United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01-91/062
September 1991
EPA Superfund
Record of Decision:
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502T2-101
REPORT DOCUMENTAT10N It. REPOATNO.
PAGE EPA/ROD/ROl-91/062
I &
a. AIdpIenI'. Acce88Ion No.
'18 ...~
JPERFUND RECORD OF DECISION
Dover Municipal Landfill, NH
First Remedial Action - Final
7. Aulhor(.)
L Report Date
09/10/91
L
L PiIIforming OrgMlzallon Rapt. No.
8. Performing Orglllnbaton ...... ... Add!-.
to. ProJeclfT-*lWOIk Unit No.
I
"
11. Contr8c1(C) or Gnnt(G) No.
(C)
(G)
t2. ~ Or;8nIzIdon ...... ... Add!-.
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
t3. Type of Report & P8IIod Covered
Agency
800/000
t4.
tL SUppl8m8ntary No..
1e. Ab8tract (Unlit: 2110 _Ide)
The 55-acre Dover Municipal Landfill site is an inactive landfill in Dover, Strafford
County, New Hampshire. Land use in the area is rural-residential and recreational.
The site overlies both an upper and a lower aquifer that are separated by impermeable
clay. Significant nearby surface water bodies include the Bellamy reservoir located
2,000 feet south of the site, which supplies drinking water for local municipalities;
\e Calderwood well, which supplies drinking water for the City of Dover, and is
.ocated approximately one-half mile north of the landfill; and the Cocheco River, which
runs approximately 500 feet east of the landfill. A portion of the site lies within
the 100-year floodplain of the Cocheco River, and four wetland systems are in the
vicinity of the site. From 1960 until 1979, the landfill accepted municipal and
industrial wastes including drummed materials and liquid wastes. Landfill disposal
practices included trenching, burning, and fill and cover methods. Between 1980 and
1982, the facility was capped and closed, and a drainage channel was excavated around
the landfill to intercept leachate. In 1981, VOC contamination was found in private
residential wells screened in the upper aquifer in the vicinity of the landfill.
Further analyses identified two contaminant plumes, one migrating to the south and the
(See Attached Page)
17. O-tAn8/y818 L D88crIpCoIS
Record of Decision - Dover Municipal Landfill, NH
First Remedial Action - Final
Contaminated Media: soil, sediment, sludge, debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, vinyl
metals (arsenic)
b. IcI8n~EncWT-
chloride), other organics,
Co COSA 11 R8IcIIGtcqI
~ . ~Iabllty ~
tl. S8curtty Ct8M (11\18 Report)
None
20. S8curtty Ct8M (ThI8 Page)
f\Tnn""
21. No. of Palle.
280
22. PrIce
(SH ANSl-m.1S)
s..1MIructI- on "--
. FORM 272 (4.77)
(fonn8lfy NTlS-35)
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EPA/ROD/ROl-91/062
Dover Municipal Landfill, NH
r ~t Remedial Action - Final
Abstract (Continued)
other moving to the east. This Record of Decision (ROD) addresses both source control
and management Qf migration of contaminated ground water, as a final remedy. The
primary contaminants of concern affecting the soil, sediment, sludge, debris, and
'ground water are VOCs including benzene, PCE, TCE, toluene and vinyl chloride; other
organics; and metals including arsenic.
The selected remedial action for this site includes excavating and consolidating
approximately 300 cubic yards of sediment from the drainage channel, and depositing the
material into the landfill prior to capping; recontouring and. capping the landfill with
a multi-media cap including installing a passive venting system for methane gas; ground
water pumping and onsite treatment of the southern plume ground water and leachate
using aeration for VOC removal, carbon adsorption to remove other organics, and
flocculation, coagulation, and precipitation, followed by discharge of the treated
water onsite to surface water or offsite to the Dover publicly owned treatment works
(POTW); disposing of residual sludge offsite; constructing a clean ground water
diversion system upgradient of the site; natural attenuation of the eastern plume
ground water; constructing a surface water run-on/run-off diversion system; conducting
long-term ground water monitoring; and implementing institutional controls, including
deed and ground water use restrictions. If it is determined that the selected ground
water treatment remedy for the southern plume is not effective, a contingency remedy
that utilizes precipitation and air stripping will be implemented. The estimated
present worth cost for this remedial action is $24,155,700, which includes an annual
0.~ cost of $157,680 for 10 years and an annual cost for ground water monitoring of
1,600 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Sediment in areas where arsenic levels are above
50 mg/kg will be excavated and consolidated under the landfill cap., Ground water
interim clean-up goals are based on the more stringent of Federal MCLs or non-zero
MCLGs, EPA Health Advisories, State standards, or reference doses, and include arsenic
50 ug/l (RCRA MCL) or background, whichever is higher, benzene 5 ug/l (MCL), PCE 5 ug/l
(MCL), and TCE 5 ug/l (MCL). The final ground water clean-up levels will be determined
as a result of a risk assessment performed on residual ground water after all interim
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#-~ 87J1'P.
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~41 :::;'
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203.2211
DECLARATION FOR THE RECORD OF DECISION
Cover Municipal Landfill
Dover, New Hampshire
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for the Dover Municipal Landfill site in Dover, 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 ~xtent practicable, the National ~il and
Hazardous Substances contingency Plan (NCP), 40 CFR Part 300 ~.
~., as amended. The Region I Administrator has been delegated
the authority to approve this Record Of Decision. .
The State of New Hampshire has concurred on the source control
and eastern ' plume management of migration portions of the
selected remedy and has reserved a concurrence decision for the
southern plume management of migration portion of the selected
remedy.
STATEMENT OF B~SIS
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 Dover Public Library
in Dover, New Hampshire and at the Region I Waste Management
Division Records Center in Boston, Massachusetts. The
Administrative Records Index (Appendix E to the R9D) 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.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for Dover Municipal
Landfill Site, which addresses source control and management of
migration to meet cleanup goals. The selected remedy is multi-
tasked. The remedial measures will protect the drinking water
aquifer by minimizing further migration of contaminants to the B~&TO.~
, ,
.. ..
.. . ...
\J '. ~
... ~
,:) ~ ~. ~
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groundwater and surface water, will eliminate threats posed by
direct contact with or ingestion of contaminated soils and wastes
at the Site and will prevent the ingestion and direct contact
with contaminated groundwater and surface water.
The ~~j=~ components of the selected remedy include
.
Recontouring of the existing landfil11
Consolidation of sediments in the perimeter drainage
ditch;
Limited excavation and consolidation of sediments in
the drainage swale and at the confluence to the Cocheco
River;
Capping of the landfill;
Upgradient groundwater diversion;
Groundwater/leachate collection and treatment;
Pre-design studies which include the installation of
additional monitoring wells;
Natural attenuation of the "eastern" plume;
Groundwater Extraction and treatment DŁ the "southern"
plume;
Long-term environmental monitoring;
Institutional Controls, where possible.
t.;
.
.
.
.
.
.
.
.
.
.
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 principle
element to reduce toxicity, mobility, or volume of hazardous
substances.. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
As this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
hea h and the environment.
Iffl
lie Belaga
Regional Administrator
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~ "'''/P.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS 02203-2211
u.s. ENVIRONMENTAL PROTECTION AGENCY
REGION 1
RECORD OF DECISION
DOVER MUNICIPAL LANDFILL SITE
DOVER, NEW HAMPSHIRE .
1It.&/O'9j1'
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Contents
II.
III.
IV.
VI.
VII.
VIII.
IX.
XI.
ROD DBCISION SUMMARY
Dover Municipal Landfill
TABLE OF COH'l'EH'l'S
I.
8ITE NAHB, LOCATIOIJ AND DESCRIPTION. . .
8ITB HISTORY' BNFORCBMBH'l' ACTIVITIBS . .
. . . . . .
. . .
. . .
A.
B.
Land Use' Response History. . . .
Bnforcement History. . . . . . . .
. . ...
. . . .
. . .
. . .
COHMUHITY PARTICIPATION. . . .
. . . .
. . . . . . .
SCOPB , ROLB OF OPBRABLE UNIT OR RESPONSB ACTION
. .
V.
8UMMARY OF SITB CHARACTBRISTICS .
. . . . . .
. . . .
8UMMARY OF SITB RISKS. .
. . . .
. . .
. . . .
. . .
DBVBLOPHBH'l' AND SCREBNING OF ALTBRNATIVES .
. . . ...
A.
B.
Statutory Requirements/Response Objectives. . .
Technoloqy and Alternative Development
. and screening. . . . . . . . . . . . . . . . . .
DB SCRIPTION OF ALTBRNATIVES . . . . . . . . .
. . . .
A.
B.
80urce Control (SC) Alternatives Analyzed. . . .
Management of Migration (MH)
Alternatives Analyzed. . . . . . .. . . . . . . .
SUMHARY OF '1'BB COMPARATIVE ANALYSIS OF ALTBRNATIVES .
X.
'1'BB SBLECTBD RBHBDY . . . . . . . .
. . . . . . . . .
A. Cleanup Levels. . . . . . . . . . . .
B. Description of the aemedial Components
. . . . .
. . . . .
STATUTORY DBTBRMINATIONS
. . .
. . . .
. . . .
. . .
A.
The Selected Remedy is Protective of Human
Health and the Bnvironment .. . . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . .
The Selected Remedial Action ia Coat Bffective .
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Bxtent Practicable. .
The Selected Remedy satisfies the Preference
for Treatment as a principal Blement . . . . . .
B.
c.
D.
B.
paoe NUmber \)
1
4
4
6
7
8
9
18
23
23
24
2S
2S
31
36
46
46
51
61
61
62
67
73
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XII.
XIII.
DOCUMENTATION OP SIGNIPICANT CHANGES
STATE ROLE
APPENDICES
APPENDIX A
, APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
APPENDIX H
. . . . .
. . . . . . . . . . . . . . . .
. . .
Figures
Tables
Provisional RfD for Tetrahydrofuran
New Hampshire Letter of Concurrence
ARAR Tables, .
statement of Findings - Wetlands and
Responsiveness Summary
Administrative Record Index
. . .
75
7&
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ROD DECISIOH SttHKARy
DOVER MUNICIPAL LAHDPILL SITB
DOVER LANDPILL ROD' DECISIOH SttHKARy
SEPTEMBER 10, 1"1
~
I.
SITE ~, LOCATION AND DESCRIPTION
A.
General Description
The Dover Municipal Landfill Site (the Site) 'is a 55-acre
inactive landfill in Dover, Strafford County, New Hampshire. The
Site is located in the western corner of Dover, at the
intersection of the Dover, Barrington and Madbury town lines. A
locus map showing the general location of the Site is included in
Appendix A as Figure 1.
About one-half mile north of the Site. is the Calderwood Well,
which supplies roughly 20 percent of the drinking water to. the
City of Dover. About 2000 feet south of the Site is the Bellamy
Rese~~oir which provides drinking water for Portsmouth,
Newcastle, Newington, Durham, Madbury, Greenland and Rye, New
Hampshire. The Cocheco River lies 500 feet east of the Site.
The topography to the north, south and southeast of the Landfill
is relatively flat. To the east, the topography is more
undulating with a sharp drop in elevation toward the Cocheco
River. Wetlands predominate northwest, west and southwest of the
Landfill. The Landfill is bordered by Tolend Road and Glen Hill
Road on the North, by Tolend Road on the east, and by private
property on the southeast and the south. The Site is located in
.a rural area, although land along the east" side of Tolend and
Glen Hill Roads has been subdivided for residential use. A number
of homes are located along these roads. Recreational uses near
the Site include fishing in both the Cocheco River and the
Bellamy Reservoir.
Additional in~ormation regarding the characteristics of Dover,
New Hampshire may be found in Section 2, pages 2-1 and 2-2 of the
Remedial Investigation (RI) conducted by the State of New .
Hampshire's contractor; Wehran Engineers and Scientists (Wehran)
and ;r ~p.~~.~n 2, page 2-1 of the Field Element Study conducted
by HMM Associates, Inc (HMM), the contractor for the Dover
Landfill PRP Steering Committee. Site characteristics,
analytical results and remedial alternatives have been presented
in the following documents'prepared by Wehran and HMM:
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ROD DECISION 8UHMARY
~VER MUNICIPAL LAHDPILL SITB
Remedial Investiaation ReDort. Dover MuniciDal Landfill.
Dover. New HamDshire.. Wehra~ Engineers and Scientists,
November 1988.
Field Elements StudY and SupDlemental Risk Assessment for
the Municipal Landfill. Dover. New HamDshire, Hmm
Associates, Inc., February, 1991.
Dover MuniciDal Landfill Feasibilitvstudv. Dover. New
Ha~Dshire, HMM Associates, Inc., Februa.ry, 1991.
B.
Geology and Hydrology of the site
The geology of the Site area is typical of the southeastern New
Hampshire region. Unconsolidated overburden deposits, generally
of glacial origin, are underlain by consolidated, usually
metamorphio, bedrock. Unconsolidated overburden deposits include
a wide variety of grain sizes reflecting historic changes in
depositional environment. These deposits appear to divide into
two generalized aquifer units, an upper and lower, separated by a
clay aquitard that appears to have effectively limited
groundwater contamination to the upper aquifer.
The upper aquifer unit contains a sand zone and an underlying
finer grained, interbedded zone. The sand zone is composed of
fine to medium grained sand with occasional silt and organic
matter and traces of clay sized material. The sand unit ranges
in thickness from 10 feet (at well B-12L) to 33 feet (MW-105U).
The interbedded zone above the clay aquitard (the upper
interbedded zone) consists of interbedded silt and clay layers.
This unit has lateral and vertical hydraulic conductivities less
. permeable than the overlying sand, and ranges in thickness from
o feet (MW-106L) to 70 feet (MW-102U).
The clay aquitard consists of a gray marine clay unit with very
low permeability. The clay unit thickness ranges from 12 feet
(MW-106L) to 42 feet (MW-105U).. The upper surface of the unit is
at a higher elevation and near land surface north and west of the
Landfill at wells B-13, B-14 and MW-106. The upper surface is
irregular and depressions or localized lows may occur in the
vicinity of wells B-4, B-6, B-8 and B-2. This unit appears to
pinch out in the vicinity of B-14; north of this location the
lower and upper aquifers are no longer separated by a low
permeability unit.
The lower aquifer unit has three distinct zones, none of which
are continuous.. Just below the clay zone is the lower
interbedded zone.which exhibits grain sizes and permeabilities
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ROD DBCISION SUKHARY
DOVER MUNICIPAL LANDPILL SITB
similar to that of the upper interbedded zone. This zone is
thick~~~ ('lP to 50 feet at B-1) north of the Landfill, where it
also contains a thick sandy zone. ,It appears to terminate south
and west of the Landfill. Its permeability characteristics
appear similar to those of the upper interbedded zone. Beneath
the lower interbedded zone is a highly permeable sand and gravel
zone. Its thickness is quite variable. At MW-101, next to the
Landfill, it is approximately 20 feet thick, while east of this
location at B-9 it is approximately 40 feet thick. West or
northwest of MW-101 it appears to pinch out (as between B-7 and
MW-106). This zone is hydraulically connected to the Calderwood
Well, and may provide a significant proportion of the water
derived from that well. Beneath the sand and gravel zone is a
tightly packed poorly sorted glacial till of low permeability.
Where till occurs it lies directly on the bedrock; where till
does not occur, the sand and gravel zone lies directly on the
bedrock.
The Landfill is underlain by rocks of the Berwick Formation.
Rock samples recovered were predominantly unweathered to slightly
weathered micaceous quartz-biotite granobels. Sulfides
(pyrrholite, massive pyrite) were observed to be common accessory
minerals. Other lithologies observed included calc-silicate and
carbonaceous phyllitic siltstone.
The bedrock appears to be moderately fractured with occasional
highly fractured zones. Fractures generally paralleled bedding
and foliation. Orientation of the fractures was generally in a
northeast-southwest direction with dip angles moderate to steep
toward the north. The depth to bedrock varies from about 23 feet
(B-3R) to about 143 feet (B-11R) below land surface. The bedrock
high of 130 feet above sea level is at B-3, and it slopes
southward and eastward to a known low of about 11 feet below sea
level at B-12R~
Groundwater in the upper aquifer moves essentially from.an area
north of the Landfill south towards the Bellamy Reservoir and
east to the Coeheco River. To a lesser degree, groundwater also
'moves downward through the upper aquifer. Movement of
groundwater into 'the lower aquifer is effectively inhibited by
the presence of the marine clay aquitard.
