney for Hendrix Wire and Cable Company)
(August 6, 1991).
B. Letter from Gregory H. Smith, McLane, Graf, Raulerson & Middleton
(Attorney for Hitchiner Manufacturing Company, Inc.) and Daniel S.
Coolidge, Sheehan, Phinney, Bass, & Green (Attorney for Hendrix Wire
and Cable Company) to Richard A. Goehlert, EPA Region I
(May 28,1991).
C. "ROD Decision Summary - Sullivan's Ledge Superfund Site," EPA
Region I (June 28, 1989).
D. "Superfund Record of Decision - Nyanza Chemical," EPA Region I
(September 4, 1985).
E. "Declaration for the Record of Decision - Kysor of Cadillac, Inc.," EP A
Region V (September 29, 1989).
25. Comments Dated August 9,1991 from Kevin P. Cheever on the July 1991
Proposed Plan and the attached site map from "Hydrogeologic Study and Waste
Evaluation," Normandeau Associates, Inc. for OK Tool Company, Inc.
(December 1983).
26. Comments Dated August 9,1991 from L. Richard Bickford on the July 1991
Proposed Plan.
27. Comments from Shawn F. Dean, Hitchiner Manufacturing Co., Inc. on the
July 1991 Proposed Plan.
28. Comments from Bill D'Alessandro, Crossland's on the July 1991 Proposed
Plan.
29. Comments from Jacqueline Allison on the July 1991 Proposed Plan and the
attached Letter from Amy Juchatz, State of New Hampshire Department of
Health and Human Services to Mrs. Maurice Larouche (October 2, 1987).
30. Comments from Steve Burtchell on the July 1991 Proposed Plan.
31. Comments from 66 Members of the Public on the July 1991 Proposed Plan.
32. Comments from Marylou Blaisdell, League of Women Voters on the July 1991
Proposed Plan.
33. Comments from Boyd Etheredge on the July 1991 Proposed Plan.
~.
The following citations indicate documenJs received by EP A Region I after the
formal public comment period.' .
34. Comments Dated August 10, 1991 from Attila P. FarkaS on the July 1991
Proposed Plan.
35. Comments Dated August 13, 1991 from Marilyn Peterman, Town of Amherst
on the July 1991 Proposed Plan.
Record of Decision (ROD)
1.
-------
9.0
Page 18
9.1
State Coordination
Correspondence
Letter from Edward 1. Schmidt. State of New Hampshire Department of
Environmental Services to Town of Milford Board of Selectmen
(July 11, 1991). Concerning state standards and policies for groundwater use
applicable to the site.
10.0 Enforcement
1.
10.3 State and Local Enforcement Records
1.
Memorandum from Ken Marschner, State of New Hampshire Office of Solid
Waste and Public Health to Tom Roy, State of New Hampshire
(September 17, 1980) with attached sampling maps and sampling data.
Concerning the September 15, 1980 collection of soil samples to be tested for
chromium.
Petition for Temporary and Permanent Injunction and Assessment of Civil
Penalties, State of New Hampshire v. Hitchiner Manufacturing Co., Inc.,
Robert Savage and Margaret Savage, Robert E. Carter, Hendrix Wire & Cable
Corporation, and G & T Construction Corporation, State of New Hampshire
Superior Court (September 30, 1980). The following exhibits are attached:
A. Letter f:om William A. Healy, State of New Hampshire Water Supply and
Pollution Control Commission to Paul Mercier, Hitchiner Manufacturing
Co., Inc. (June 27,1980). Concerning violations of National Pollution
Discharge Elimination System (NPDES) Permit No. 0001376.
B. Letter from Richard P. Grouman for William A. Healy, State of New
Hampshire Water Supply and Pollution Control Commission to J.H.
Morison, Hitchiner Manufacturing Co., Inc. (July II, 1980). Concerning
violations of National Pollution Discharge Elimination System (NPDES)
PerniltNo.OOOI376. .
C. Letter from Thomas L. Sweeney, State of New Hampshire Water Supply
and Pollution Control Commission to J.H. Morison, Hitchiner
Manufacturing Co., Inc. (July II, 1980). Concerning the illegal disposal
of haza:.-dous waste and the order to remove contaminated sludge and soil
on or before August 15, 1980.
Stipulation, State of New Hampshire v. Hitchiner Manufacturing Co., Inc.,
Robert Savage and Margaret Savage, Robert E. Carter, Hendrix Wire & Cable
Corporation, and G & T Construction Corporation, State of New Hampshire
Superior Court (October 9, 1980) with attached Amendment to Stipulation, State
of New Hampshire v. Hitchiner Manufacturing Co., Inc., Robert Savage and
Margaret Savage, Robert E. Carter, Hendrix Wire & Cable Corporation, and
G & T Construction Corporation, State of New Hampshire Superior Court.
"Hydrogeologic Study and Waste Evaluation - O.K. Tool Company,"
Normandeau Associates, Inc. for O.K. Tool Company, Inc. (December 1983).
"Report of Findings - Hydrogeologic and Water Quality Investigations -
Hitchiner Manufacturing Co.," Roy F. Weston, Inc. (March 16, 1984).
"Water Quality Monitoring -O.K. Tool Company - May II, 1984 Sampling,"
Normandeau Associates, Inc. for O.K. Tool Company, Inc. (August 1984).
"Phase II Site Investigation Summary Report - O.K. Tool Company, Inc.,"
Normandeau Associates, Inc. for O.K. Tool Company, Inc.
(November 15, 1984).
2.
3.
4.
5.
6.