Groundwater movement in the lower aquifer (in the landfill
vicinity) moves northeastward under the influence of the pumping
of the Calderwood Well. Water levels in the bedrock aquifer
suggest upward movement into the lower aquifer and lateral
movement towards the Calderwood Well.
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ROD DBCISIOH SUMMARY
OVER MUHICIPAL LAHDPILL SI'1'B
Additional information about the site geology and hydrology can
be found in the Remedial Investigation on pages 5-1 through 5-29
and in the Field Element study on pages 2-26 through 2-28 and
pages 3-16 through 3-31. . .
c.
Groundwat.r supply
Two public water supplies are located in the vicinity of the
landfill, the Calderwood well and the Bellamy Reservoir. The
Calderwood well is located one half mile north of the site. The
Calderwood Well is a gravel-pack well approximately 114 feet
deep. It is currently pumped at a rate of approximately 400 to
500 gpm or 576,000 to 720,000 gallons per day (GPD). .
The Bellamy Reservoir is located approximately 1,700 south- .
southwest of the landfill and is a drinking water supply for the
towns of Portsmouth, Newcastle, Newington, Durham, Madbury,
Greenland, and Rye, New Hampshire. The drainage basin for the
reservoir comprises approximately 22 square miles. The 420-acre
reservoir has an average depth of 6 to 7 feet and an estimated
usable storage capacity of 865 million gallons. Two water
intakes connected to the City of Portsmouth Water Treatment
Facility are located at the reservoir dam on Mill Hill Road,
approximately 2 miles to the south of the Site.' 2.0 to 2.8
million gallons per day (mgd) of water from the reservoir is
treated prior to release into the Portsmouth water supply
distribution system.
Residential wells near the site obtained water from both the
lower and upper aquifer. In 1981, contamination was found in the
residential wells closest to the site and situated in the upper
aquifer, which also underlies the Landfill. The City of Dover
installed a w~ter supply line along Glen Hill and Tolend Roads
during 1983, and residents closest to the site were connected to
the main at that time. Additional residential connections,
further from the Landfill, continued until the fall of 1989.
A more complete description of the Site can be found in the
Remedial Investig~tion Report on Pages 2-1 through 2-4, 4-3,and
4-4 and in the Field Element Study on pages 2-4 through 2-8.
II.
SI'I'B HISTORY UtD BHFORCBKBH'I' ACTIVI'1'IBS
A.
Land u.. and a.spon.. History
operation of the Dover Municipal Landfill reportedly began about
1960 and ceased in 1979. The Dover Municipal Landfill accepted
wastes, including liquids and sludges from both domestic and
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ROD DECISION BUKKARY
DOVER MUNICIPAL LAHDPILL SITE
industrial sources. The waste materials included, among other
things, domestic and industrial sludges, shoe and leather tanning
waste products, organic solvents, "waste oil, and municipal solid
waste. Table 1 found in Appendix B of this ROD provides a list
of the types of industrial wastes, compiled from an industrial
waste survey taken by The state of New Hampshire in 1976, that
were disposed of at the Landfill from 1976-1977. Closure
operations at the Site, conducted by the City of Dover, included
a sandy-loam cover and surface water/leachate drainage channel
construction, and site access control. .
Landfill disposal practices varied during operation. They
evolved from trenching, to burning, "to a fill and cover method in
1962. Fill and cover operations were begun at the eastern
portion of the present Landfill area and progressed westward
until 1977 where it appears the current areal extent of the "
Landfill was reached. Disposal continued at the Landfill on top
of previously deposited material. Drums of industrial waste were
accepted at the Landfill until at least 1975. Since detailed
records of each load of refuse brought to the Landfill were not
kept, a detailed quantification and characterization of the waste
buried cannot be calculated.
Liquid wastes were historically brought to the Landfill and
reportedly disposed of by being poured onto the surface of
existing refuse~ If the wastes were flammable, during the early
years of the Landfill's operation they were ignited and burned.
Empty containers, such as drums, were crushed and disposed of
with the municipal refuse. Some chemical wastes were known to
have been disposed of at the Landfill while still in drums.
Landfill closure operations, by the City of Dover,. consisting of
placing clean fill over the existing material, were completed in
March, 1980. One or two years later, the Landfill was closed for
the interim as a part of a cooperative effort between the State
. and the City of Dover, and the drainage ditch was re-excavated
around the Landfill consistent with its current configuration tor
the purpose of intercepting leachate and thereby limiting"
off-site contaminant migration.
Dover City officials along with the New Hampshire Water Supply
and Pollution Control Commission (the Commission has since been
incorporated as a Division within the New Hampshire Department of
Environmental Services and is herein referred to as th~ NHDES)
initiated a groundwater monitoring program at the Landfill in
1977. In 1980, the monitoring program was expanded to include
several residential wells. Contamination was first found in a
private residential well near the Landfill in February, 1981.
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ROD DBCISI08'SUHHARY
DOVER MUNICIPAL LAHDPILL SITB
Subsequent samples, collected by the NHDES, were taken to
determine whether the Landfill was the source of the
contamination detected in the private water supplies. Surface
water sampling and analyses were conducted by the NHDES in March
and 'April, 1977, and by the City of Dover and the City of
Portsmouth Water Departments in April, May and September, 1981
and in March, 1982.
The Landfill was evaluated as a potential haz~rdous waste site by
the U.S. Environmental Protection Agency (EPA), ranked, and
proposed for the EPA's National Priorities List (NPL) on December
30, 1982. The site was placed on the NPL on September, 8, 1983.
In accordance with the requirements of the National Contingency
Plan (NCP), a Remedial Action Master Plan (RAMP) was prepared for
the site in 1983. The RAMP included a recommended scope of
services for remedial action planning activities at the site, and
called for completion of a Remedial Investigation/Feasibility
Study.
The Remedial Investigation (RI) for the Dover Municipal Landfill
was conducted by the NHDES under a cooperative agreement with the
EPA. The NHDES contracted with Wehran Engineers and Scientists
to conduct the RI. The Field Element Study (FES), which
addresses the data gaps of the RI, and the Feasibility Study eFS)
were conducted by a group of Potentially Responsible Parties
(PRPs.) for the Site under an Administrative Order by Consent with
EPA. The PRPs contracted with HMM Associates, Inc. to conduct
these activities. The RI was completed in March 1989 and the FES
and FS were completed in February 1991.
A more detailed description of the site history can be found in
the Remedial Investigation Report on pages 1-5 through 1-9 and in
the Field Element Study on pages 2-1 through 2-8.
B.
Enforcement Hi.tory
In the spring of 1987 the City of Dover and several Dover
businesses formed a PRP group and expressed to the Agency an
interest in undertaking the Feasibility Study CFS) and filling
the data gaps left by the RI. Negotiations between EPA and the
PRP group were undertaken in the late summer 1987. After
extended neoqtiations, the City of Dover and eight businesses
signed an Administrative Order by Consent CAO) with EPA and the
State of New Hampshire in July 1988. In that Order the PRPs
agreed to pay some past costs associated with the RI, to conduct
a Field Element Study (FES) to fill data gaps left by the RI, and
to conduct the FS. The Order also provided that additional
parties could sign-on without renegotiating the terms of the
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ROD DBCISIOH SUXMARY
DOVER KUHICIPAL LANDPILL SITB
Order: an additional fourteen (14) PRPs have since signed the
OrdeL. ~uc r~rS contracted with HMM Associates, Inc. to conduct
these activities. The FES and FS were completed in February
1991.
In late January 1988 the city of Dover and four businesses were
sent formal notice of their potential liability for the
remediation of the Site. In late March and early April 1991,
after an extensive PRP search, general notice was sent to 39
potentially responsible parties, including those PRPs already
sent notice. Copies of the proposed Plan were sent to all
noticed parties as well as to public. representatives and the news
media to provide an" opportunity to comment on the EPA's preferred
Remedial Alternative. On April 15, 1991 EPA met with the PRPs to
discuss their potential liability at the Site. At the request of
EPA, the PRPs have been active in forming a new steering
committee to consider the performance and financing of the
Remedial .Design and Remedial Action (RD/RA).
The PRPs have been active in the remedy selection process for
this site. Technical comments presented by PRPs during the
public comment period and at the Public Hearing were evaluated,
summarized in writing, and the summary and written comments are
included in the Administrative Record. .
III. COMMUNITY PARTICIPATION
Until April 1991, community concern and involvement at the site
had been relatively low. EPA has kept the community and other
interested parties apprised of the Site activities through
informational meetings, fact sheets, press releases and public
meetings. .
During December, 1984, EPA released a community relations plan
which outlined a program to address community concerns and keep
citizens informed about and involved in activities during.
remedial activities'. On August 9, 1983 EPA and the NHDES held a
meeting at .the Dover city Hall auditorium to discuss the findings
and recommendations of the Remedial Action Master Plan (RAMP).
On December 13, 1984, NHDES held an informational meeting in the.
Dover city Hall auditorium to describe the plans for the Remedial
Inve~t~~~~i~~ ~"d Feasibility study. On March 30, 1989 NHDES and
the BPA held an informational meeting in the Dover City Hall
.auditorium to discuss the results of the " Remedial Investigation.
On March 16, 1991, BPA made the Administrative Record available
for public review at EPA's offices in Boston and at the Dover
Public Library in Dover, New Hampshire. EPA published a notice
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~OD DECISION SUMHARY
A>VER MUNICIPAL LANDPILL SITE
and brief analysis of the Proposed Plan in Foster's Daily
Democrat on March 22, 1991 and made the plan available to the
public at the Dover Public Library: The Proposed Plan included
notice of a proposed waiver for the Safe Drinking Water Act,
Maximum contaminant Level (SDWA MCL) for arsenic in groundwater.
On March 25, 1991 EPA held an informational meeting at the Horne
Street Elementary School to discuss the results of the Remedial
Investigation, Field Elements Study and the cleanup alternatives
presented in the Feasibility Study, and to present the Agency's
Proposed Plan. Also during this meeting, the Agency responded to
questions from the public. From March 26, 1991 to May 24, 1991,
the Agency held a sixty day public comment period to accept
public comment on the alternatives presented in the Feasibility
Study and the Proposed Plan and on any other documents previously
released to the public. On April 16, 1991 the Agency held a
public meeting to discuss the Proposed Plan and to accept any
oral commerits. A transcript of this meeting and the comments
from the general public, Dover and Madbury city officials and
from representatives of the Dover Landfill steering Co~ittee
along with the Agency's response to comments are included in the
attached Responsiveness Summary.
IV.
SCOPE AND ROLE OP RESPONSE ACTION
The selected remedy was developed by COmbining components of
different. source control and management of migration alternatives
to obtain a comprehensive approach for site remediation. In
summary, the remedy provides for recontouring the existing
landfill surface and construction of a 55-acre multi-layer cap
over the landfill to prevent infiltration and promote run-off and
the installation of a leachate and contaminated groundwater
collection system around the perimeter of the landfill. The
contaminated groundwater and leachate would then be treated on-
site by a powdered Activated Carbon Treatment system (PACTTM) or
equivalent system with discharge to the Cocheco River or .
pretreatment and discharge to the Dover Publicly owned Treatment
Works (POTN). There will be a limited excavation of the
contaminated sediments from the existing drainage swale. These
excavated sediments would be placed onto the landfill prior to
capping. Natural attenuation processes will be utilized to
attain groundwater cleanup levels in the eastern plume while a
groundwater extraction and treatment system will be employed to
attain cleanup levels in the southern plume.
The remedial action will address the following primary risks and
principal threats to human health and the environment posed by
the site: .
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ROD DECISION SttNKARy
I)()VER J(tJHICIPAL LAHDPILL SITE
-Further contamination of groundwater through the leaching'
of contaminants from the landfill.
-Direct contact with contaminated soils, sludge, sediments
and debris found in the Landfill.
-Ingestion of contaminated soils, sludges, sediments and
debris found in the Landfill.
-The off-site migration of contaminants in groundwater.
-Ingestion and direct contact with contaminated
groundwaters and surface waters.
Remedial activities at the Site are comprehensive and designed to
be a final remedy.
v.
8UKHARY OF SITE CHARACTERISTICS
Section 1 of the FS contains an overview of the Remedial
Investigation and Field Elements StUdy. Contami~atio~ at the
Site is a result of the disposal of hazardous ,substances in the
Landfill and the leaching of contaminants into the surrounding
groundwater, surface waters, soils and sediments.
Analysis of soil, groundwater, sediment and surface water from
areas in and around the Landfill indicate that the contamination
at the Site is found primarily in the groundwater, surface water
and sediments. The Landfill itself presents a potential threat
as it may conceal containers of hazardous substances.
The most prevalent contaminants identified in groundwater at the
Site are Volatile Organic Compounds (VOCs) such as 1,1,1-
Trichloroethane (TCA) and degradation products of TCA such as
. l,l-Dichloroethylene (DeE) and l,2-Dichloroethane (DCA); acetone,
benzene, toluene, and tetrahydrofuran. Also identified in the
groundwater are trichloroethYlene (TCE), ethylbenzene, XYlenes,
tetrachloroethylene, chloroethane, methyl ethyl ketone, methyl
iSobutyl ketone, vinyl chloride and methylene chloride. Arsenic
was the prevalent metal found in the groundwater.
The significant findings of the Remedial Investigation and Field
Element Study are summarized below.
A.
80il
Soil investigations were conducted at the Dover Landfill during
the Remedial Investigation and also during the Field Elements
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~OD DECISION SUKKARY
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study to address specific data gaps. Specifically, Base\Neutral "
and Acid extractable organic compound (BNA) contamination was
detected in the soils "between the drainage ditch and well cluster
B-13 during the RI. Contamination at these locations was found
" to be below minimum detection limits during FES investigations.
A limited study of the potential locations of buried drums at the
Landfill was conducted as part of the RI using surface
geophysics. Test pits (excavations into the waste material) were
also conducted. Crushed drums were found in many of the test pits
throughout the Landfill. No definable areas of excessively high
contamination, highly mobile sludges or large volumes of liquid
filled drums (hot spots) were found in any of the test pits in
the Landfill. The locations of the test pits can be seen in
Figure 2 of Appendix A of this ROD.
Soil samples were obtained from the unsaturated zone within
selected test pit excavations on the Landfill during the RI.
VOCs were detected in single soil samples obtained from the
following test pits:
Test pit and location at the Landfill
TotalVOC Concentration
TP-l -
TP-16-
TP-19-
TP-20-
northern part of the Landfill
northwestern part of the Landfill
southeastern part of the Landfill
southwestern part of the Landfill
475 ug/kg
8,410 uq/kq
680 ug/kg
20,330 ug/kg
Primary VOCs observed, in terms of relative concentration or
fr~quency include:
. ethylbenzene
. toluene
. xylene
. methyl butyl
. acetone
. methyl ethyl
ketone
ketone
Other soils sampled from the drainage ditch surrounding the
Landfill, including the wetlands and the discharge stream, are
described in the sediments discussion. "
B.
Surface Water
The RI included surface water and sediment samples from the
perimeter drainage ditch and discharge stream of the wetland
areas. Surface water samples did not detect the presence of
elevated levels of me~als or BNAs. VOC contamination was found
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ROD DECISION SUKKARY
DOVER MUNICIPAL LANDPILL SITE
in the surface water samples taken from the drainage ditch from
sampling lcc~tions SW-2 and SW-5. ,Samples taken during the RI
from SW-2 (from the northern and upgradient side of the Landfill)
contained total VOC concentrations as high as 1,819 ppb and the
SW-5 sample (from the east side of the Landfill) contained 431
ppb. These data indicate that the drainage ditch is a
predominant avenue for contaminant movement, including
groundwater discharge, flowing from the Landfill and discharging
into the Cocheco River.
The perimeter drainage ditch does not completely freeze over in
the winter, indicating that exothermic conditions are present as
a result of leachate from the Landfill entering the drainage
ditch and affecting water quality and temperatures. This
condition may also be a contributing factor with regard to the
limited vegetative establishment in and around the ditch.
Surface water samples were collected ~s part of the Field
Elements Study from the Cocheco River (a class B waterway), the
Bellamy Reservoir (a class A surface water), and the culvert
drainage area just northeast of Glen Hill Road as can be seen in
Figure 2. The total concentration of VOCs (BNAs and metals were
not analyzed) at SW-1 (taken at intersection of drainage
culverts) was 50 ppb and at SW-2 (taken at the point of discharge
to the Cocheco River) was 153 ppb. Additionally, EPA split
samples indicated the presence of a combined total of 19 ppb of
vinyl chloride, 1,2-dichloroethane, 1, 1, 1-trichloroethane,
trichloroethene, benzene, 1,1-dichloroethane and ethyl benzene
from station SW-2. VOCs identified in the surface water in the
drainage ditch included:
. acetone
. 1,2-dichloroethylene
. methylene chloride
. methyl ethyl ketone
. ,methyl isobutyl ketone
Samples from the Bellamy Reservoir indicated no detectable levels
of VOC contamination. The sampling of the Cocheco River
indicated VOCs at the intersection of the drainage swale and the
river (SW-2) and a trace amount of methylene chloride, further
downriver.
. tetrachloroethylene
. tetrahydrofuran
. toluene
. xylene
Surface water samples were also taken as part of the Treatability
study. Surface water samples were analyzed for various
parameters such as BOD, COD, TSS, etc. The complete list of
parameters analyzed for can be found on Table 1-5 of the FES.
Laboratory results for Treatability study surface water
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ROD DECISIOB SUMKARY
DOVER ~CIPAL LAHDPILL SITE
parameters are shown on Table 1-15 of the FES.
C.
Sediments
Sediment sampling occurred in four general areas during the RI:
the perimeter drainage ditch, the Cocheco River, the Bellamy
Reservoir and the wetland locations north and west of the
landfill. The highest levels of contamination were found within
the perimeter drainage ditch and at the discharge point of the
drainage swale into the Cocheco River. VOCs were detected in
sediment sample S-5, including methyl ethyl 'ketone and
trichloromethane at concentrations of 1700 and 400 ug/kg,
respectively. Cadmium and arsenic were detected above
anticipated background levels at stations S-5 and S-7. No VOC or
BNA contamination was detected in the Bellamy Reservoir.
Results of the. sediment sampling episode in the FES indicate some
elevated concentrations of metals, principally arsenic and
cadmium. The common range for arsenic in soils across the qnited
States is 1 to 50 ppm, and for cadmium it is 0.01 to 0.70 ppm.
Exceedances of the common range for arsenic were found at
stations SO-1, SO-3, and SO-6 with concentrations of 51, 210 and
99 ppm, respectively. Each of these samples were collected from
the drainage ditch around the Landfill or from the area where the
drainage ditch culverts discharge to the swale that runs to the
Cocheco River. Exceedances for cadmium were found at stations
SO-4, SO-9, SO-10 and SO-16 with concentrations of 1.54, 1.16,
1.41 and 3.31 ppm, respectively.
Both lead and mercury concentrations were elevated in off-site
station SD-2, and at station SD-9 located just upstream from
where the culvert drainage waters enter tbe Cocheco River. The
lead concentration from SO-16 (just south of Minichiello
Brothers), and SO-8 (on the floodplain of the Cocheco River),
were also relatively high. With the exception of suspected
laboratory contaminants that were detected in four BNA samples,
no other contamination was detected in the wetland sediments.
Sediment samples were collected for Total Organic Carbon (TOC)
and sediment grain size analysis. Results of the TOC laboratory
analysis are shown on Table 1-10 and results of the sediment.
grain size analysis on Table 1-11 of the FES. Actual laboratory
reports of the analysis are shown in Appendix III of the FES.
The discussion of sediments in the Remedial Investigation can be
found on pages 7-4 through 7-7 and in the Field Element Study on
pages 3-56 through 3-64.
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ROD DECISIOH SUHKARY
DOVER MUNICIPAL LANDPILL SITE
D.
Air
On Septewber 11, 1990, EPA's Environmental Services Division
(ESD) from Lexington, Massachusetts, conducted an eight hour air
sampling program at five locations on and around the Dover
Landfill site. The air sampling program involved collecting
eight-hour ambient air samples on prepared Tena~ sorbent
cartridges and analyzing these sample cartridges with a gas
chrom~tograph/mass spectrometer (GC/KS) at ESD's facility. The
five stations were selected by the EPA based on previously
obtained site-specific information and the objectives of this air
sampling program, and concentrated in. areas of high contamination
found in the drainage ditch and swale which discharges to the
Cocheco River.
The results, presented in Table 1-12 of the FS, showed low levels
of VOCs.in the air and were incorporated into the risk assessment
(Section 2.0 of the Feasibility study). The risk assessment
evaluated potential health effects to humans from exposure to the
contaminants at the concentrations detected.
In conjunction with this air sampling program, the EPA collected
surface water/leachate samples from three of the five air
sampling locations (locations '1, '3 and '4). The results from
the analysis of these surface water samples are listed in Table
1-13 of the FS. The results from the surface water sampling
program were evaluated to determine if volatilization of
contaminants from the discharge stream was impacting the levels
of contaminants in the ambient air on and around the site. The
analytical results from the air samples collected from locations
not impacted by the leachate in the drainage ditch (stations #2
and '5) and the stations impacted by volatilization of
contaminants from the leachate in the drainage ditch (stations
'1, '3 and '4) indicate that there is no significant impact to
the on-site, ambient air quality from volatilization of
contaminants from the leachate in the drainage ditch.
B.
..tlands ADalysis
Wetland scientists from HMM Associates carried out a limited
field investigation on March 27, 1990 of the wetland resource
areas identified within and adjacent to the boundaries of the
Dover Lanat~ll. Various reference sources were used in the
initial Field Elements Study to identify potential wetland
resource areas. These sources included:
. Soil Survey of Strafford County, New Hampshire, March
1973
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ROD DSCISIOH SUHKARY
DOVER MUNICIPAL LANDPILL SITS
. Federal Emergency Management Agency (FEMA) Flood
Insurance Rate Map (FIRM) for the Town of Dover, New
Hampshire, strafford County, Community Panel No. 330145
0005B, Effective Date: April 15, 1980
. National Wetland Inventory, Dover West, New Hampshire,
April, 1977
. New Hampshire Department of Transportation (NHDOT)
Wetlands Map
Further on-site review and verification of the related
information indicated that there are four wetland systems in the
vicinity of the Dover Landfill. Three of these wetland systems.
are described as the Bellamy Reservoir, Cocheco River, and the
Hopper~ System north of the site. The fourth wetland area
includes the man-made drainage ditch which extends around the
perimeter of the Landfill which is hydraulically connected with
the Bellamy Reservoir wetland system. Delineation of the wetland
areas are shown on Fiqure 3. The drainage ditch is not
cross-hatched as are the other three areas on Fiqure 3.
These wetland systems were reviewed for evidence of physical
effects on vegetation that could be attributed to the Dover
Landfill. The review was limited in scope due to seasonal
constraints in that no herbaceous vegetation could yet be seen.
However, the woody vegetation exhibited no observable signs of
stress-related conditions. With the exception of the drainage
ditch and swale to the Cocheco River, the standing pockets of
water throughout the systems were relatively clear and exhibited
no signs of foaming or discoloration. Thus, there was no visible
evidence that these wetland systems have been impacted by the
Dover. Landfill. The drainage ditch waters were observed to have
foam on the water. In addition, although the temperature was
such that area water bodies had ice cover, the drainage channels
close to the landfill were not frozen. These factors suggest
that leachate from the landfill is affecting the water quality
~nd temperature of these surface waters.
w.
Groundwatar
Groundwater contamination (VOCs, metals, and BNAs) was found at
several locations around the Dover Landfill. All three of these
contaminant types were encountered in the upper aquifer just
downgradient of or near the Landfill. The lower aquifer was not
found to contain consistent or reproducible levels of
contaminants in current or RI data. contamination in well OW-1
was detected during the RI on several occasions possibly due to
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ROD DECISION SUMMARY
DOVER MUNICIPAL LANDFILL SITE
faulty well joints or construction, and therefore the well was
aba~d~~~~ i~ January 1988. Faulty joint connections were also
corrected on well B-2. Figures 4.through 8 show total VOC, BNA
and arsenic contaminant concentrations for groundwater for the
upper and 'lower aquifers. "ND" indicates that contaminant levels
were below the minimum detection level (MDL) of the instrument
performing the analysis.
~ - Figure 4 depicts the concentrations of VOC data for
groundwater samples collected from the upper aquifer at the Site,
and Figure 8 shows the estimated extent of known VOC
contamination related to the Landfill from the RI and FES in
areas directly influenced by the La~dfill. Generally, the
November 1989 sampling results suggest that the VOC plume is
attributable to hazardous substances in the Landfill and is
moving in an east, southeastward direction. Figure 8 presents
the estimated limit of contamination in the groundwater. The
upper aquifer exhibits semi-radial groundwater flow (see Figure
9) with contamination generated by the Landfill being detected at
monitoring well clusters B-2 to the east, toward the Cocheco
River; southeast of the Landfill at MW-103, 104, OW-S and B-6;
and along the southern edge of the Landfill at clusters B-8 and
B-4. Analytical data collected to date do not indicate that
contaminants have migrated as far south as clusters MW-102 or
B-10. VOC contamination was found in upper aquifer wells
MW-101U, OW-1A, .MW-104S, MW-104U, MW-103S, MW-103U, B-2U, B-4U,
B-8U and Ow-s during the November, 1989 sampling episode. The
highest concentrations of total VOCs for the site were detected
at MW-101U (2,174 ppb), B-4U (760 ppb), OW-S (744 ppb) and OW-1A
(733 ppb). These analytical results indicate that the
predominant mass of contaminants is migrating to the
east/southeast toward the Cocheco River. Contaminants from the
northwestern area of the Landfill appear to be flowing toward the
Bellamy Reservoir. The estimated location and apparent
historical trends for this data are provided on Figure 8. VOCs
were found in some private residential wells near the Landfill in
.1981. Residents near the Landfill were then connected to the
City's water supply. At this time, only two residential wells
(RW-J and RW-21) are still being used for drinking water
purposes. Of these two wells, RW-3 is in the lower aquifer, and
the depth of RW-21 is unknown. .
Residential Wells - Residential wells located in the
vicinity of the Dover Landfill were sampled and analyzed for VOCs
during numerous sampling episodes of the RI. Results of these
analyses are shown. on Figure 9. . Contaminants were detected in
wells RW-8 and RW-9 during the March 1981 sampling episode at 78
ppb and 10 ppb total VOCs respectively; and in wells RW-8, RW-17,
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OD DECISION SUKKARY
OOVER KURXCIPAL LAHDPILL SITB
RW-18 and RW-21 at 10, 10, 95,
respectively, in the May, 1985
levels of VOC were observed in
after 1985.
and 62 ppb total VOCs
sampling episode. No detectable
the residential wells sampled
Metals - Arsenic is the only metal with concentrations that
exceed state and Federal drinking water standards of 0.05 parts
per million (ppm)" Concentrations of unfiltered arsenic from the
November, 1989 FES sampling event varied widely across the site
from 0'.021 to 1.3 ppm in areas adjacent to the Landfill
exhibiting VOC contamination and 0.003 to 0.09 ppm in areas where
VOC contamination was not detected.
Arsenic occurs naturally in the soil matrix at the site and has
been observed in other areas of southern New Hampshire. Other
studies of New Hampshire groundwater indicate that, where .
elevated arsenic levels in water supplies are found it may be the
result of natural geologic conditions. Arsenic has been found
where no VOC contamination has been detected (including
upgradient samples) as well as in samples associated with the VOC
plume within the upper aquifer emanating from the Landfill.
Figure 6 depicts the concentrations of arsenic found in the
groundwater samples from the upper aquifer. 'Arsenic is also
found at measurable concentrations in groundwater samples from
the lower aquifer at wells B-6L and OW-3A, where VOC
contamination had been detected during the RI but below minimum
detection levels during the FES.
Filtered and unfiltered groundwater samples were obtained at
various wells in the upper aquifer around the Landfill. Results
indicate that arsenic is present in both, suggesting that
particulate and dissolved forms of arsenic are present in
groundwater in the upper aquifer. The particulate arsenic is
that component adsorbed to soils or bound within the soil matrix.
The presence of arsenic in the unfiltered groundwater samples and
in background groundwater and sediment samples, including
upgradient locations, suggests that arsenic is a naturally
occurring element of the area's geologic formations.
The higher arsenic concentrations found in close proximity to and
downgradient of the landfill relative to concentrations found
elsewhere in the study area suggests that they are a result of
landfilling activities. The waste materials disposed of' at the
landfill may be the source of the arsenic, or the leachate from
the landfill may'produce changes in groundwater geochemistry such
that native arsenic is being mobilized.
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ROD DECISION SUKKARY
DOVER MUNICIPAL LANDPILL SITB
~ - BNA contaminants were found in groundwater samples
from the upp~r aquifer in November, 1989 (wells B-13U, OW-5 and
MW-104S). Monitoring well B-13 showed low levels of
contamination during the RI, but subsequent sampling did not
indicate any sources. The area around B-13 is adjacent to a dirt
road and is heavily traveled by recreational vehicles. It is
possible that this BNA sampling reflected random spills as
opposed to the effects of a leachate seep from the Landfill.
Therefore, only the shallow wells MW-104S, OW-5, B-6U and B-2U
located in a narrow band directly adjacent to the eastern edge of
the Landfill are suspected to have BNA contamination derived from
the Landfill.
PCBs/Pesticides - Groundwater from the Landfill was not
found to contain-any PCBs or pesticides from any of the
analytical laboratory sampling results from either the upper or
lower aquifers.
A complete discussion of site characteristics can also be found
in the Remedial Investigation Report on Pages 7-1 through 7-15
and in the Field Element study on Pages 5-1 through 5-15..
G. GROQNDWATBR CONTAMINANT TRANSPORT
The Cocheco River ,and the Bellamy Reservoir are considered
potential receptors of contaminants migrating from the Landfill.
Residentia1 wells have already been impacted by the migration of
contaminants in the upper aquifer. The Calderwood well is also
considered a_potential, though less likely, receptor of the
contamination form the Landfill.
Contaminants at the Site may enter the groundwater flow regime
via percolation of liquid-wastes disposed on the ground surface,
infiltration of precipitation through contaminated solids, and
direct subsurface discharges from leaking drums.
During the RI, VOC, BNA, and metals contamination in groundwater
was observed.to be most prevalent in the upper aquifer at
monitoring well locations within 400 feet or less from the
Landfill. contamination detected in the lower aquifer monitoring
wells is not indicative of transport of contamination from the
Landfill through the marine clay layer to the lower aquifer. As
was stated earlier, the results of contamination in the lower
aquifer in well OW-1 may reflect leakage-of contaminated
groundwater from the upper aquifer through the PVC well pipe
joi~ts. This well has since been decommissioned.
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ROD DBCISIOB SUKKARY
DOVER MDBICIPAL LAHDPILL SITB
The RI groundwater transport model provides an estimate of
contaminant migration from the Landfill source area easterly and
southeasterly toward the.Cocheco River and private residential
wells located along Tolend Road, and southerly toward the Bellamy
Reservoir. The concentration isopleths depicting the contaminant
plume predicted by each model simulation over time are found in
the RI as Figures 25 through 30. Modeling results suggest that
contaminated groundwater will reach the east bank of the Bellamy
Reservoir, south of the Landfill, betwe~n approximately .1990 and
2005. Advective transport times are estimated to be on the order
of 100 to several hundred years for the transport of contaminants
from the upper aquifer through the marine clay layer. .
Contaminant transport times to the Calderwood well predicted by
the model are on the order of 40 to 80 years after contaminant
breakthrough to the lower aquifer.
HMM Associates., the contractor performing the FES for the PRP
Steering Committee, also developed and utilized a groundwater
contaminant transport model. Data during the FES indicated that
the primary direction of groundwater flow was east/southeast
towards the Cocheco River and that a small flow was south towards
the Bellamy Reservoir. Field data during the FES also indicated
that groundwater transport velocities may be slower than the RI
had predicted. Additional sampling rounds indicate that the
contamination has not migrated beyond the non-detect plume
estimated by the RI.
The results from the FES groundwater model predicted that through
natural attenuation it would take 5 to 7 years for the
contamination in the eastern plume to attain groundwater cleanup
levels and 10 to 24 years to attain cleanup levels in the
southern plume once source control measures were implemented
(including capping and leachate/ groundwater collection). Since
monitoring well B-8u was installed with an 80 feet screened
interval, it is currently unknown whether the contamination is
primarily in the upper, unconsolidated layer, hence the 10. year
attenuation time frame, or in the lower interbedded layer, which
yields a t~me frame for attenuation of 24 years. The FES
groundwater model also predicted that it is not likely. that
groundwater contamination will reach the Bellamy Reservoir, but
if it did, it would do so below the Safe Drinking Water Act MCLs.