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Page 19
10.3 State and Local Enforcement Records (cont'd.)
8. "Soil Removal From Beneath Indoor Degreasing Tank - O.K. Tool Company,
Inc.," Normandeau Associates, Inc. for O.K. Tool Company, Inc.
(January 3, 1985).
9. "Final Report - Environmental Actions With Regard to the Abandon Drywell
Located at the Milford, New Hampshire Facility," Les A. Cartier and
Associates, Inc. for Hitchiner Manufacturing Company, Inc. (January 7, 1986).
10. Letter from Maureen E. Raiche, Devine & Nyquist (Attorney for John F. Kick)
to James B. Zeppieri, State of New Hampshire Department of Environmental
Services (April 4, 1989). Concerning transmittal of the attached sampling maps
and the October 1983 "Seismic Ref~action and Gravity Investigation - O.K. Tool.
Company, Inc.," John F. Kick for Normandeau Associates, Inc. .
10.5 General Negotiations
1.
Letter from Gregory H. Smith and Daniel S. Coolidge, McLane, Graf,
Raulerson, & Middleton (Attorney for the PRP Group) to Richard A. Goehlert,
EPA Region I (May 28, 1991). Concerning the PRP Group's position on the
site cleanup and notification that Hitchiner Manufacturing Company, Inc. and
Hendrix Wire & Cable Corporation will bear the brunt of financial responsibility
for the cleanup.
10.7 EPA Administrative Orders
1.
Administrative Order By Consent, In the Matter of Savage Municipal Water
Supply Well Site, O.K. Tool Company, Inc., Hitchiner Manufacturing
Company, Inc., New England Steel Fabricators, Inc., and Hendrix Wire and
Cable Corporation, Docket No. 1-87-1096 (August 10, 1987) with the attached
"Attachment A: Work Plan for Remedial Investigation/Feasibility Study -
Volume I: Technical Scope of Work," Camp Dresser & McKee Inc.
(June 20, 1986).
11.0 Potentially Responsible Party (PRP)
11.7 PRP-Steering Committee Documents
1.
Letter from Gregory H. Smith, McLane, Graf, Raulerson, & Middleton
(Attorney for the PRP Group) to Richard A. Goehlert, EP A Region I
(June 22, 1990). Concerning notification that the PRP Group would like to
conduct the August 6, 1990 public meeting.
11.9 PRP-Specific Corr~spondence
1.
Letter from Merrill S. Hohman, EPA Region I to William Paradise, Hendrix
Wire and Cable Corporation (June 18, 1985). Concerning notification that
Hendrix Wire and Cable Corporation is potentially responsible for the site
cleanup. .
Letter from r-..ferrill S. Hohman, EPA Region I to Nicholas Babich, Hitchiner
Manufacturing Company, Inc. (June 18, 1985). Concerning notification that
Hitchiner Manufacturing Company, Inc. is potentially responsible for the site
cleanup.
Letter from Merrill S. Hohman, EP A Region I to Richard Bucknam, New
England Steel Fabricators, Inc. (June 18, 1985). Concerning notification that
New England Steel Fabricators, Inc. is potentially responsible for the site
cleanup.
2.
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Page 20
11.9 PRP-Specific Correspondence (cont'd.)
4. Letter from Merrill S. Hohman, EPA Region I to Thomas Hollis Jr., O.K. Tool
Company, Inc. (June 18, 1985). Concerning notification that O.K. Tool
Company, Inc. is potentially responsible for the site cleanup.
5. Letter from Merrill S. Hohman, EPA Region I to Nicholas Babich, Hitchiner
Manufacturing Company, Inc. (January 13, 1987). Concerning the invitation
for Hitchiner Manufacturing Company, Inc. and other potentially responsible
parties to voluntarily perform the Remedial Investigation and Feasibility Study.
6. Letter from Merrill S. Hohman, EPA Region I to Richard Bucknam, New
England Steel Fabricators, Inc. (January 13, 1987). Concerning the invitation
for New England Steel Fabricators, Inc. and other potentially responsible parties
to voluntarily perform the Remedial Investigation and Feasibility Study.
7. Letter from Merrill S. Hohman, EPA Region I to Thomas Hollis Jr., O.K. Tool
Company, Inc. (January 13, 1987). Concerning the invitation for O.K. Tool
Company, Inc. and other potentially responsible parties to voluntarily perform
the Remedial Investigation and Feasibility Study.
8. Letter from Merrill S. Hohman, EPA Region I to William Paradise, Hendrix
Wire and <;:able Corporation (January 13, 1987). Concerning the invitation for
Hendrix Wire and Cable Corporation and other potentially responsible parties to
voluntarily perform the Remedial Investigation and Feasibility Study.
9. Cross-Reference: Comments Dated August 9, 1991 from Maureen E. Raiche,
Devine & Nyquist (Attorney for OK Tool Company, Inc.) on the July 1991
Proposed Plan and with the following attachments [Filed and cited as entry
number 23 in 5.3 Responsiveness Summary]:
A. Letter from Peter 1. McGlew, Aries Engineering to Maureen E. Raiche,
Devine & Nyquist (Attorney for OK Tool Company, Inc.)
(August 6, 1991).
B. Section 1, Page 1 of "Report of Findings - Hydrogeologic and Water
Quality Investigations," Roy F. Weston, Inc. for Hitchiner Manufacturing
Co. (March 16, 1984).
10. Cross-Reference: Comments Dated August 9,1991 from Mark C. Rouvalis,
McLane, Grcl, Raulerson & Middleton (Attorney for Hitchiner Manufacturing
Company, In~.) on the July 1991 Proposed Plan and the following attached
exhibits and documents supporting those comments [Filed and cited as entry
number 25 in 5.3 Responsiveness Summary]:
A. Letter from Jeffrey S. Lawson for Timothy M. Cosgrave and John A.
Cheny, Environmental Project Control to Richard A. Goehlert, EP A
Region I (December 11, 1990).