VI.
SUKKARY OP SITB 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:
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ROD DBC1810H 8UMHARY
DOVER MUNYC1PAL LAHDP1LL 81TB
1) contaminant identification, which identified those hazardous
subst......._- ..:.':...:~, 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 Dover
Municipal Landfill Site are discussed below followed by the
conclusions o.f the-environmental risk assessment.
Sixteen contaminants of concern, listed in Table 2 found in
Appendix B of this Record of Decision were selected for
evaluation in the risk assessment. These contaminants constitute
a representative subset of the more than 41 contaminants
identified at the Site during the Remedial Investigation and
Field Element study. The sixteen 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 Chapter 4
of the Field Elements Study and Supplemental Risk Assessment
(FES).
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of the following four hypothetical exposure pathways:
- Future potential use of groundwater as drinking water
- Future potential use of Bellamy Reservoir as drinking
water
- Incidental ingestion and dermal contact with surface
water (Cocheco River and perimeter swale) while swimming
or wading
- Ingestion and dermal contact with soil/sediment while
swimming or wading
These ~~t~w~ys 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 Chapter 4 of the FES. For
each pathway evaluated, an average and a reasonable maximum
exposure estimate was generated corresponding to exposure to the
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ROD DBCISION SUHXARY
DOVER MURICIPAL LANDPILL SITB
average and the maximum concentration detected and estimated
exposure in that particular medium.
Groundwater
Groundwater is currently not
use scenario was evaluated.
70-year lifetime was assumed
exposure estimates.
Surface Water - Bellamv Reservoir
being used; therefore, only a future
Ingestion of 2 liters per day over a
for both average and maximum
This water body, currently used as drinking water supply for
seven municipalities, has not yet been contaminated by the Site.
Potential future use of the Bellamy Reservoir as a drinking water
supply was evaluated. Estimated future contamination
concentrations were obtained by predicting, via modeling, the
flow of contaminated groundwater. The predicted concentrations
were considered to be a reasonable maximum exposure scenario.
Ingestion of 2 liters per day over a 70-year lifetime was
assumed.
Surface Water - Cocheco River and Landfill Perimeter Swale
Ingestion and dermal contact with surface water while swimming or
wadinq in the Cocheco River and dermal contact while wading in
the perimeter swale were evaluated as potential current and
future exposure scenarios. The current and future use exposure
scenarios were considered to be equivalent. The average exposure
estimate for the Cocheco River exposure point was based on the
assumption that children aged 6 to 16 swim or wade 12 times per
year; the maximum exposure estimate was based on a frequency of
24 times per year. The average and maximum exposure estimate for
the perimeter swale exposure point was based on the assumption
that the children may wade 12 times per year.
Soil/Sediment EXDosure
Ingestion and dermal contact with sediment while wading in the
perimeter swale were evaluated as potential current and future
use exposure scenarios. The average exposure estimate for both
current and future use was based on the assumption that children
aged 6 to 16 would wade 30 times per year; the maximum exposure
estimate was based on a frequency of 90 times per year.
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
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ROD DECISION SUMMARY
DOVER MUNICIPAL LANDPILL SITB
developed by EPA from epidemiological or animal studies to
ref1~~t ~ ~nnservative "upper bound" of the risk posed by
potentially carcinogenic compounds. That is, the true risk is
very unlikely to be greater than the risk predicted. The
resulting risk estimates are expressed in scientific notation as
a probability (e.g. 1 x 10-6 for 1/1,000,000) and indicate, that
an individual is not likely to have greater than a one in one
million chance of developing cancer over 70 years as a result of
site-related exposure to the compound at the stated
concentration. CUrrent EPA practice considers carcinogenic risks
to be additive when assessing exposure to a mixture of hazardous
substances.
The hazard index was also calculated for each pathway as EPA's
measure of the potential for non-carcinogenic health effects. .
The hazard index is calculated by dividing the exposure level by
the reference dose (RfD) or other suitable benchmark for non-
carcinogenic health effects. Reference doses have been developed
by EPA to protect sensitive individuals over the course of a. .
lifetime and they reflect a daily exposure level that is likely
to be without an appreciable risk of an adverse health effect.
RfDs are derived from epidemiological or animal studies and
incorporate uncertainty factors to help ensure that adverse
health effects will not occur. The hazard index is often
expressed as a 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 produce liver damage should not be
. added to a second whose toxic endpoint is kidney damage).
SummarY of Baseline Risk Assessment
Tables 3 through 8 of Appendix B of this ROD depict the
carcinogenic and non-carcinogenic risk summary for the
contaminants of concern in each exposure pathway described above.
Groundwater
The average and reasonable maximum exposure case carcinogenic
risks associated with the potential future consumption of
groundwater were approximately 2x10.2 (2 cancer cases in 100) and
7X10.2, respectively. Arsenic comprised over 90t of the risk for
both the average and reasonable maximum worst case scenarios.
Vinyl chloride comprised approximately 5% of the risk for both
scenarios. Othe~ chemicals which contributed a risk of greater
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ROD DECISIOM SUKMARY
DOVER MUM%CIPAL LAHDPILL SITE
than one in a million were benzene: chloroethane: 1,1
dichloroethylene: 1,2 dichloroethane: methylene chloride:
tetrachloroethylene and trichloroethylene.
For non-carcinogenic effects, the average and reasonable maximum
exposure case Hazard Indices exceeded one for the toxic endpoints
of keratosis (skin discoloration) and liver effects. Arsenic and
tetrahydrofuran were the major contaminants for these toxic
endpoints, respectively.
The groundwater contaminant concentrations measured during the
FES were used in the Baseline Risk Assessment except for two
compounds. Data from the RI was used for tetrahydrofuran which
was not analyzed for in the FES and 1,2 dichloroethane which was
not detected in the FES.
Surface Water - Bellamy Reservoir
The reasonable maximum exposure case carcinogenic risk associated
with the potential future consumption of groundwater was
approximately ax 10-6. OVer 95% of this risk was due to arsenic.
For noncarcinogenic effects, the Hazard Index was well below one.
8ur~ace Water - Cocheco River and Landfill Perimeter Swale
The reasonable maximum exposure case carcinogenic risks
associated with exposure to both the Cocheco River and landfill
perimeter swale were well below EPA'srisk range of 10-6 to 10-'.
For noncarcinogenic effects, the Hazard Index was well below one.
Soil/Sediment Exposure
The average and reasonable maximum exposure case carcinogenic
risks due to arsenic ~ssociated with exposure to the landfill
perimeter swale sediments via the ingestion pathway were
approximately lxlO-6 and aX10-s, respectively. .
For noncarcinogenic effects the Hazard Indices for the average
and reasonable maximum exposure scenario were below one.
Summary
In summary, predicted average and maximum carcinogenic health
risks of 2xlO-2 and 7xlO-2 for the future use of groundwater
exceeded EPA's acceptable risk range of lX10-4 to lX10-6. Arsenic
and vinyl chloride were the major contributors to these risks.
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ROD DBCISION SUKKARY
DOVER KURICIPAL LAHDPILL SITB
A Hazard Index greater than one was predicted for future use of
groundwater. Arsenic and tetrahydrofuran were the major
contributors to the noncarcinogenic risks with maximum Hazard
Indices of 37 and 24, respectively.
Maximum contaminant levels in groundwater exceeded the applicable
regulatory standards set or proposed under the Safe Drinking
Water Act - Maximum Contaminant Levels (MCLa) and Maximum
Contaminant Level Goals (MCLGs) for the following co~pounds:
arsenic: benzene; 1,1 dichloroethylene; 1,2 dichloroethane;
tetrachloroethylene; trichloroethylene and vinyl chloride.
The maximum predicted carcinogenic risk for sediment ofax10"s is .
within EPA's acceptable risk range (10-4 to 10"6). .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, and the environment. Specifically
an imminent and substantial threat to public health could result
from the contaminated soils, sediments, sludges and debris in the
Landfill and from drinking groundwater in proximity to the
Landfill.
VII.
. DBVELOPMENT AND SCRBBNING OP ALTBRNATIVES
A. statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at Superfund
sites is to undertake remedial actions that are prote~tive 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 statutory
mandates.
Based on preliminary information relating to types of contaminants,
environmental media of concern, and potential exposure pathways,
remedial action objectives were developed to aid in the development
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ROD DBCISIOB SUKKARY
DOVER MURXCIPAL LAHDPILL SITB
and screeninq of alternatives. These remedial action objectives were
developed to mitiqate existinq and future potential threats to public
health and the environment. These objectives were:
.
Prevent the miqration of hazardous substances in the
landfill to qroundwater and surface water and the
miqration of the qroundwater contamination beyond its
current extent;
.
Reduce risks to human health by preventinq exposure
to contaminants in qroundwater, soils, surface
waters, and sediments; and
Restore contaminated qroundwater at and beyond the
compliance boundary to state and Federal applicable
or relevant and appropriate requirements (ARARs)
including drinking water standards, and to a level
that is protective of human health and the
environment.
.
B. T8chDoloqy and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial actions are
evaluated and selected. In accordance with these requirements, a
range of alternatives were developed for the site.
~ith re$pect to source control, the FS developed a range of
alternatives in which treatment. that reduces the toxicity, mobility,
or volume of the hazardous substances is a principal element. This
range included an alternative that removes or destroys hazardous
substances to the maximum extent feasible, eliminating or minimizing
to the deqree possible the need for lonq term management. This range
also included alternatives that treat the principal threats posed by
the site but vary in the degree of treatment employed and the
qUantities and characteristics of the treatment residuals and
untreated waste that must be managed; alternative(s) that involve
little pr no treatment but provide protection through engineering or
institutional controls; and a no action alternative.
With respect to qround water response action, the FS developed a
limited number of remedial alternatives that attain site specific
remediation levels within different time frames using different
technoloqies as well as a no action alternative.
A Treatability study was conducted by HMM to provide data to evaluate
treatment options for the Site, and to reduce cost and performance
uncertainties for various treatment options. The study consisted of
an additional samplinq episode for sediment, surface water and
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ROD DBCI8IOlf 8tJJIKARy
DOVER MUNICIPAL LANDPILL SITB
groundwater. The objective of the sampling round was to determine
concentra i.~,"",-= ....... Q fu..i.:mber of indicator parameters. The parameters
analyzed represent an engineering assessment of specific chemical
constituents that could affect the implementability or effectiveness
of a groun~w~tAr rem~dial technology. Groundwater VOC data was used
to determine the high and low ends of VOC loading for a treatment
process. Groundwater was sampled to generate filtered arsenic data to
help determine the amount of dissolved arsenic in the groundwater.
Table 1-3 of the FS lists each parameter or set of analytes sampled as
part of the Treatability study and describes the associated criteria
and treatment technologies.
Section 2 of the FS identified, assessed' and screened technologies
based on implementability, effectiveness, and cost. These
technologies were combined into source control (SC) and management of
migration (MM) alternatives. Section 3 of the FS presented the '
remedial alternatives developed by combining the technologies
identified in the previous screening process in the categories
identified in Section 300.430(e) (3) of the NCP. The purpose of the
initial screening was to narrow the number of potential remedial
actions for further detailed analysis while preserving a range of
options. A limited number of alternatives were then evaluated in
Section 4 of the FS. ,
In summary, of the approximately 9 source control and 4 management of
migration remedial alternatives evaluated and screened in Section 3, 4
source control and 4 management of migration alternatives were
retained for detailed analysis in Section 4. Tables 3-1 and 3-2 of
Section 3 of the FS identify the 4 source control alternatives and 4
management of migration alternatives that were retained through the
screening process, as well as those that were not chosen for detailed
analysis. .
VIII.
DBSCRIP'1'IOlf 01' ALTERNATIVES
This, Section provides a narrative summary of each alternative subject
to detailed evaluation. A tabular assessment of each alternative can
be found in Tables 3-4 and 3-5 of the Feasibility study.
A.
Source COD~rol (8C) Al~erDa~ive. Analyzed
Source co~~~~l ~'~ernatives (on-site), were developed for the
contaminated soils, sludges, debris and sediments associated with the
Landfill as well as the contaminated groundwater located under the
Landfill and the contaminated surface water in the perimeter drainage
ditch.
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~D DECISIOB SUMMARY
~VBR KURXCIPAL LANDFILL SITE
The source control alternatives analyzed for the site include the
following alternatives:
SC-l:
No-Action with Long-Term Monitoring:
Limited Action with Long-Term Monitoring/ Access
Restriction/ Institutional Controls:
SC-2:
SC-S/SA:
Recontouring of Landfill/ MUlti-layer Cap/ Slurry
Wall/ Groundwater Recovery System/ Groundwater
Treatment/ Discharge to Cocheco River (SC-S) or POTW
(SC-SA)/ Geotextile Cover in Drainage Swale/ Erosion
Control Blanket: and
SC-7/7A:
Recontouring of Landfill/ MUlti-layer Cap/
Interceptor Trench with Internal Landfill Extraction-
. Wells/ Groundwater Treatment/ Discharge to Cocheco
River (SC-7) or POTW (SC-7A)/ Selected Sediment
Excavation with Consolidation in Landfill.
SC-l:
No-Action
- This alternative is included in the Feasibility study, as required by
~ERCLA, to serve as a basis for comparison with the other source
~ntrol alternatives being considered.
This alternative would require no remedial action except for long-term
monitoring of groundwater, sediments, and surface water. No treatment
or containment of disposal areas would occur and no effort would be
made to restrict potential exposure to site contaminants. It is
possible that a reduction of toxicity of contaminants may occur over
ti~e due to natural attenuation, but this may take many' decades.
A Site inspection including groundwater and sediment monitoring would
be performed four times a year, for 30 years. Samples collected would
be analyzed for VOCs, BNAs, and metals. Monitoring data would be
evaluated every five years.
This alternative does not meet many ARARs, which include the Safe
Drinking Water Act groundwater MCLs, and State and Federal
requirements that hazardous waste landfills be capped. In addition,
the landfill has a potential for future non-compliance with ARARs such
as State and Federal laws protecting the wetlands surrounding the Site
and those laws protecting the Class A surface waters of the Bellamy
Reservoir.
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ROD DBCISION SUMMARY
DOVER MUNICIPAL LANDPILL SITB
Estimated Time for Design and Construction: None
Estimated Time for Operation: 30 years, groundwater monitoring
Estimated Capital Cost: None
Estimated Operation and Maintenance Cost (net present worth):
Estimated Total Cost (net present worth for 30 years at 10%
interest):$1,593,400
$169,000
SC-2:
Limited Action
This alternative is similar to SC-1, except that this alternative
allows for limited measures to control access to and use of the Site.
Warning signs and a fence with barbed wire would be installed to limit
any further access to the Site. Institutional controls, such as deed
restrictions, and municipal by-laws, where possible, would be
implemented to prohibit disturbance of the contaminated source areas
and use of the contaminated groundwater.
An inspection and long-term monitoring program similar to alternative
SC-1 would be. instituted. Also air monitoring would be performed at
the Site annually at three locations along the southern, eastern, and
northern perimeters of the landfill. Surface water monitorinq would
be performed at several locations along the perimeter drainage ditch.
While this alternative offers limited protection of human health fz'om
the hazards posed by the site, this alternative, like SC-1, provides
little or no protection to the environment. In addition, many of the
ARARs, such as the SDWA, RCRA, and State hazardous waste regulations,
are not met by this alternative. CUrrently, groundwater contains
contaminants which significantly exceed MCLs and the threat to the
wetlands and the Bellamy Reservoir remain unchecked.
Estimated Time for Design and Construction: 1 month
Estimated Period for Operation: 30 years, air and groundwater
monitoring
Estimated Capital Cost: $44,400
Estimated Operation and Maintenance cost (net present worth):. $177,600
Estimated Total Cost (net present worth, for 30 years at @ 10%
interest): $1,718,300
:~~~~:~:::~v.:::o;;::~~::t~~i~:::;~~1~:U~:~;;:~e:i~::1:~u~r;.:
Alternative SC-5/SC-SA would involve recontouring of the landfill,
construction of a multi-layer cap and a slurry wall to contain
groundwater migration, on-site groundwater treatment (SC-S) or
pretreatment eSC-SA), and final discharge to the Cocheco River eSC-S)
or the Publicly OWned Treatment Works ePOTW) eSC-SA).
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~OD DBCISION SUMMARY
)VBR MUNICIPAL LUmPILL SITB
Approximately 300,000 cubic yards of soils and debris from the toe of
the side slopes and from the sediments in the drainage ditch would be
consolidated into the Landfill to contour features of the Landfill
prior to capping. Recontouring of the Landfill may reduce the amount
of clean soil, necessary to achieve a maximum allowed slope of 5
percent, from 1,200,000 cubic yards to 850,000 cubic yards.
After t~e Landfill has been recontoured, backfilled and compacted, a
mUlti-layer cap system will be constructed. The multi-layer cap would
consist of a vegetative layer including topsoil and common fill,
filter fabric, a drainage layer, a flexible membrane liner and a low
permeability soil layer, and a gas (methane) vent layer directly over
the buried solid wastes. Figure 10 is a cross-section of a typical
multi-layer cap. Alternative SC-5/5A proposed the installation of a
12-inch sand layer as the material to be used for the drainage layer
of the' multi-layer cap, 2-feet of a compacted soil (with a hydraulic
permeability of less than or equal to 10.7 em/sec) in the low
permeability layer and a 20 mil flexible membrane liner.
A slurry wall and a groundwater recovery system would be constructed
around the perimeter of the landfill down to the clay layer.
Construction of the slurry wall may be difficult because the bottom of
the slurry wall must be keyed into the marine clay layer, which varies
~Jidely in depth and thickness. This method also risks'puncturinq the
~otectiv.e clay "lens" which may allow contaminated groundwater from
~ne upper aquifer to migrate into the uncontaminated lower aquifer.
Installation of the cap, slurry wall and groundwater recovery system
eliminates the use of the perimeter drainaqe ditch as an avenue for
contaminant migration, thereby limiting exposures to contaminated
surface water and sediments.
The groundwater treatment system would consist of a sequencing. batch
reactor such as the powdered Activated Carbon Treatment system
(PACTTM) or an air stripper, pendinq pre-desiqn pilot study results.
The FS chose the PACTTM system to describe and provide a cost analysis
for the FS. .In the PACTTM system the contaminated qroundwater 'would
first enter an aeration tank to remove VOCs: activated carbon present
in the tank would remove non-volatile orqanic chemicals from the
water. The water would then pass throuqh a settlinq tank where
flocculation, coaqulation and precipitation processes take place to
remove metals and suspended solids. The metals and solids settle at
the bottom of the tank in the form of a sludqe. If it is a RCRA
waste, sludge will be disposed of at a permitted RCRA facility. The
'water would then pass through a multi-media filter and ultimately be
discharged into the Cocheco River. A schematic of the proposed
groundwater treatment system is shown in Fiqure 11 of this Record of
Decision.
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ROD DSCISIOB SUKHARY
DOVER MUNICIPAL LANDPILL SITS
. If discharge to the POTW is utilized, tile construction of a
pretreatment system may be required to.~t the intake requirements of
the Dover POTW. The pretreatment process ~d Łocus primarily on
reducing suspended metals and solids. An approximately 2.5 mile
piping system would be constructed to trAnsport the pretreated
groundwater to the POTW. The Dover POTW currently has the extra
capacity to handle pre-treated water from the Landfill, and the
capacity is expected to increase further by 1992 with the start-up of
a secondary treatment unit, currently under constru'ction.
This Alternative would also involve the installation of cover material
over the drainage swale which drains from Glen Hill Road adjacent to
the landfill down into the Cocheco River in order to minimize human
and wildlife exposure to the contaminated sediments and minimize the
potential migration of contaminated sediments in the surface water
flow of the swale.
This alternative meets all ARARs.
SC-5 Cost
Estimated
Estimated
Estimated
Estimated
. $221,400
Estimated Total Cost (net present
$33,353,600
SC-5A Cost Estimate (discharge to POTW option):
Estimated Time for Design and Construction: 3-4 ~ears
Estimated Period for Operation:JO years
.Estimated Capital Cost: $3~,334,600
Estimated Operation and Maintenance Cost (net present worth): $206,000
Estimated Total Cost (net present worth for 30 years at 10% interest):
$33,267,100
Estimate (discharge to Cocheco River option):
Time for Design and Construction: 3-4 years
Period for Operation:30 years
Capital Cost: $31,266,600
Operation and Maintenance Cost Jnet present worth):
worth for 30 years at 10% interest):
SC-7/7A: Recont9urinq of Landfilll Multi-Laver CaDI InterceDtor
Tr.nc~arq8 to COCh8CO Rtv8r or POTW:
Alternative SC-7/SC-7A would involve recontouring of the landfill,
construction of a multi-layer cap and an interceptor/diversion trench
around the perimeter of the ~andfill to containand~collect
contaminated groundwater~ .divert c1ean groundwater, an on-site
groundwater treatment (SC-7) or pretreatment (SC-7A), and final
discharge to the Cocheco River (SC-7) or the Publicly Owned Treatment
Works (POTW) (SC-7A).
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'ROD DECISION SUMXARY
DOVER MUNICIPAL LAHDPILL SITB
This alternative would involve recontouring the existing landfill and,
construction of a multi-layer cap over the recontoured landfill.
. Recontouring would involve the excavation of up to 300,000 cubic yards
of on-site fill material from the perimeter of the landfill and
depositing it on the landfill center to achieve the necessary slope
for proper drainage. Approximately 250,000 cubic yards of clean fill
would also be required for the minimum 3 percent slope allowed.
The 55-acre multi-layer cap would be constructed after the existing
landfill had been recontoured, backfilled, and compacted. The cap
would consist of a vegetative layer including topsoil and common fill,
a geocomposite drainage layer, a flexible membrane liner, 'a synthetic
low permeability layer, and a gas (methane) vent layer directly over
the buried solid wastes. Figure 10 is a cross-section of a typical
mUlti-layer cap. Alternative SC-7/7A proposed the use of a
geocomposite as the drainage layer material, a 40 mil flexible
membrane liner and a low-permeability bentonitic blanket for the low
permeabilit~ layer '(with a hydraulic permeability of less than or
equal to 10. em/see). '
A groundwater recovery system would consist of an upgradient
groundwater diversion trench to intercept clean groundwater before it
flows into the landfill system and a downgradient interceptor
trench/extraction well system, or combination system, to collect
~roundwater/leachate, which currently migrates from the site. The
ntercepto~/diversion trench system would extend around the entire
existing landfill perimeter. Inside the trench, a one foot diameter
perforated pipe, wrapped in filter fabric, and a drainage net would be
connected to a series of manholes. Submersible pumps housed in the
manholes would extract collected groundwater. This system would be
designed. to lower the groundwater table beneath the landfill's refuse.
Extraction wells will be placed within the landfill boundaries to
lower groundwater below the waste material. Collected contaminated
groundwater would be conveyed to an on-site groundwater treatment
system with discharge to the Cocheco River or the Dover POTW after
pre-treatment. .Clean groundwater in the upgradient diversion trench
would be diverted to either the surrounding wetland system or the
Cocheco River without being mixed with contaminated water. The
installation of the cap and the interceptor/diversion trench system
eliminates the perimeter drainage ditch as, an avenue for contaminant
migration and limits potential human and wildlife exposure to site
contaminants.
The actual on-site treatment system(s) that will be used at the site
will be determined during pre-design studies and will include a
sequencing batch reactor such as the Powered Activated Carbon
Treatment System or an air stripper. The FS described the Powered
Activated Carbon Treatment System (PACTTM), summarized above in
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ROD DBCISION SUKKARY
DOVER MUNICIPAL LANDFILL SITB
Alternative-SC-S/SA.
If the POTW option is utilized, the construction of a pretreatment
system which would meet the intake requirements of the Dover POTW, may
be required. The ~retreatment process would focus primarily on
reducing suspended metals and solids. As was described in SC-S/SA,
the Dover POTW currently has the extra capacity to handle some pre-
treated water from the landfill.
- The sediment control component provides for predesign sampling to
identify specific areas of sediment deposition along the drainage
swale that could contain concentrations of contaminants in excess of
the cleanup levels. Based on the physical characteristics of the
drainage swale, the ext~nt of contamination is expected to be limited.
Contaminated sediments will be removed with little or no heavy
equipment: sediments will likely be removed by hand shovel. This
method was evaluated because of-the difficulties associated with
getting heavy equipment into and out of tbe steep-sloped swale. This
approach, will reduce the overall impact to the environment during
implementation as compared to using heavy equipment. .
This alternative meets all ARARs.
SC-7 Cost
Estimated
Estimated
Estimated
Estimated
$239,300
Estimated Total Cost (net
interest):$22,273,600
SC-7A Cost Estimate (POTW option):
Estimated Time for Design and Construction: 3-4 years
Estimated Period for Operation: 30 years
Estimated Capital Cost:$20,174,700
Estimated Operation and Maintenance Cost (net present worth):
$211,900 ..
Estimated Total Cost (net present worth for 30 years at 10' interest):
$22,171,900
Estimate (discharge to Cocheco River option):
Time for Design and Construction: 3-4 years
Peri,Od for Operation: 30 years
Capital Cost:$20,014,700
Operation and Maintenance Cost (net present worth):
present worth for 30 years at 10'
B.
MaDaqemeDt of KiqratioD (MM) Alternative. ADaly.ed
Management of migration alternatives address contaminants that have
migrated beyond the boundaries of,the Landfill. At the Dover Site,
contaminants have migrated from the Landfill into groundwater
east towards the Cocheco River, and also south towards the Bellamy
Reservoir. The primary groundwater threat to human health and the
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ROD DBCISIOH SUMMARY
DOVER MUNICIPAL LANDPILL SITB
environment is in that portion of the groundwater contaminant plume
flowing south towards the Bellamy Reservoir.
The Management of Migration alternatives evaluated for the site
include the following alternatives:
MM-l:
No Action with Long-Term Monitoring;
Limited Action with Long-Term Monitoring/
Institutional Controls;
MM-2:
MM-3:
Groundwater Interceptor Trench/ Groundwater
Treatment/ Hydraulic Barrier/ Discharge to Wetlands;
and
MM-4:
Groundwater Extraction Wells/ Groundwater Treatment/
. Discharge to Wetlands and Cocheco River.
MM-l No-Action
This alternative was evaluated in detail in the FS to serve as a
baseline for comparison with the other remedial alternatives under
. consideration. Under the No Action alternative, there would be no
removal, containment, or treatment of off-site contaminated
;roundwater. However, this alternative would require long-term
groundwater monitoring, as is described under Alternative SC-l.
This alternative combined with alternatives SC-5/5A or SC-7/7A, would
achieve over time the chemical specific ARARs, through natural
attenuation. Natural attenuation times frames for the groundwater to
attain cleanup levels are 5 to 7 years in the eastern plume
(groundwater contamination flowing in the direction of the Cocheco
River) and 10 to 24 years in the southern plume (groundwater
contamination flowing in the direction of the Bellamy Reservoir),
after the implementation of an active source control alternative.
However, du~ing this period of natural attenuation, contaminated
groundwater east and south of the site poses a threat to human health
and the environment. In addition, contaminants may reach the waters
of the Bellamy Reservoir.
Estimated Time for Design and Construction: None
Estimated Period of operation: 30 years
Estimated Capital Cost: None
Estimated operation and Maintenance Cost (net present worth): $142,800
. Estimated Total Cost (net present worth for 30 years at 10% interest):
$1,346,500
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ROD DBCISION SUHKARY
DOVER MUNICIPAL LANDPILL SITB
KM-2:
Limi~ed Ac~ion:
Management of Migration Alternative MM~2, Limited Action, provides
. long-term monitoring of the off-site contaminated groundwater for at
least 30 years. In addition, under this alternative institutional
controls will be employed where possible, limiting Site access, Site
use, and preventing the use of groundwater from the upper aquifer for
potable and municipal usage. These institutional controls will be
implemented regardless of which management of migration alternative
(except for no action, MM-1) is implemented. The City of Dover passed
a zoning ordinance in February 1991 that restricts the use of
groundwater within 1500 feet of the landfill as a potable water
supply. ..
A long-term groundwater sampling and monitoring program will be
developed and implemented. This may include the installation of
additional wells, including the area of the plume closest to the
Bellamy Reservoir. The monitoring will further define groundwater
contaminant concentrations and the extent of migration towards the
Bellamy Reservoir.
This alternative, coupled with SC-5/5A or SC-7/7A, would achieve over
time the chemical specific ARARs through natural attenuation. Natural
-attenuation times frames for the groundwater to attain cleanup levels
are 5 to 7 years in the eastern plume and 10 to 24 years in the
southern plume, after the implementation of an active source control
alternative. While this alternative provides more protection to
humans from contaminated groundwater during natural attenuation, it
does nothing to prevent contaminants from reaching the Bellamy
Reservoir.
Estimated Time for Design and Construction: 6 months
Estimated Period of Operation: 30 years
Estimated Capital Cost: None
Estimated Operation and Maintenance Cost (net present worth): $176,541
Estimated Total Cost (net present worth for 30 years at 10% interest):
$1,673,593
::-~: :roun4~.r InterceDtor Trench/Recharae Trench/Hvdraulic
Barrier:
Management of migration alternative MM-3, includes the construction of
a groundwater interceptor trench at the leading edge of the
groundwater contaminant plume on the southern and southeastern sides
of the landfill. Installation of this trench would passively collect
contaminated groundwater, which has migrated into the wetlands
adjacent to the Landfill, thereby limiting the further spread of the
plume. Contaminated groundwater collected by the trench would be
-------
~OD DECISION SUMMARY
')oVER MUNICIPAL LAHDPILL SITB
pumped to a treatment unit on or adjacent to the Landfill. The
treated groundwater would then be recharged downgradient of the
trench. .
.The interceptor trench would be located off-site south and southeast
of the Dover Landfill extending laterally approximately 2,200 linear
feet. An approximately 4-foot wide by 25-foot deep trench would be
excavated and dewatered prior to laying the pipe. The bedding inside
the trench would include gravel and .a perforated pipe wrapped with
filter fabric. After placement of the bedding material, the trench
would be backfilled to surface grade. The recharge trench would be
located downgradient of the interceptor trench and also extend about
2,200 linear feet. An approximately 2-foot wide by 4-foot deep
recharge trench would be excavated and HDPE corrugated, perforated
pipe would be installed. Gravel would be placed around the pipe to
promote drainage. Groundwater collected by the interceptor trench
would be pumped from a manhole via a submersible pump to an on-site
groundwater treatment facility. A portion of the treated groundwater
would be returned to the management of migration area via the recharge
trench. This would minimize localized dewatering of the wetlands
which would reduce the adverse impact of this activity. Treated
groundwater in excess of that which could be recharged would be
discharged to the river. Trench installation would adversely impact
'~etlands along the southern and southeastern portions of the Landfill.
;owever, once the trench and associated piping have been installed any
wetland areas impacted by excavation and installation procedures can
be restored. Actual design configuration of the interceptor-recharge
system would be dependent upon additional data and analysis obtained
during predesign activities.
Groundwater treatment technologies previously identified for the
source control alternatives apply as well to this alternative.
The cleanup time frames for this alternative
5 years for the eastern plume area and 10 to
plume, after the implementation of an active
alternative.
are estimated to be 3 to
24 years for the southern
source control
Implementation of this alternative in conjunction with a source
control alternative which involves treatment would allow all ARARs to
be met. Construction of the groundwater interceptor trench and a
groundwater recharge trench in the wetlands and the associated
treatment system would alter portions of the wetlands. All
construction activities associated with the implementation of this
alternative will be coordinated with federal and state authorities and
meet the substantive legal requirements of federal and state wetland
protection laws. Key ARARs include the SDWA MCLs; Executive Orders EO
11988 and 11990 and 40 CFR 6 Appendix A (concerning the protection of
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ROD DECISION SUMKARY
DOVER KUNICIPAL LANDPILL SITE
wetlands and floodplains): the Clean Water Act:. the New Hampshire
criteria and Conditions for Fill and Dredging in Wetlands: and the New
Hampshire Rules Relative to Prevention of Pollution from Dredging,
Filling, Mining, Transporting and Construction.
Figure 12 presents the conceptual layout for this alternative.
Estimated
Estimated
Estimated
$78,800
Estimated Total Cost (net present worth for 10
$1,936,600 .