B. Letter from Timothy M. Cosgrave, Environmental Project Control to
Richard A. Goehlert, EPA Region I (January 7, 1991).
C. Letter from Gretchen R. Rich and Lawrence P. Smith, Haley & Aldrich to
Gregory H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for
Hitchiner Manufacturing Company, Inc.) (August 9, 1991).
D. Letter from Jeffrey T. Dawson, Environmental Project Control to Gregory
H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for Hitchiner
Manufacturing Company, Inc.) and Daniel S. Coolidge, Sheehan,
Phinney, Bass, & Green (Attorney for Hendrix Wire and Cable Company)
(August 6, 1991).
E. "Summary of Selected Publications on Groundwater Pump and Treat
Remedies, Including DNAPL Issue."
F. "Evaluation of Groundwater Extraction Remedies - Volume 1 - Summary
Report," EPA Headquarters (September 1989).
G. "Groundwater Issue," EPA Headquarters (October 1989).
H. "Guidance on Remedial Actions for Contaminated Groundwater at
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Page 21
11.9 PRP-Specific Correspondence (cont'd.)
I. "Basics of Pump-and-Treat Groundwater Remediation Technology," EPA
Headquarters.
1. "Groundwater Contamination: Pump-and Treat Remediation,"
Environmental Science & Technology (June 1989).
"Pollutants in Porous Media," B. Yaron, G. Dagan, and J. Goldshid.
"The Trouble With DNAPLs," Roy F. Weston, Inc. (November 1990).
"Subsurface Contamination by Dense Non-Aqueous Phase Liquid
(DNAPL) Chemicals," Stan Feenstra and John A. Cheny (May 1988).
N. Letter from Richard Mace, Sr., Richard Medlyn, Peter Leishman, John
Ruonala, and Rosario Ricciardi, Town of Milford to Julie Belaga, EP A
Region I (July 26, 1991).
11. Cross-Reference: Comments Dated August 9,1991 from Thomas S. Burack,
Sheehan, Phinney, Bass, & Green (Attorney for Hendrix Wire and Cable
Company) on the July 1991 Proposed Plan and the following attached exhibits
and documents supporting those comments [Filed and cited as entry number 26
in 5.3 Responsiveness Summary]:
A. Letter from Jeffrey T. Dawson, Environmental Project Control to Gregory
H. Smith, McLane, Graf, Raulerson & Middleton (Attorney for Hitchiner
Manufacturing Company, Inc.) and Daniel S. Coolidge, Sheehan, .
Phinney, Bass, & Green (Attorney for Hendrix Wire and Cable Company)
(August 6, 1991).
B. Letter from Gregory H. Smith, McLane, Graf, Raulerson & Middleton
(Attorney for Hitchiner Manufacturing Company, Inc.) and Daniel S.
Coolidge, Sheehan, Phinney, Bass, & Green (Attorney for Hendrix Wire
and Cable Company) to Richard A. Goehlert, EPA Region I
(May 28, 1991).
C. "ROD Decision Summary - Sullivan's Ledge Superfund Site," EPA
Region I (June 28, 1989).
D. "Superfund Record of Decision - Nyanza Chemical," EPA Region I
(September 4, 1985).
E. "Declaration for the Record of Decision - Kysor of Cadillac, Inc.," EP A
Region V (September 29,1989).
K.
L.
M.
13.0 Community Relations
13.1 Correspondence
1.
Letter from Lee F. Mayhew, Town of Milford to Dennis Huebner, EP A
Region I (At-gust 10, 1989). Concerning the provisions of the transfer of the
Savage Well property from the Town of Milford to Hitchiner Manufacturing
Company. .
Letter from Dennis Huebner, EPA Region I to Lee F. Mayhew, Town of
Milford (September 28, 1989). Concerning the response to the August 10, 1989
letter and information on aquifers. .
Letter from Richard Mace Sr., Richard Medlyn, Peter Leishman, John Ruonala,
Rosario Ricciardi, Town of Milford to Julie Belaga, EPA Region I
(May 28, 1991). Concerning position the Town of Milford on the selection of a
. remedy at the site.
Letter from Julie Belaga, EP A Region I to Richard Mace Sr., Town of Milford
(June 20, 1991). Concerning the response to the May 28, 1991 letter and the
explanation of the public comment period.
2.
3.
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Page 22
..
13.1 Correspondence (cont'd.)
5. Letter from David E. Harris, Earl J. Ellingwood, and George Hicks, Town of
Littleton to Julie Belaga, EPA Region I (July 3, 1991). Concerning the
importance of Hitchiner Manufacturing Co. to the Town of Littleton and the
Town of Littleton's position on the site cleanup.
6. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Mr. and
Mrs. Leonard Cushing (July 5, 1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
has commenced .
7. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to William
Furguson (July 5, 1991). Concerning transmittal of the Proposed Plan for
review and notification that the process for selecting a cleanup remedy has
commenced.
. 8. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Mr. and
Mrs. Steven H. Foskett (July 5, 1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
has commenced
9. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to John S.
Kopka, JK Realty Trust (July 5,1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
has commenced .
10. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Edith I.
Graves and Phylis M. Tagg (July 5,1991). Concerning transmittal of the
Proposed Plan for review and notification that the process for selecting a cleanup
remedy has commenced.
11. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Edward
Medlyn, Medlyn Motors (July 5, 1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
has commenced .
12. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Steven
Talarico, Talarico Chevrolet/Pontiac (July 5,1991). Concerning transmittal of
the Proposed Plan for review and notification that the process for selecting a
cleanup remedy has commenced
13. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Steven.
Talarico, Body Magic Autobody Shop (July 5,1991). Concerning transmittal of
the Proposed Plan for review and notification that the process for selecting a
cleanup remedy has commenced
14. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Mr. and
Mrs. Ralph Talarico (July 5, 1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
has commented .
15. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Richard
Prunier, Souhegan Valley Aquaculture (July 5,1991). Concerning transmittal
of the Proposed Plan for review and notification that the process for selecting a
cleanup remedy has commenced
16. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Stanley
Trombley (July 5,1991). Concerning transmittal of the Proposed Plan for
review and notification that the process for selecting a cleanup remedy has
commenced.
17. Letter from Frank Ciavattieri for Merrill S. Hohman, EP A Region I to Suburban
Propane Gas Company (July 5,1991). Concerning transmittal of the Proposed
Plan for review and notification that the process for selecting a cleanup remedy
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Page 23
13.1 Correspondence (cont'd.)
18. Letter from Frank Ciavattieri for Meni11 S. Hohman, EPA Region I to Roben
Schannett, Milford Drive-In (July 5,1991). Concerning transmittal of the
Proposed Plan for review and notification that the process for selecting a cleanup
remedy has commenced.
19. Letter from Frank Ciavattieri for Menill S. Hohman, EPA Region I to Richard
Fisk, Nashua Trust Company (July 5, 1991). Concerning transmittal of the
Proposed Plan for review and notification that the process for selecting a cleanup
remedy has commenced.
20. Letter from Frank Ciavattieri for Menill S. Hohman, EPA Region I to Stephen
Faccidomo, Souhegan Investment Corporation (July 5, 1991). Concerning
transmittal of the Proposed Plan for review and notification that the process for
selecting a cleanup remedy has commenced.
21. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Edward
F. Hutchinson, Hutchinson and Hutchinson (July 5, 1991). Concerning
transmittal of the Proposed Plan for review and notification that the process for
selecting a cleanup remedy has commenced.
22. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Celia F.
Melendy (July 5, 1991). Concerning transmittal of the Proposed Plan for
review and notification that the process for selecting a cleanup remedy has.
commenced.
23. Letter from Frank Ciavattieri for Menill S. Hohman, EPA Region I to Mr. and
Mrs. Charles P. Hayward (July 5, 1991). Concerning transmittal of the
Proposed Plan for review and notification that the process for selecting a cleanup
remedy has commenced.
24. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Roben .
Savage (July 5, 1991). Concerning transmittal of the Proposed Plan for review
and notification that the process for selecting a cleanup remedy has commenced.
25. Letter from Frank Ciavattieri for Menill S. Hohman, EPA Region I to Gary
Frye, Frye Farm (July 5, 1991). Concerning transmittal of the Proposed Plan
for review and notification that the process for selecting a cleanup remedy has
commenced.
. 26. Letter from Frank Ciavattieri for Merrill S. Hohman, EPA Region I to Roben
Fawcett, State of New Hampshire Fish and G~me Department (July 5, 1991).
Concerning transmittal of the Proposed Plan for review and notification that the
process for selecting a cleanup remedy has commenced.
27. Letter from Frank Ciavattieri for Menill S. Hohman, EPA Region I to Karen
Emery, Public Service Company (July 5, 1991). Concerning transmittal of the
Proposed Plan for review and notification that the process for selecting a cleanup
remedy has commenced.
28. Letter from Julie Belaga, EPA Region I to David E. Hanis, Town of Littleton
(July 23, 1991). Concerning the response to the July 3, 1991 Letter from David'
E. Harris, Earl 1. Ellingwood, and George Hicks, Town of Littleton to Julie
Belaga, EPA Region I and transmittal of the July 1991 Proposed Plan.
29. Letter from Julie Belaga, EPA Region I to Richard Mace, Sr., Town of Milford
(September 26, 1991). Concerning the response to the Town of Milford's
Comments Dated July 26, 1991 and August 5, 1991 on the July 1991 Proposed
Plan.
13.2 Community Relations Plans
1.
2.
"Updated Coinmunity Relations Plan," Booz Allen & Hamilton, inc.
(July 18, 1988).
"Final Repon - Revised Community Relations Plan," Camp Dresser & McKee
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Page 24
13.3 News Clippings/Press Release
1.
"Environmental News," EPA Region I (July 22, 1985). Concerning the
announcement that a public meeting will be held July 29, 1985 to discuss plans
to cleanup the site.
"Environmental News," EPA Region I (August 12, 1987). Concerning the
announcement that O.K. Tool Company, Hitchiner Manufacturing Company
Inc., Hendrix Wire and Cable Corporation, and New England Steel Fabricators
Inc. have entered into a Consent Order with EPA.
"Environmental News," EPA Region I (July 17, 1991). Concerning the
announcement that the public hearing date and location has been changed to
July 29, 1991 at the Hampshire Hills Spons and Fitness Club.
"Environmental News," EPA Region I (September 27,1991). Concerning the
announcement that the Record of Decision (ROD) for the site has been signed.
2.
3.
4.
13.4 Public Meetings
"Summary of Public Meeting on Savage Municipal Well Superfund Site," EPA
Region I (July 29, 1985).
EPA Region I Meeting Agenda, Public Meeting for the Savage Municipal Well
Superfund Site (July 25, 1988).