The cost of long-term (semi-annual) monitoring is estimated as
follows:
Period for operation: 10 years
Capital Cost: $1,452,200
Operation and Maintenance Cost (net present worth):
years at 10% interest):
Estimated Period for Operation: 30 years
Estimated Capital Cost: $9,400
Estimated Operation and Maintenance Cost (net present worth):
Estimated Total Cost (net present worth for 30 years at 10%
interest): $892,100
Total cost, MM-3 and long-term monitoring: $ 2,828,700
$93,600
MM-4:
Groundwater Extraction Wells and Treatment System:
Alternative MM-4 is designed to collect and treat contaminated
groundwater which has migrated from the landfill in both the southern
and eastern directions. It differs from Alternative MM-3 only in that
the interceptor trench would be replaced by a series of recovery
wells. This alternative would consist of the following: the
installation of several groundwater extraction wells at off-site
locations on the southern and eastern sides of the site: the on-site
treatment of contaminated groundwater: the recharge of the treated
water to wetlands downgradient of. the wells and/or discharge of the
treated water. to the Cocheco River. Groundwater collected by the.
extraction wells would be pumped at a total of approximately 125 gpm
to a treatment unit on or adjacent to the Landfill.
Tne estimated time to achieve cleanup levels is contingent on the
aquifer characteristics, retardation, plume mass and areas of
extraction. Based on these factors, MM-4 would be located in
approxiaately the same place as MM-3, as shown in Figure 1~. The
cleanup time frames for this alternative are estimated to be 3 to 5
years for the eastern plume area and less than 10 to 24 years for the
southern plume, after the implementation of a source control
alternative.
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ROD DBCISIOll SUJlKARY
DOVBR MURXCIPAL LANDFILL SITB
Implementation of this alternative in conjunction with a source
control alternative which involves treatment would allow all ARARs to
be met. . Wetland mitigation measures and restoration efforts would be
required in order to comply with the Location Specific ARARs, as
discussed for Alternative MM-3. However, this alternative would have
less detrimental impact on the wetlands than MM-3. All ARAR~ will be
met. .
Estimated Period for operation: 10 years
Estimated Capital Cost: $1,503,700
Estimated operation and Maintenance Cost (net present worth): $394,200
Estimated Total Cost (net present worth for 10 years at'10% interest):
$3,925,900
The cost of long-term (semi-annual) monitoring is estimated as
follows:
Estimated Period for operation: 30 years
Estimated Capital Cost: $9,400
Estimated Operation and Maintenance Cost (net present worth): $93,600
Estimated Total Cost (net present worth for 30 years at 10% interest):
$892,100 .
rotal cost MM-4 and. long-term monitoring: $ 4,818,000
IX.
StJKMARY OF TO COMPARATIVE ANALYSIS OF ALTERNATIVES
section l2l(b)fl) of CERCLA presents several factors that EPA must
consider in its assessment of alternatives. Building upon these
specific statutory mandates, the National Contingency Plan articulates
nine evaluation criteria to be used in assessing the individual
remedial alternatives.
A detailed analysis was performed on the alternatives using the nine
evaluation criteria in order to select a site remedy. The following
is a summary of the comparison of each alternative's strength and
weakness with respect to the nine evaluation criteria. These criteria
and their definitions are as follows:
Thresho14 criteria
An alternative must meet the two threshold criteria described below in
order to be eligible for selection in accordance with the NCP.
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ROD DECISION SUKNARY
DOVER MUNICJPAL LANDPILL SIT!
1. OVerall protection of human health and the environment addresses
whether or not a remedy provides adequate protection and describes how
risks posed through each pathway are eliminated, reduced or controlled
through treatment, engineering controls, or institutional controls.
2.Complianc. wlLu AAARS 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 used to compare and evaluate the
elements of alternatives which have met the threshold criteria to each
other. .
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, mObility, or volume through treatmeD~
addresses the degree to which alternatives employ recycling or
treatment that reduces toxicity, mobility, or volume, including
treatment is used. to .address the principal threats posed by the
how
site.
S.Short term effectiveness addresses the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period, until cleanup levels are achieved.
6.Implementability addresses the technical and administrative
feasibility of a remedy, including the availability of materials and
services needed to implement a.particular option. .
7.Coat includes estimated capital and Operation & Maintenance . (O&M)
costs, as well as present-worth costs.
Modifvina Criteria
The modifyinq criteria are used on the final evaluation of remedial
alternatives generally after EPA has received public comment on the
RI/FS and Proposed Plan.
8.State acceptance addresses the State's position and key concerns
related to the preferred alternat~ve and other alternatives, and the
State's comments on ARARs or the proposed use of waivers.
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ROD DECISION SUXMARY
,DOVER MUNICIPAL LANDPILL SITB
9.community acceptance addresses the publics 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. This
comparative analysis can be found in Section 4, Tables 4-22 and 4-23
of the Feasibility Study.
The section below presents the nine criteria and a brief narrative
summary of the alternatives and the strengths and weaknesses according
to the detailed and comparative analysis~
1. OVerall Protection of Human Health and the Bnvironment
Alternatives SC-7/7A and SC-S/SA would provide overall protection to
human health by preventing direct contact, ingestion, and inhalation
of site contaminants. These alternatives would provide dermal contact
protection from "on-site contaminants due to the construction of the
multi-layer landfill cap. There were no hot spots found in the
landfill that would warrant treatment. Both alternatives minimize the
further off-site migration of leachate and contaminated groundwa~r
and provide for treatment of the collected contamination.
Alternatives Se-l'and Se-2, the No Action and Limited Action
Alternatives, would not meet this criterion in its entirety.
\lternative SC-2 provides for certain protective measures to secure
the site from unauthorized entry, and would reduce the potential for
direct contact with and possible ingestion of contaminated materials
at the site. Inhalation hazards from airborne dust particles or VOC
emissions could ,be a factor if the Landfill were to be disturbed at
some point in the future.
Alternatives MM-2, MM-3 and MM-4, would provide overall protection to
human health as long as the groundwater is not used as a drinking
water source. Off-site groundwater contamination is reduced through
natural attenuation as described under MM-l and MM-2 and by
groundwater extraction and treatment'as described under alternatives
MM-3 and MM-4. MM-3 and MM-4 would provide overall protection to
human health and the environment by controlling the migration of
contaminated groundwater thereby preventing further contamination of
the aquifer and neighboring wetlands. Alternative MM-4 would provide
a shorter cleanup time than MM-3, because of increased groundwater
extraction rates. Alternative MM-l (the no action alternative) would
provide no protection of human health from groundwater contamination.
Neither MM-l nor MM-2 protect the Class A waters of the Bellamy from
contamination during the period of natural attenuation.
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ROD DBCISION SUKHARY
DOVER KURYCIPAL LANDFILL SITB
,2. compliance with ARARa
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific and location specific ARARs. These
alternative specific ARARs are presented in Section 4 of theFS.
With the exception of the no action (SC-l) and the limited action (SC-
2) source control alternatives, all of the other source control
alternatives would meet all ARARs. SC-l and SC-2 does not comply with
RCRA regulations and the New Hampshire regulations for the design,
closure and post closure requirements of the Landfill and General
Facility standards. In addition, SC-l and SC-2 allow contaminants in
excess of MCLs to migrate from the site. Further degradation of the
current landfill cover and the leachate trench also poses a threat to
the wetlands, the Cocheco River and the Bellamy Reservoir in
contravention of Federal and State laws protecting wetlands, flood
plains, and Class A drinking water sources. Alternatives SC-7A and
SC-SA will have to meet POTW discharge requirements.
All of the management of migration alternatives would over time meet
Federal and State ARARs if implemented in conjunction with' a preferred
source control alternative. However, during the natural attenuation
period MM-l fails to protect human health from groundwater containing
contaminants in excess of MCLs south and east of the site. Also, MM-l
fails to protect the Bellamy Reservoir from the migration of the
southern plume. Alternative MM-2 includes institutional controls to
assist in protecting humans from consumption of contaminated
groundwater, yet do nothing in the short term to protect the waters of
the Bellamy Reservoir.
Alternative MM-3, and to a lesser extent, alternative MM-4, have
significant short-term adverse impacts on the wetlands to the south
an~ east of the site as a result of construction and monitoring to
take place in them. However, they meet the NCP's mandate of
groundwater cleanup in a reasonable time. Alternatives MM-3 and MM-4
would have to comply with additional action specific ARARs such as
state and federal groundwater discharge limits and other applicable
groundwater anti-degradation regulations.
The manaqeaent of migration alternatives would meet few if any ARARs
if implemented without an active source control portion of the remedy.
The time frame to attain cleanup levels would increase significantly
due to the continued release of contaminants into the groundwater from
the Landfill.
In the lonq term all of the manaqement of miqration alternatives
achieve compliance with chemical specific ARARs~ however, the
alternatives differ in the time it takes to achieve compliance.
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ROD DBCISIO.'SUKMARY
DOVER MUNICIPAL LAHDPILL SITB
. 3. Long-term Bffectivene.8 and permane~ce
The No Action (SC-l) and Limited Action (SC-2) alternatives would not
be effective or permanent in reducing long-term risk: all of the
contaminants will remain at the Site and continue to leach into the
groundwater.
Alternative SC-7/7A and alternative SC-5/5A provid~ effective, long-
term reduction in leachate generation, control of landfill gases, and
eliminate the potential for dermal contact with untreated wastes.
Both alternatives require the construction of a multi-layer
(composite) cap on the Landfill that provides long-term minimization
of precipitation infiltration, resulting in a reduction in the amount
of leachate generated. They also require the construction of a
leachate collection system - either a slurry wall or an interceptor
trench - both of which provide for long term reduction of clean water
entering the Landfill and long term collection of contaminated water'
leaving the Landfill. Both alternatives provide for treatment of the
contaminated leachate and groundwater.
All of the Management of Migration Alternatives, provide an equal
degree of long-term effectiveness and permanence, when instituted with
an active source control alternative. Alternatives MM-3 and MM-4
~mploy treatment of contaminated groundwater to meet cleanup levels
lor VOCs and metals. Alternatives MM-l and MM-2 do not propose any
action to remediate the contaminated groundwater but rely on natural
attenuation processes, over time, to attain the groundwater cleanup
levels. The primary difference in these alternatives are the times
they ta~e to meet clean up levels and the protection they afford in
the short run. Both MM-3 and MM-4 provide significantly more
protection in the short run to the Bellamy Reservoir.
4.. aeduction of Toxicity, MObility, or Volume through Treatment
Alternatives SC~l and SC-2 would not provide a reduction in
contaminant toxicity, mObility, or volume through treatment because
these alternatives do not provide for treatment. Alternatives SC-7/7A
and SC-5/5A are similar in their ability to achieve the cleanup levels
for groundwater at and beyond the point of compliance by effectively
reducing contaminant toxicity, mObility, and volume through
collection and treatment of the groundwater/leachate prior to
discharge. Alternatives SC-7/7A and SC-5/5A would reduce the mObility
of the contaminants in soil and sediments but would not reduce the
volume or toxicity because direct treatment of these materials is not
practic~le. .
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ROD DBCISIOHSUMKARY
DOVER MDNYCIPAL LANnPILL SITH
Alternatives MM-l and MM-2 would not provide any reduction in
toxicity, mobility, or volume of any groundwater contaminants through
treatment. Alternatives MM-3 and MM-4 would reduce toxicity, mobility,
and volume through treatment since both alternatives would employ
collection and treatment of contaminated groundwater prior to
discharqe.
5. Short-term Bttectivene..
. Alternatives SC-l and SC-2 would not have any short term impacts from
construction and implementation activities. Alternatives SC-5/5A and
SC-7/7A have the potential for release of contaminants during
construction activities especially during the recontouring of the
landfill and the digging of the trench or slurry wall. However,
special engineering precautions would be taken to minimize the
potential for air releases of contaminants to ensure protection of
workers and area residents during cleanup related construction
activities. These measures include interim foam covers, enclosed cabs
on backhoes and hydraulic excavators, and dust and odor suppression
techniques to control fugitive dust emissions. Additionally, since
active measures are being taken to control and intercept the migration
of contaminated groundwater/leachate, attainment of groundwater
cleanup levels at the compliance boundary will occur sooner than with
SC-l and SC-2.
Some increase in traffic and noise pollution would be expected from
! activities under SC-5/SA and SC-7/7A, especially from the import of
off-site fill needed to construct the cap. Short term effectiveness
would be somewhat lower for SC-5A and SC-7A relative to SC-5 and SC-7
due to the construction impacts from the 2.5 mile sewer connecting to
the POTW. The total construction periods are estimated to be 3-4
years for SC-S/5A and 2-3 years for SC-7/7A.
Neither MM-l nor MM-2 poses a threat to human health or the
environment as a result of construction or implementation.
Alternatives MM-3 and MM-4 would have short-term impacts to adjacent
wetlands during construction. Construction of the groundwater
recovery wells and recharge system in MM-4, plus associated
transmission piping may negatively impact the wetland vegetation in
the construction area. An area 10 feet wide and 2,000 feet long would
be extensively disturbed in order to install the extraction wells and
piping. The construction of the interceptor and recharge trenches
under MM-3 require an even larger impact due to construction
activities. An access roadway along the perimeter of the trench would
be necessary to transport the material for construction as well as
.providing a staging area for the excavated soils. Both alternatives
have the potential to affect the water balance of the wetlands due to
pumping and discharge. Recharging of the treated groundwater is
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ROD DECISION SUMKARY
DOVER MUNICIPAL LANDPILL SITB
expected to minimize the dewatering of the wetlands.
Alternatives ~~-1 and MM-2 employ natural attenuation and are expected
to attain cleanup levels in the eastern plume in S to 7 years and 10
to 24 years in the southern plume after the implementation of an
active source cO!l~rol remedy. In the eastern plume, MM-3 and MM-4
offer an improvement over MM-l and MM-2: 3 to S years vs. S to 7
years. In the southern plume, because MM-3 relies on the natural flow
of groundw~ter, the time frame for MM-3 clean up will not be a
. significant improvement over MM-l and MM-2. . The time frame for MM-4
cleanup of the southern plume will depend largely upon the rate that
the contaminated groundwater can be extracted ~rom the aquifer: it is
expected to be an improvement over the MM-3 time frame. Alternatives
MM-3 and MM-4 offer significantly better protection for the Bellamy
Reservoir in the short term: contaminants will be prevented from
migrating closer to the reservoir by these two alternatives.
6. Implem8ntability
Alternatives SC-S/SA, SC-7/7A, MM-2, MM-3, MM-4 are implementable, are
well-developed technologies, and have been used successfully at other
sites. The recontouring activities present some potential for
encountering hazardous waste. Preliminary studies and special
construction procedures would be used to minimize this potential.
~ot spots, consisting of highly toxic and/or highly mobile material
bich present a potential principal threat to human health or the
environment, once exPosed by recontouring would have to be tested,
removed, treated and disposed of in an off-site RCRA TSD facility.
The multi-layer cap and PACTTM systems of SC-S/SA and SC-7/7A have
been installed on many other sites. Obtaining clay of sufficient
volumes for the low permeability layer of the cap may be difficult
under alternative SC-S/SA.
Sufficient land is available for operation of the groundwater/leachate
treatment system and its supporting facilities for SC-S/SA and SC-
7/7A. Preliminary bench-scale and pilot-scale testing would have to
be performed. prior to implementation of the groundwater treatment
system. . No major technical problems are anticipated. .
The interceptor trench/barrier wall of SC-7/7A would require less
technical and support equipment resources 'to install than the slurry
wall of SC-S/SA. The design and construction of the sediment cover
(SC-S/SA) in ~hd urainage swale down to the Cocheco River would not
pose any unique implementation problems. However, the limited.
excavation provided for in SC-7/7A would be much easier and quicker to
. implement. Construction activities would have to be scheduled during
seasonal low flows to minimize potential impacts on the Cocheco River.
The sediment removal activity under SC-7/7A poses no significant
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ROD DBCISIOIl stOOIARY
DOVER MURYCIPAL LAHDPILL SITB
implementability problems.
An expansion of the DoverPOTW is currently under construction and is
expected to be in place by 1992. It should be able to provide
adequate treatment capacity for the Site's pre-treated groundwater and
leachate as an alternative (SC-5A and SC-7A) to discharging to the
Cocheco River. .
Alternatives SC-1, SC-2, MM-1 and MM-2 can be accomplished with little
difficulty and use well established and reliable monitoring and.
analytical procedures. However, some of the proposed institutional
controls may be difficult to implement.
Alternatives MM-3 and MM-4 are both easily implemented. MM-3's trench
construction in wetlands is somewhat more difficult than MM-4's '
extraction wells. Also, MM-4 would be implemented more easily for a
deeper zone of contamination than would the trench.
7. Cost
The estimated' present worth value of each alternative and the options
are as follows:
COST COKPARISOIl OP SOURCB COIlTROL ALTERNATIVES
SC-1
SC-2
No Action
Limited Action
Recontour/Multi-
Layer Cap/ Slurry
Wall/ Groundwater
Treatment/
Disch~rge to
Cocheco River/
Sediments Cover
Be-SA Recontour/Multi-
Layer Cap/ Slurry
Wall/ Groundwa~er
Treatment/
Discharge to POTW/
Sediments Cover
SC-5
$
Capital
Costs
o
o & M
169,000
177,600,
221,400
Present
Worth
1,593,400
1,718,300
33,353,600
44,400
31,266,600
31,334,600
205,000
33,267,100
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ROD DBCISIOI1 SUJlKARY
DOVER MUNICIPAL LAllDPILL SITB
SC-7
Recnnto1.1r/Multi-
Layer cap/
Interceptor/
Diversion Trench/
Groundwater
Treatment/
Discharge to
Cocheco River/
Sediments
Excavation
Recontour/Multi-
Layer cap/
Interceptor/
Diversion Trench/
Groundwater
Treatment/
Discharge to
Cocheco River/
Sediments
Excavation
20,014,800
239,300
22,270,600
SC-7A
20,174,700
211,862
22,171,900
COST COMPARISON OF MANAGEMENT OF MIGRATION ALTERNATIVES
capital
Costs
O&M Costs Long-Term
($/Yr) Monitorina
Present
Worth
MM-1 No Action $ 0 142,834 * 1,346,482
MM-2 Limited Action 9,356 176,541 * 1,673,593
MM-3 Groundwater Interceptor 1,452,154 78,840 892,200 2,828,738
Trench/Recharge Trench/
Groundwater Treatment
.
MM-4 Groundwater Extraction 1,503,699 394,200 892,200 4,818,047
Wells and Treatment
System
* Long-term monitoring costs are included in the capital and 0 & M
costs for these remedies.
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ROD DECISIOB SUKKaRY
)OVER MUNICIPAL LAHDPILL SITE
,8. state Acceptance
The New Hampshire Department of Environmental Services (NHDES) has
been involved in the study and oversight of the site since the late
1970's, as summarized in section II of this document. The Remedial
Investigation was performed as a state lead through a cooperative
agreement between the state and EPA. The NHDES has reviewed this
document and concurs with the source control and eastern plume
management of migration portions of ,the selected remedy and has
reserved a concurrence decision on the southern plume management of
. migration portion of the selected remedy until pre-design studies have
been completed. A copy of the declaration of concurrence is attached
as Appendix D.
9.community Acceptance
The comments received during the public comment period and the and
the public hearing on the Proposed Plan and FS are summarized in the
attached document entitled "The Responsiveness summary" (Appendix G).
In addition, a summary of the comments appears below.
A large number of comments were submitted by citizens of Dover and
Madbury as well as their community leaders and representatives, both
at the public hearing and in writing during the pUblic comment period,
\rquing that the taxpayers of these two towns could not bear the costs
~f the proposed remedy. Many of these commentors argued that the EPA
should take no action other than long term monitoring, while others
argued that a less effective cap would suffice. It should be noted
that prior to the public comment period, the City of Dover and the
Town of Madbury had been issued general notice of potential liability
for the cleanup of the site thus giving rise to the possibility that
local taxpayers will bear some portion of the cleanup cost.
One resident from the community wrote that placing a fence around the
site will not p~otect anyone from possible hazards of the
contamination, does not feel residents should be penalized for the
PRPs' unwillingness or inability to correct mistakes made in the past,
and hopes that EPA takes into consideration the effect of a Limited
Action Plan on the people and property values around the Landfill.
The Public Works Department of the City of portsmouth commented on the
proposed plan stating it agreed with the EPA's preferred alternative.
It also noted that if the aellamy Reservoir were contaminated, the
cost of replacing it would far exceed the cost of the remedial action
proposed for the Landfill.
The PRPs submitted seven comments, an alternative to EPA's proposed
cleanup plan, and a public health evaluation report. The seven
comments are summarized as follows: 1) the PRPs want to see a
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ROD DBCISIOB SUMMARY
DOVER MUNICIPAL LAHDPILL SITB
conditionally phased approach to cleanup the Site; 2) the PRPs do not
feel that remediation of the southern plume through groundwater
extraction and treatment is justified; 3) the PRPs state that the
Proposed Plan did not clearly define the criteria for termination of
active on~ and off-site groundwater recovery and treatment operations;
4) the PRPs want the compliance boundary at the edges of the Bellamy
Reservoir and the Cocheco River to which Site groundwater discharges;
5) the PRPs comment that the EPA preferred multi-layer cap is,
excessive and that the NHDES minimum design specifications for solid
waste landfill caps should be incorporated; 6) the PRPs want a .
separation of flows between the contaminated groundwater in the
interceptor trench and the clean groundwater in the diversion trench;
and 7) the PRPs comment that the remediation of the drainage swale
sediments to address risk associated with arsenic present in the
sediments is overprotective.
The alternative that the PRPs submitted includes phasing the cleanup
at the site. Phase 1 includes the construction of a NHDES solid waste
cap over the Landfill. They commented that if this remedial action
was sufficient to achieve Site cleanup objectives, further action
would not be needed and would not be implemented, and if further
action were judged to be needed, additional phases could be
sequentially implemented. Phase 2 includes the installation of a
groundwater interception trench upgradient of the Landfill; Phase 3
includes the installation of a groundwater interceptor trench
downgradient of the Landfill with collection and treatment of
intercepted groundwater and Phase 4 includes the installation and
operation of an off-site groundwater extraction and treatment system.
The public health evaluation report submitted by the PRPs commented on
the methodologies employed by and the uncertainties associated with
the baseline risk assessment of the RI.
z.
TJIB 8BLBCTBD RBKBDY
The remedy selected for the Dover Municipal Landfill Site, source
control alternative SC-7/7A and a 'combination of the management of
migration alternatives MM-2 and MM-4, addresses all contamination at
the site.
A.
Inter!. Groundwater CleanuD Levels
Interim cleanup levels have been established for contaminants of
concern identified in the baseline risk assessment found to pose an
unacceptable risk to either public health or the environment. Interim
cleanup levels have been set based on the appropriate ARARs (e.g.
Drinking Water MCLGs and MCLs) if available, or other suitable
criteria. Periodic assessments of the protection afforded by remedial
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OD DECISION SUMMARY
~R MUNICIPAL LANDPILL SITB
actions will be made as the remedy is being implemented and at the
completion of the remedial action. At the time that all the interim
cleanup levels described below have been achieved, a risk assessment
shall be performed on the residual groundwater contamination. This
risk assessment of the residual groundwater contamination shall follow
EPA procedures and will assess the cumulative risks for carcinogens
and non-carcinogens posed by consumption of groundwater. If the risks
, are not within EPA's risk levels for carcinogens and non-carcinogens,
.then the remedial action will continue until protective levels are
attained, or the remedy is otherwise deemed protective.
Because the aquifer at and beyond the compliance boundary for 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 and B) have been set at the appropriate MCL given that the
MCLGs for these compounds are set at zero. In the absence of an MCLG,
an MCL, a proposed drinking water standard or other suitable criteria
to be considered (i.e. health advisory, state criteria), a cleanup
level was derived for carcinogenic effects based on a 10'6 excess
cancer risk level. considering the ingestion of ground water.
interim cleanup levels for the Class C, D and E compounds (possible
carcinogens, not classified, and no evidence of carcinogenicity) have
been set at the MCLG. Interim cleanup levels for compounds in ground
water exhibiting non-carcinogenic effects have been set at the MCLG.
In the absence of a MCLG or other suitable criteria to be considered,
interim 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 lifetime.
EPA has determined that the Safe Drinking Water Act (SDWA) MCL for
arsenic in groundwater is relevant but not appropriate to this site
and therefore is not an~. since naturally occurring levels of
arsenic 'in the groundwater at and around the site are suspected of
being greater than the SDWA MCL for this substance, based on field
sampling and relevant literature, it may be technica~ly impracticable
for any cleanup technology to reduce arsenic levels below background
to the SDWA MCL. Given that the Resource Conservation and Recovery
Act (RCRA) regulations establish cleanup levels for arsenic in the
groundwater at the same point as the SWDA MCL (50 ug/l) or at
background levels, 'whichever is higher, RCRA sets a more appropriate
'flexible standard for the arsenic cleanup level for this site. )
~ough the interim cl~anup level for arsenic is based on the RCRA MCL
of 50 ug/l, data has indicated that arsenic occurs naturally in
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ROD DECI8IO& 8UMMARY
DOVER MUHICIPAL LANDFILL 8ITE
groundwater at the Site. It is the intent of EPA to establish the
background '~vp.1 ~or arsenic in groundwater prior to or during the
remedial design. In accordance with RCRA, cleanup levels for arsenic
will be set at 50 ug/l or background, whichever is higher. Until
background levels "for arsenic in groundwater is determined, the
interim clean~p lev~l will be set at 50 ug/l.
Table 1 below summarizes the Interim cleanup levels for carcinogenic
and non-carcinogenic contaminants of concern identified in ground
water.
TABLE 1: INTERIM GROUND WATER CLEANUP LBVBL8
Carcinogenic Interim
Contaminants of Cleanup Level of
Concern IClass) Level IDDb) Basis Risk
Arsenic (A) 50' MCL8 2 . OX-04b
Benzene (A) 5 MCLc 4 . 1X-06
1, 1 Dichloro-. 1.2x-04
ethylene (C) 7 MCLG
1,2 Dichloro- 1. 3x.05
ethane (B) 5 MCL
Methylene pMCLd 1. 1X-06
chloride (B) 5
Tetrachloro-
ethylene (B) 5 MCL 7. 3x-06
Trichloro-
ethylene (B) 5 MCL 1. 6x-06
Vinyl Chloride (A) 2 MCL 1.3x-04
SUM 4. 8x10-4
Bon-carcinogenic Interim. Target
Contaminants cleanup Endpoint Hazard
Concern Level IDDb) Basis of Toxicitv Index
Arsenic 50 MCL keratosis 1..4
Chloroethane 14000 RfD developmental 1.0
Tetrahydrofuran. 700 RfC8 liver 10.0
Acetone 700 NHCPHSf liver 0.2
Methyl Ethyl Ketone 200 HA' fetotoxicity 0.1
Methyl Isobutyl
Ketone 350 NHDPHS liver, kidney 0.2
Toluene 1000 MCL liver, kidney 0.14
. Due to the presence of naturally occurring arsenic at and around the
Site, the cleanup levels will be 50 ug/l (MCL) or background,
whichever is higher~ as determined by the EPA and NHDES during
predesign and design activities.
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ROD DBCISIOR SUXMARY
DOVER MUNICIPAL LAHDPILL SITB
a - Maximum Contaminant Level, Resource Conservation and Recovery Act.
b - The cleanup level for arsenic in groundwater 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 recent
'studies indicating that many skin tumors arising from 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 these risks downward by as
much as a factor of ten. As a result, the carcinogenic risks for
arsenic at this Site have been managed as if they 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.)
c - Maximum Con~aminant Level, Safe Drinking Water Act
d - Proposed Maximum contaminant Level
e - A Reference Dose of .002 mg/kg/day was used to derive the 'interim
cleanup level and associated Hazard Index. (See memo from P. Hurst to
R. Duwart dated May 3, 1990 - Appendix C) An uncertainty factor of
10,000 is associated with this RfD. Because of this've~ high
~ncertainty factor, a Hazard Index of 10 is considered acceptable.
f - New Hampshire Department of Public Health Services Drinking Water
criteria
g - EPA Health Advisory
These cleanup levels must be met at the completion of the remedial
action at the point of compliance, which in accordance with the NCP,
is. established at and beyond the edge of the existing waste area. The
existing waste area includes the landfill and the leachate trench
surrounding it. After construction of the remedy the point of
compliance will be the outer wall of the interceptor trench. EPA has
estimated that these cleanup levels will be obtained within 5 to 7
years' for the eastern plume and in less than 10 to 24 years for
attainment in the southern plume after implementation of the source
control component.
While these interim cleanup levels are consistent with ARARs (or
suitable To Be Considered criteria) for groundwater, a cumulative risk
th~t could be posed by these compounds may exceed EPA's acceptable
risk range for remedial action. Consequently, these levels are
considered to be interim cleanup levels for groundwater. In addition,
once all these levels are achieved for each compound, EPA expects that
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ROD DBCISION SUMMARY
DOVER MUNICIPAL LANDFILL SITE
.due to different rates of attenuation for each compound, levels of
most will be below these interim cleanup levels. Thus, when all of
the interim cleanup levels have been attained, a risk assessment will
be performed on residual groundwater contamination to determine
whether the remedial action is protective. Remedial actions shall
continue until protective concentrations of residual contamination
have been achieved or until the remedy is otherwise deemed protective
by EPA. These protective residual levels shall constitute the final
cleanup levels for this Record of Decision and shall be considered
performance standards for any remedial action.
B. Sediment Cleanup Levels
The cleanup level for arsenic, in the sediments of the drainage swale,
has been set at a level deemed protective for environmental receptors.
The drainage ditch surrounding the Landfill conducts surface water to
a drainage swale which empties into the Cocheco River. Arsenic levels
in the drainage swale range from 36 ppm at the top of the swale, to 99
ppm at the confluence of the swale with the Cocheco River. Arsenic
levels in the sediments of the landfill perimeter drainage ditch were
found at 51 and 210 ppm.
The National Oceanic and Atmospheric Administration (NOAA) has
analyzed data collected worldwide using a variety of methods to
determine the probable levels where adverse biological effects would
occur for most contaminants. The chemical concentrations observed or
predicted by the different methods to be associated with biological
effects were sorted. The lower 10th percentile (Effects Range Low or
ER-L) was identified indicating the low end of the range of chemical
concentrations at which an adverse effect was observed or predicted.
The median concentration (Effects Range Median or ER-M) was identified
as representative of the concentration above which adverse effects
were frequently or always observed or predicted among most species.
These ER-L or ER-M values are not to be construed as NOAA standards or
criteria, but as guidelines by which sediment contamination can be
evaluated. .
The levels of arsenic found in the sediments in the drainage swale
exceed both the NOAA ER-L and ER-M for arsenic. The ER-L is 33 ppm,
that is, 10 percent of the available data showed some adverse affect
occurred at an arsenic level of 33 ppm. TheER-M is 85 ppm, a
concentration at which 50 percent of the data demonstrated an adverse
response.
The observed concentrations of arsenic at the site were evaluated in
conjunction with the associated physical parameters, specifically
total organic carbon (TOC), and grain size, which contribute to the
bio-avail~ility of the arsenic; and with the NOAA guidelines. The
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ROD DBC%S%OW SUMMARY
DOVER MUH%C%PAL LANDP%LL S%TB
evaluation indicates that a 33 ppm cleanup level corresponding to the
ERL would be conservative cleanup level. A cleanup level of 50 ppm
would be justified, and would provide 'for protection of the
environment. '
This 50 ppm cleanup level must be met at the completion of the
remedial action at and beyond the point of compliance. Thus, the
drainage swale east of the Landfill and down to the Cocheco ~iver and
the sediments that have accumulated 'at the convergence of the swale
and the river must meet this cleanup level. .
c.
DescriDtion of Remedial ComDonents
The source control portion of the remedy will involve the following
key components:
Use of on-site material from the perimeter of the Landfill to
recontour the existing Landfill to achieve the necessary slope
for drainage; ,
Construction of a multi-layer cap over the recontoured Landfill;
Construction of a leachate/groundwater extraction system and
clean groundwater diversion system provided by a perimeter
interceptor trench, extraction wells or a combination of the two;
Installation and operation of an on-site groundwater/leachate
treatment system with discharge to the Cocheco River for SC-7 and
discharge to POTW for SC-7A;
Methane gas collection and passive venting;
Construction of a surface run-on/run-off diversion 'system with
sedimentation/ detention basins; and
Limited drainage swale sediment removal and consolidation under
,the Landfill cap.