Cross-Reference: Letter from Gregory H. Smith, McLane, Graf, Raulerson, &
Middleton (Attorney for the PRP Group) to Richard A. Goehlen, EPA Region I
(June 22, 1990). Concerning notification that the PRP Group would like to
conduct the August 6, 1990 public meeting [Filed and cited as entry number 1 in
11.7 PRP Steering Committee Documents].
"Meeting Summary: Preliminary Results of the Remedial Investigation & Risk
Assessment," EPA Region I (August 1990).
EPA Region I Meeting Agenda, Public Meeting for the Savage Municipal Well
Superfund Site (July 11, 1991). Concerning the Feasibility Study, Addendum,
and Proposed Plan.
"Meeting Summary: Feasibility Study, Addendum, and Proposed Plan," EPA
Region I (July 11, 1991 ). .
"Statement of Hitchiner Manufacturing Co., Inc. - Savage Well Public Comment
Meeting - July 29, 1991."
13.5 Fact Sheets
1.
2.
3.
4.
5.
6.
7.
"Fact Sheet - Savage Municipal Well Site," EPA Region I (December 1988).
"Fact Sheet - EPA Announces the Preliminary Results of Remedial Investigation
and Risk Assessment Studies," EPA Region I (July 1990).
"EPA National Priorities List Sites: New Hampshire - Savage Municipal Water
Supply," EPA Headquarters (September 1990).
14.0 Congressional Relations
1.
2.
3.
14.1 Correspondence
1.
Letter from Gordon J. Humphrey, Member of the U.S. Senate to Michael R.
Deland, EPA Region I (November 26,1984). Concerning the request that EPA
include the Keyes well field contamination in the scope of work for the site.
Statement, Attachment to Statement of Michael R. Deland, EP A Region I Before
the Natural Resources, Agricultural Resources and Environmental Subcommittee
of the Committee on Science Technology (October 18, 1985).
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Page 25
14.1 COlTespondence (cont'd.)
3.
Letter from Judd Gregg, Member of the U.S. House of Representatives to
Michael R. Deland, EPA Region I (February 20, 1986). Concerning a request
for EPA's position regarding the proposal in which the polluted well would be
sold to a group of area companies.
Letter from Michael R. Deland, EP A Region I to Judd Gregg, Member of the
U.S. House of Representatives (March 10, 1986). Concerning an update of site
activities and the attached letter from Michael P. Donahue, State of New
Hampshire Water Supply and Pollution Control Commission to Lee F. Mayhew,
Town of Milford (December 20, 1985). .
Letter from Bob Smith, Member of the U.S. Senate to Julie Belaga, EPA Region
I (August 20, 1991). Concerning the importance of arriving at a fair settlement .-
at the site.
4.
5.
16.0 Natural Resource Trustee
16.1 Correspondence
1.
Letter from Kenneth Finkelstien, United States Department of Commerce
National Oceanic and Atmospheric Administration to David J. Newton, EPA
Region I (September 18, 1987). Concerning notification that United States
Department of Commerce National Oceanic and Atmospheric Administration
considers the site to be impacting natural resources under their trusteeship.
16.4 Trustee Notification Form and Selection Guide
1.
Letter from Ira W. Leighton for Merrill S. Hohman, EPA Region I to William
Patterson, United States Department of the Interior (June 8, 1987). Concerning
notification of potential damages to natural resources and the following
attachments: .
A. "Trustee Notification Attachment"
B. "Guide to Trustee Selection."
Letter from Ira W. Leighton for Merrill S. Hohman, EPA Region I to Sharon
Christopherson, United States Department of Commerce National Oceanic and
Atmospheric Administration (June 8, 1987). Concerning notification of
potential damages to natural resources and the attached "Trustee Notification
Attachment."
2.
17.0 Site Management Records
17.8 State and Local Technical Records
1.
"Bedrock Fracture Fabric Analysis of the Savage Well, Grugnale Pit and Milford
Landfill Hazardous Waste Study Areas," BCI Geonetics, Inc. for the State of
New Hampshire Water Supply and Pollution Control Commission
(August 24, 1984.)
"Commission Repon #145 - Hydrogeological Investigation of the Savage Well
Site - Volume I," State of New Hampshire Water Supply and Pollution Control
Commission (June 1985).
"Commission Repon #145 - Hydrogeological Investigation of the Savage Well
Site - Volume IT," State of New Hampshire Water Supply and Pollution Control
Commission (June 1985).
2.
-------
Section II
-------
.6.
..10.
14.
15.
GUIDANCE DOCUMENTS
EP A guidance documents may be reviewed at EP A Region I, Boston, Massachusetts.
General EPA Guidance Documents
1.
"Protection of Wetlands (Executive Order 11990), Appendix D," Federal Re~ister
(Vol. 42),1977.
2.
U.S. Environmental Protection Agency. Guidance Manual for Minimizin~ Pollution from
Waste Disposal Sites (EPA/600/2-78/142), August 1978.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Carbon Adsox:ption Isothenns for Toxic Or~anics (EPA/600/8-80/023), April 1, 1980.
3.
4.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Costs of Remedial Response Actions at UncontroI1ed Hazardous Waste Sites,
April 15, 1981.
5.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Handbook for Evaluating Remedial Action Technolo~ Plans (EPA/600/2-83/076),
August 1983.
7.
"Final and Proposed Amendments to the National Oil and Hazardous Substances Pollution
Contingency Plan," Code of Federal Regulations (Title 40, Part 300), September 8, 1983.
"National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
Regulations (Title 40, Part 300), 1985.
8.
"National Oil and Hazardous Substances Pollution Contingency Plan," Federal Re~ister
(Vol. 55, No. 46), March 8, 1990.
9.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6),
September 1983.
11.
U.S. Environmental Protection Agency. Environmental Monitoring Systems Laboratory.
Soil Sampling Ouality Assurance User's Guide (EPA/600/4-84/043), May 1984.
U.S. Environmental Pro~ction Agency. Office of Ground-Water Protection.
Ground-Water Protection Strategy (EP A/440/6-84/002), August 1984.
12.
u.s. Environmental Protection Agency. Environmental Criteria and Assessment Office.
Health Effects Assessment Documents (58 Chemical Profiles) (EPA/5401l-86/001-058),
September 1, 1984. .
"Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean
Water Act; Final Rule and Interim Final Rule and Proposed Rule," Federal Register
(Vol. 49, No. 209), October 26, 1984.
13.
U.S. Environmental Protection Agency. Environmental Criteria and Assessment Office.
Health Effects Assessment for Asbestos, November 1984.
U.S. Environmental Protection Agency. Hazardous Response Support Division. Standard
-------
24.
25.
26.
27.
Page 27
16.
u.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
field Standard Qperatine Procedures Manual #4: Site Enny (OSWER Directive
9285.2-01), January 1, 1985.
17.
u.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatin~ Procedures Manual #8: Air Surveillance (OSWER Directive
9285.2-03), January 1, 1985.
18.
U.S. Environmental Protection Agency. Office of Health and Environmental Assessment.
I)evelQpment of Statistical Distribution or Ranies Standard Factors Used in Exposure
Assessments (EPA OHEA-E-16), March 1985. .
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Operatin~ Procedures Manual #6: Work Zones (OSWER Directive
9285.2-04), April 1, 1985.
19.
20.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Eield Standard Qperatini Procedures Manual #9: Site Safety Plan (OSWER Directive
9285.2-05), April 1, 1985.
21.
U.S. Environmental Protection Agency. Environmental Research Laboratory. EPA Guide
fur Minimizini the Adverse Environmental Effects of Cleanup of Uncontrolled
Hazardous-Waste Sites (EPA/600/8-85/008), June 1985.
22. .
U.S. Environmental Protection Agency. Environmental Monitoring Systems Laboratory.
~:diment Sampline Quality Assurance User's Guide (EPA/600/4-85/048), July 1985.
23.
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.
Is)xicoloiY Handbook (OSWER Directive 9850.2), August 1, 1985.
Memorandum from Gene Lucero, U.S. Environmental Protection Agency Office of Waste
Programs Enforcement t:> Addressees (" Director, Waste Management Division, Regions I,
N, V, vn, and Vill; Director, Emergency and Remedial Response Division, Region II;
Director, Hazardous Waste Management Division, Region III; Director, Air and Waste
Management Division, Region VI; Director, Toxics and Waste Management Division,
R(:gion IX; Director, Hazardous and Waste Division, Region X"), August 28, 1985
(discussing community relations activities at Superfund Enforcement sites).
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement.
futdaneerment Assessment Handbook, August 1985.
U.S. Environmental Protection Agency. Chemical. Physical. and Bioloiical Properties of
Q:)mpounds Present at Hazardous Waste Sites (OSWER Directive 9850.3),
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36.
37.
38.
39.
Page 28
28.
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, VII, and VIll; Director,
Emergency and Remedial Response Division, Region II; 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 and Michigan Department ofNaturaI Resources.
Field Screenine for Oreanic Contaminants in Samples from Hazardous Waste Sites,
April 2, 1986. .
L.
29.
30.
U.S. Environmental Protection Agency. Office of Health and Environmental Assessment.
Development of Advisory Levels for Polychlorinated Biphenyls (PCBs) Cleanup
(EPA 600/8-86/002, OHEA-E-187), May 1986.
31.
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. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), December 1988.
32.
33.
"Guidelines for the Health Risk Assessment of Chemical Mixtures," Federal Reeister
(Vol. 51, No. 185), September 24, 1986.
34.
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 Emergency and Remedial Response.
Superfund Public Health Evaluation MamW (EPN540/1-86/060, OSWER Directive
9285.4-1), October 1986.
35.
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.
"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 Solid Waste and Emergency Response.
Test Methods for Evaluatine Solid Waste: Laboratory Manual Physical/Chemical Methods.
Third Edition (Volumes IA. lB. Ie. and II) (SW-846), November 1986.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Su?Crfund Selection of Remedy (OSWER Directive 9355.0-19),
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49.
50.
Page 29
40.
Memorandum from 1. 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, VII, and
VllI; Director, Emergency and Remedial Response Division, Region II; 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 VII (OSWER Directive
9355.0-19), December 24, 1986 (discussing interim guidance on Superfund selection of
remedy).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Federal-Lead Remedial Project Manaiement Handbook (EPA/540/G-87/001,
OSWER Directive 9355.1-1), December 1986.
41.
42.
U.S. Environmental Protection Agency. Office of Ground-Water Protection. Guidelines
for Ground-Water Classification under the EPA Ground-Water Protection StrateiY, .
December 1986.
43.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
.superfund Glossary (WHIFS-86-007), Winter 1986.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Technolo&y Briefs: Data ReQuirements for Selectin& Remedial Action
J'echnoloiY (EPA/600/2-87/001), January 1987.
44.
45.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Quality Objectives for Remedial Response Activities: Development Process
O~PAJ540/G-87/003, OSWER Directive 9355.0-7B), March 1987.
46.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement Data
Qpality Obiectives for Remedial Response Activities - Example Scenario: RIIFS Activities
at a Site with Contaminated Soils and Groundwater (EPA/540/G-87/004, OSWER Directive
9355.0-7B), March 1987. .
47.
U.S. Environmental Protection Agency. Office of Water Regulations and Standards.
Quality Criteria for Water 1986 (EPA/440/5-86/001), May 1, 1987.
48.
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 final guidance for the coordination of A TSDR health
assessment activities with the Superfund remedial process).
U.S. Environmental Protection Agency. Quality Assurance Management Staff. Guidelines.
il]d Specifications for Preparin& Quality Assurance Pro&ram Documentation, June 1987.
Memorandum from 1. 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 I, IV,
V, VIT, and VIII; Director, Emergency and Remedial Response Division, Region II;
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
-------
59.
60.
61.
62.
Page 30
51.
Memorandum from David P. Ryan, EPA Headquarters to Addressees (Assistant Regional
Administrators; Management Division Directors; Senior Budget Officers; Regional
Comptrollers; Waste Management Division Directors; ESD Directors of Regions I, VI, and
VII; Director, Office of Emergency and Remedial Response; Director, Office of Waste
Programs Enforcement; Financial Management Officers), July 15, 1987 (Discussing
determination of indirect costs in Superfund Removal project ceilings (Comptrollers Policy
Announcement No. 87-15».
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, vn, and VITI; Director, Emergency and Remedial Response Division, Region II;
Directors, Hazardous Waste Management Divi~ion, Regions III and X; Directors, Toxics
and Waste Management Division, Region IX (OSWER Directive 9355.0-20), July 23, 1987
(discussing RI/FS improvements).
52.
53.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions, (OSWER Directive
9355.0-21), July 24, 1987.
54.
Memorandum from Francis S. Blake, General Counsel, to 1. Winston Porter, Assistant
Administrator for Solid Waste and Emergency Response, July 31, 1987 (discussing the
scope of the CERCLA petroleum exclusion under sections 101 (14) and 104 (a) (2».
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Alternate Concentration Limits Guidance (QSWER Directive 9481.00-6C,
EPA/530-SW-87-017), July 1987.
55.
56.
U.S. Environmental Protection Agency. Environmental Research Laboratory. Role of
Acute Toxicity Bioass<\ys in the Remedial Action Process at Hazardous Waste Sites
(EPA/600/8-87/044), August 1, 1987.
57.
U.S. Environmental Protection Agency. Center for Environmental Research Information.
A Compendium of Technoloiies Used in the Treatment of Hazardous Waste
(EPA/625/8-87/0l4), September 1987.
58.
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 Drinkini Water Sites (OSWER Directive 9360.1-01),
October 6,1987.
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 Emergency and Remedial Response.
Public Involvement in the Superfund Proiram (WHIFS-87-004R), Fall 1987.
Memorandum from 1. 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 Solid Waste and Emergency Response.
Draft Guidance on CERCLA Compliance with Other Laws Manual (OSWER Directive
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71.
72.
73.
74.
Page 31
63.
u.s. Environmental Protection Agency. Office of Emergency and Remedial Response.
A Compendium of Superfund Field Operations Methods (OSWER Directive 9355.0-14),
December 1987.
64.
"Estimated Soil Ingestion Rates for Use in Risk Assessment," Risk Analysis
(Vol. 7, No.3), 1987.
65.
u.S. Environmental Protection Agency. Hazardous Evaluation Division. Laboratory Data
Yalidation Functional Guidelines for Evaluatin~ Organics, February 1, 1988.
66.
u.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Conductin& Remedial Investi&ations and Feasibili~ Studies
ynder CERCLA (Comprehensive Environmental Response. Compensation. and Liabili~
i~ October 1988.
67.
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 information on drinking water
a,ction 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 IT; Directors,
Hazardous Waste Management Division, Regions III 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 RllFS improvements
follow-up).
68.
.
69.
U.S. Environmental Pro~ection Agency. Office of Emergency and Remedial Response.
Superfund Exposure Assessment Manual (EPA/5401l-88/001, OSWER Directive
9285.5-1), April 1988. '
70.
U.S. Environmental Protection Agency. Office of Research and Development and Office of
Drinking Water. Drinkin~ Water Criteria for Polychlorinated Biphenyls (PCBs) (Final)
(ECAO-CIN-414), April 1988.
Memorandum form J. 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, V, VII, and
vrn; Director, Emergency and Remedial Response Division, Region IT; 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 Water. Interim Sediment Criteria Values
fur Nonpolar F{ydrophobic Organic Contaminants (SCD #17), May 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
.communi~ Relations in Superfund: A Handbook (Interim Version) (EPA/540/G-88/OO2,
OSWER Directive 9230.0-3A), June 1988.
U.S. Environmental Protection Agency. Hazardous Site Evaluation Division. Laboratory
-------
. 80.
84.
85.
86.
Page 32
75.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (CoIT\Prehensive Environmental Response. Compensation. and Liabilitv 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.
Technoloi)' Screenini Guide for Treatment of CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) Soils and Sludies (EPA 540/2-88/004),
September 1988.
76.
77.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Field Screenini Methods Cataloi: User's Guide (EPA/540/2-88/005), September 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. .
~~~a;~~~~~~~~:~:~::n~~~~s~~~~~~~:~~~ti~~~s~~~i3l~~e~~t~~~~t~~~n~)
(EPA/540/G-89/004, OSWER Directive 9355.3-01), October 1988.
78.
79.
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. .
81.
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:
recommendation No. 26).
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.
82.
Interagency Cooperative Publication. Federal Manual for Identifyin~ and Delineatini
Jurisdictional Wetlands, January 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 II; Directors, Hazardous Waste Management Division, Regions III, VI; Director,
Toxic and Waste Management Division, Region IX; Director, Hazardous Waste Division,
Region X"), February 9, 1989 (discussing interim final guidance on soil ingestion rates).
83.
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.
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 Desi~n. Construction. and Closure
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97.
98.
99.
100.
Page 33
87.
Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I,
N, 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 IT and Gerald Emison, EPA 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).
88.
89.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Land Disposal Restrictions: Summary of Requirements, June 1989.
.
90.
U.S. Environmental Protection Agency. Risk Assessment Work Group, Region I.
SJ.Hwlemental Risk Assessment Guidance for the Superfund Pro~ram (Draft Final)
(EPA/901l5-89/oo1), June 1989.
"Protection of Environment," Code of Federal Re~ulations (Title 40, Parts 190-299),
Revised as of July 1, 1989.
91.
92.
"Land Disposal Restrictions for Certain 'California List' Hazardous Wastes and
Modifications to the Framework (Final Rule)," Federal Re~ister (Vol. 52, No. 130),
July 8, 1989.
93.
Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division, Region I to Merrill S. Hohman, Waste Management
Division, Region I (QSWER Directive 9355.0-28), July 12, 1989 (discussing air stripper
control guidance). .
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
.s..uperfund LDR Guide #1. Overview of RCRA Land Disposal Restrictions (LDRs)
(OSWER Directive 9347.3-01FS), July 1989.
94.
95.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #2. Complyin~ With the California List Restrictions Under Land
L>isposal Restrictions (LDRs) (OSWER Directive 9347.3-02FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
~uperfund LDR Guide #3. Treatment Standards and Minimum TechnolQ~y Requirements
lTnder Land Disposal Restrictions (LDRs) (OSWER Directive 9347.3-03FS), July 1989.
96.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
~uperfund LDR Guide #4. Complyin~ With the Hammer Restrictions Under Land Disposal
Restrictions (LDRs) (OSWER Directive: 9347.3-04FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency RespOnse.
Superfund LDR Guide #5. Detenninin~ When Land Disposal Restrictions (LDRs) 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. Q.ptainin~ a Soil and Debris Treatability Variance for Remedial
A&tiQm. (OSWER Directive: 9347.3-06FS), July 1989.
~p~~nn~~;~~n~~~:ti~E~el~~~o~~~e~~: ~~:~f~ ~~~~~~~~i~n of the
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107.
108.
109.
110.
111.
112.
113.
114.
Page 34
101.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on ~arini Superfund Decision Documents (OSWER Directive
9355.3-02), July 1989.
102.
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.
"RCRA Regulations," Code of Federal Reiulations (Title 40, Part 264), July 1989.
103.
104.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (Comprehensive Environmental Response. Compensation. and LiaIDlity Act)
Compliance with Other Laws Manual - Part II: 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 Emergency and Remedial Response.
Evaluation of Ground Water Extraction Remedies. Volume 1. Summary Report
(EPA/540/2-89/054), September 1989.
105.
106.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Discussine Considerations in Groundwater Remediation at Superfund Sites (OSWER
Directive 9355.4-03), October 18, 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
Requirements (OSWER Directive 9234.2-04), October 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Determinini Soil Response Action Level Based on Potential Contaminant Miiration to
Ground Water: A Compendium 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 Pump-and-Treat Remediations
(EPA/540/4-89/005), October 1989. .
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Develo-,pment and Screenini of Remedial Action Alternatives
(OSWER Directive 9355.3-0IFS3), November 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Gettini Read,y Scopini the RIfFS (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 Treatability Studies
(OSWER Directive 9355.3-01FS2), November 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
State and Local Involvement in the Superfund Proiram (9375.5-01/FS), Fall 1989.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund - Volume I: Human Health Evaluation Manual
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119.
120.
121.
122.
123.
124.
125.
126.
SI
Page 35
115.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #7. Detenninin~ When Land Disposal Restrictions r'LDRs) are
l~elevant and Ap,prQpriate to CERCLA Response Actions. (OSWER Directive
9347.3-08FS), December 1989.
116.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
!:ERCLA Compliance with Other Laws Manual - CERCLA Compliance with State
RCQuirements (OSWER Directive 9234.2-05/FS), December 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
{:ERCLA Compliance with Other Laws Manual - Overview of ARARs - Focus on ARAR
.waivers (publication 9234.2-03/FS), December 1989.
117.
118.
U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
Technolo~y Evaluation Report: SITE Prof:1'UTl Demonstration of the Ultrox International
IJltraviolet Radiation/Oxidation Technolo~ (EPA/540/5-89/012), January 1990.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - CERCLA Compliance with t}1e CW A and
S.IDY.A (OSWER Directive 9234.2-06/FS), February 1990.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
1ne Feasibility Study: Detailed Analysis of Remedial Action Alternatives (OSWER
Directive 9355.3-01FS4), March 1990.
"A Field Evaluation of the UV /Oxidation Technology to Treat Contaminated Groundwater,"
IlMC. Marchi April 1990.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
BOD Annual Report: FY 1989 (EP A/540/8-90/(06), Apri11990.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Summary of Part II - CAA. TSCA. and
Qther Statutes (OSWER Directive 9234.2-07/FS), Apri11990.
"Control Technology: A Field Demonstration of the UV /Oxidation Technology to Treat
Groundwater Contaminated with VOCs," Journal of the Air & Waste Mana~ement
hssociation (Vol. 40, No.4), April 1990, pp. 540-47.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
EPA Guide for Identifyin~ Oeanup Alternatives at Hazardous Waste Sites and Spills:
Bioloeical Treatment (EPA/600/3-83/063).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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