Recontouring involves the moving of the existing Landfill perimeter
soils and debris from the toe of the Landfill side slopes, as well as
the perimeter drainage ditch sediment, on top of the Landfill to
contour features of the Landfill prior to capping. Recontouring will
be done to provide adequate slopes to allow for proper surface water
drainage from the waste pile area. Recontouring will also reduce the
amount of imported clean fill required to obtain these slopes.
Approximately 1,200,000.cubic yards of imported soil will be necessary
to cover the 55-acre Landfill if the maximum allowed 5% slope is used.
This volume is reduced to approximately 850,000 cubic yards if the
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ROD DBCISIOH SUHHARY
DOVER XUHICIPAL LANDPILL SITB
Landfill is recontoured. For a minimum 3% slope, the amount of
imported soil cculd be reduced by another 20-30% from the
approximately 550,000 cubic yards. Reductions in the amount of
imported soil would translate to a proportionate reduction in truck
traffic, congestion, roadway damage, noise and dust. It will also
significantly reduce the cost of the cap. The ultimate slope will be
determined during desiqn.
During recontouring, waste material at the perimeter of the Landfill
'would be uncovered and hot spots may be encountered. To minimize
this possibility, a preliminary assessment would be performed
consisting of geophysics and test pit exploration before the
commencement of recontouring activities aimed at limiting the
excavation to areas containing predominantly soils, debris, and
municipal waste. If, however, hot spots are exposed, the material
would be tested and removed, treated, and disposed of off-site in
accordance with RCRA and state hazardous waste laws.
The multi-layer cap (also referred to as a composite cap) prevent$
direct infiltration of precipitation into the Landfill to minimize the
subsequent generation of leachate. Figure 10 is a cross-section of a
typical mUlti-layer cap. This mUlti-layer cap consists of the
following layers (from top to bottom):
.
Top soil
Common fill
Geosynthetic fabric
Drainage layer
composite low permeability layer consisting of a
membrane liner over a low-permeability material
Geosynthetic fabric
Gas vent layer
flexible
.
.
.
.
.
.
The top layer of the multi-layer cap consists of two components: (1)
a vegetative top soil, selected to minimize erosion and, to the extent
possible, promote drainage off the cover and (2) a soil component
comprised of common fill, the surface of which slopes uniformly at
least 3 percent but not more than 5 percent.
The drainage layer shall have a minimum hydraulic conductivity of 1 X
10-2 em/sec which will effectively minimize water infiltration into'
the low-permeability layer. This layer will have a final slope of at
least 3 percent after settlement and subsidence to allow the
infiltrated water to flow along the low-permeability liner and not
collect, or .pool", in anyone location along the low-permeability
'liner. The drainage layer also provides a protective bedding for the
flexible membrane liner (FML). There are generally two options for
the materials used to construct this layer: (1) 12 inches of soil
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~OD DBCISION SUKMARY
DOVER MUNICIPAL LANDPILL SITB
(coarse sands) or (2) a geocomposite material (geonet between two
layers of geotextile) with equivalent perŁormance characteristics.
The largest factor in determining the material to be utilized will be
the depth of protection needed to prevent the maximum frost
penetration of the low-permeability layer. Cycles of freezing and
thawing may cause cracking, lessening ~f density, and loss of strength
to the low-permeability layer. If a geocomposite material is utilized
as the drainage layer, the thickness of the vegetative layer must be
protective such that the maximum depth of frost penetration will not
ipfiltrate the low-permeability layer. .
~he third layer is the two-component low~permeability layer, lying
wholly below the maximum depth of frost penetration, that provides
~ong-term minimization of water infiltration into the underlying
wastes. This low-permeability layer consists of a 40-mil (1.0 mm)
minimum thickness flexible membrane liner component and a compacted
soil component with a minimum thickness of at least 24 inches and a
maximum in-place saturated hydraulic conductivity of 1 X 10-7 em/sec.
There are several alternative ma~erials that can be used for the low-
permeability layer; clay, a soil/bentonite mixture.or a bentonitic
blanket. Regardless of which material is used, it must meet the
criteria of having a hydraulic conductivity of 1 x 10-7 em/sec. The
criteria for selecting which ma~erial to use for the low~permeability
layer are availability, implementability, and cost.
A gas vent layer between the Landfill wastes and the low-permeability
layer shall be installed. This layer is generally made up of 12
inches of coarse-grained, porous materials (similar those used in the
drainage layer) that allow gases emanating from the wastes buried in
the landfill to be collected. vent structures will be installed into
this layer, allowing the gases to vent ~ the atmosphere. These gases
shall be tested, and if needed, additional measures, such as, .but not
limited to, the installation of carbon canisters, will be implemented
to reduce odors and VOC emissions.
Filter layers (geotextiles) are lik~ly to be needed above the drainage
layer, above the gas vent layer and between any other layers comprised
of soils of greatly different particle sizes, to prevent one from
migrating into the other. The filters may be constructed of graded
soil materials or geosynthetic materials.
This mUlti-layer cap represents the state-of-the-art in landfill cap
design and as such is as a reliable .and effective cap as can currently
be designed. The cap wil1 be designed to meet or exceed the
.performance requirements set forth in ARARs including 40 CFR 264.111,
40 cta 264.310 and the guidance document Final Covers on Hazardous
Waste Landfills and Surface ImDoundments, July 1989 (EPA/530-SW-89-
047) (Technical Guidance) or iri a manner to achieve performance
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ROD DBCIS%OH SUXHARY
DOVER MUNICIPAL LANDPILL SITB
equivalent to that of ARARs.
The pUrpose of the interceptor trench/extraction well system is to
actively lower the groundwater table level beneath the Landfill so
that the waste material is no longer in contact with the groundwater
, that may wig~atG vff-.site. Figure 14 shows a typical groundwater
depression caused by an interceptor trench. The groundwater/leachate
recovery system consists of approximately 2,200 feet of interceptor
trench installed to approximately 25-feet of depth on the downgradient
side of the Landfill, at the historical boundaries of the Landfill, to
collect contaminated groundwater. The length of the interceptor
trench vertical barrier (impermeable membrane) will extend the full
6,100 feet around the perimeter of the existing (5S-acre) Landfill.
The actual depth will depend on the results of hydrogeologic and
geotechnical engineering studies conducted during predesign. The
2S-foot depth represents the approximate point at which the lower
permeability interbedded zone begins. Inside the trench, a perforated
pipe wrapped with filter fabric and drainage net would be laid and
connected to a series of manholes. Submersible pumps with high/low
switches will be housed inside the manholes to extract the collected
groundwater and leachate. .
The upgradient portion of the trench serves as a diversion system for
the upgradient clean groundwater. The upgradient groundwater is
diverted to prevent clean groundwater from possible contact with the
landfill wastes, thus reducing the volume of contaminated groundwater
requiring treatment. The clean groundwater flowing into this trench
would be diverted to either the ,wetlands or the Cocheco River without
mixing with contaminated groundwater. The determination as to the
ultimate discharge location will be made during design.
Extraction wells, alone or in conjunction with the interceptor trench,
may be utilized, especially where contaminated groundwater flows from
the Landfill at a depth greater than 25 feet. The extraction wells
can be placed at points around the Landfill to optimize the extraction
of the more highly contaminated areas of the plume. An example of
this would be the installation of an extraction well on the edge of
the landfill, closest to the monitoring well B-2U. The extraction
well will collect not only leachate emanating from under the Landfill,
but through draw down, can also "pull back" and extract the
contaminated groundwater currently detected in well B-2U.This will
prevent this contaminated groundwater from flowing past B-2U and
entering in~~ ~h~ Cccheco River, or discharging through seeps in the
drainage swale and volatilizing into the atmosphere.
Monitoring wells will be installed in the central portion of the
Landfill for the following purposes: to determine groundwater
contamination levels directly under the Landfill: to detect
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ROD DBCISIOB SUXMARY
DOVER MUHICIPAL LAHDPILL SITB
'contaminants that may have pooled under the Landfill and on top of the
marine clay layer; and to monitor water' table declines within and
beneath the Landfill. The installation of extraction wells in the
landfill will supplement contaminated groundwater and leachate
extraction from under the Landfill and further lower the water table
beneath the Landfill. The number and location of these wells will be
determined during design.
The implementation of the contaminated groundwater and leachate
collection system, the upgradient diversion trench and the
installation of extraction wells within the Landfill will be optimized
so as to minimize redundant functions of each individual component. In
addition the components, as a complete system, will be designed to
achieve the objectives of lowering the groundwater beneath the waste
materials, preventing clean groundwater from contact with the wastes
or increasing the amount of contaminated groundwater requiring
treatment, and preventing contaminated groundwater and leachate from
exceeding SDWA MCLs at and beyond the compliance boundary.
The groundwater/leachate treatment system selected for the Site must
be able to address metals, organics, and potentially high chemical and
.biochemical oxygen demand levels. A r.0wdered activated carbon
treatment system, similar to the PACT" System, has been selected to
treat the contaminated groundwater/leachate. However, if during pre-
design pilot studies it is determined that this system will not be as
effective or efficient as an air stripping system, preceded by metals
precipitation, this alternate treatment system may be employed.
The Powered Activated Carbon Treatment System (PACTTM) consists of the
following steps. Collected groundwater would first enter an aeration
tank to remove VOCs; activated carbon present in the tank would remove
non-volatile organic chemicals from the water. The water would then
pass through a settling tank where flocculation, coagulation, and
precipitation processes takes place to remove metals and suspended
solids. precipitation reduces the solubility of iron, nickel,
chromium and other metals so that tiny particles of the metals are
produced. Once a precipitate forms, the flocculation tank allows the
particles to collide and adhere due to flocculating agents. The
heavier metals precipitates and solids then settle at the bottom of
the tank in the form of sludge. The sludge will tested to determine
if it i8 a RCRA waste and then disposed of off-site in compliance with
ARAns. The water then passes through a mUlti-media filter before
being discharged. The effluent from the groundwater treatment process
would have to meet the substantive requirements of NPDES for discharge
to the Cocheco River and/or discharge to the wetlands. A schematic of
this groundwater treatment system is shown in Figure 11. The design
flow for the groundwater/leachate treatment systems is approximately
40.gpm.
-
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~OD DECISIOB SUKMARY
DOVER MUNICIPAL LANDFILL SITE
The two discharge options available are: 1) discharge to the Cocheco
River ar.d ~} ~1~~harge to the Dover POTW. The POTW option would
require the installation of approximately 2.5 miles of sewer line and
at least one li(t station. Leachate collected from the groundwater/
leachate collection system would be discharged to the local sewer
system. Some on-site pretreatment of leachate may be required to meet
applicable sewer discharge standards. Table 9 lists the current sewer
discharge pretreatment standards for the Dover POTW. At pres~nt, the
Dover POTW has the extra capacity to handle some pre-treated water
from the Landfill, and the capacity is expected to increase further by
~992 with the start-up of the secondary treatment unit, currently
under construction. The decision on discharge options will be made
during pre-design studies.
The sediment control component provides for predesign sampling to be
performed to identify specific areas of sediment deposition along the
drainage swale that contain concentrations of contaminants in excess
of the arsenic clean-up level. Based on the physical characteristics
of the drainage swale, the extent of contamination is expected to be .
limited. The removal of approximately 300 cubic yards of contaminated
sediments is expected to occur through the use of manual labor.
However, if the amount of material to be removed is extensive, other
mechanical means may have to be employed. The excavated sediments
will be deposited back on top of the Landfill prior to the
construction of the Landfill cap.
The selected remedy for the management of migration utilizes portions
of MM-2 and MM-4 and includes the fOllowing elements:
the use of institutional controls, where possible, to prohibit
the use of groundwater:
implementation of a long-term groundwater sampling/monitoring
program:
pre-design studies which include the installation of additional
"monitoring wells to further define the lateral extent, depth and
mass of the contaminated groundwater; .
one or more pump tests to determine the ability and rate that
contaminated groundwater can be extracted from the aquifer:
use of natural attenuation processes to attain groundwater clean-
up levels in the eastern plume:
installation of several off-site groundwater extraction wells in
the southern plume, connection to an on-site treatment system,
extraction and treatment of the groundwater and recharge of the
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ROD DBCISIOB SUMHARY
DOVER MUNICIPAL LANDFILL SITB
reservoir which is a drinking water source for seven municipalities.
Data indicates groundwater in the southern plume, containing levels of
contaminants significantly above MCLs, has migrated from the Landfill
to' within approximately 900 feet of the reservoir.
In addition, it is estimated that if these contaminants are left to
naturally attenuate, it would take from 10 to 24 years to attain
cleanup levels after the implementation of the source control
alternative. During such a period of natural attenuation, which may
be up to 27 years when the years for construction of the source
control measures are taken into account, the groundwater contaminants
would continue to exceed ARARs. A 27 year period for cleanup .does not
constitute a reasonable time-frame for cleanup at this site. Also,
during this 27 year period contaminants, if left to naturally
attenuate, could reach and pollute the waters of the Bellamy
Reservoir. Therefore, a groundwater extraction and treatment system
will be implemented to return contaminant levels to MCLs as soon as
practicable and to manage the plume so as to prevent it from
contaminating the Bellamy Reservoir.
The. groundwater extraction system includes a low rate collection of
contaminated groundwater which has migrated into the wetlands adjacent
. and in a southern .direction from the Landfill. Extraction wells will
be installed at off-site locations and will intercept contaminated
groundwater in the direction of flow. Groundwater collected by the
extraction wells will collectively be pumped at an approximate total
of 50 qpm to a treatment unit on or adjacent to the Landfill.
Construction in the wetlands will be required to allow drilling
equipment access to new well locations, if necessary, and to install
the piping system connecting the extraction wells to the treatment
system. Once the extraction system is installed (approximately 6
months) the affected area will.be restored.
Groundwater treatment would be similar to that described in the
previous source control remedy except for the required treatment
capacity. The. treated groundwater will be recharged to the wetlands
to minimize any potential dewatering that may occur due to the
extraction system(and/or discharged to the Cocheco River. The
effluent from the groundwater treatment process would have to meet the
substantive requirements of NPDES for discharge to the Cocheco River
and/or discharge to the wetlands. .
One or more pump tests will be performed during pre-design studies to
determine the ability and rate that contaminated groundwater can be
extracted from' the aquifer. The actual time frame for attaining
cleanup levels in this southern area will depend largely upon the data
from this pump testes) and data from the installation of additional
monitoring wells to determine the lateral extent and depth of
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ROD DECISION SUHNARY
DOVER KUHICIPAL LAHDPILL SITB
treated groundwater to the wetlands or discharge to the Cocheco
River.
Institutional controls, where possible, will limit Site access, Site
use, prohibit the use of groundwater from the upper aquifer for
potable usage and prohibit the disturbance of the marine clay unit
between the upper and lower aquifers. These institutional controls
include fencing, warning signs, deed restrictions, zoning changes, and
. other actions which will prohibit the use of contaminated groundwater.
The City of Dover has already passed a zoning ordinance restricting
the use of groundwater within 1,500 feet of the Landfill as a potable
water 8upply. The Town of Madbury has proposed to take similar
action.
The RI and FES investigations indicate that contaminants exceeding
MCLs have migrated from the Lan~fill into the groundwater to the south
and the east of the site. Since ARARs are not met in the groundwater
at and beyond the point of compliance and. the risk to human health is
outside the EPA acceptable risk range in this area, sufficient.
justification exists for instituting active groundwater treatment in
both the southern and eastern plumes. However, groundwater modeling
has shown that in the eastern plume, natural attenuation processes
such as degradation, adsorption, advection and dispersion will
effectively cleanup the groundwater within 5 to 7 years after the
implementation of the source control. portion of this remedy. This
being the case, EPA has determined that the.NCP's requirement that
groundwater be returned to its beneficial uses within a time frame
that is reasonable given the circumstances at this site, will be met
by the use of natural attenuation for cleaning up the eastern plume.
This determination is in part based on the groundwater modeling
information which indicates that active treatment of the eastern plume
groundwaters would shorten cleanup times by only a few years.
If the groundwater cleanup levels in the eastern plume have not been
attained within the estimated time frame of 5 to 7 years through
natural attenuation processes, or if it becomes apparent that there
will be a siqnificant increase in the original estimated time frame,
then an active restoration system will be evaluated and implemented
for the eastern plume.
An active groundwater treatment remedy is selected for the
contaminated groundwater in the southern plume, which extends in the
direction of the Bellamy Reservoir. While the RI and FES
investigations indicate that the groundwaters around the Site, in. both
. the southern and eastern pl~e directions are in excess of SDWA MCLs,
these levels are of particular concern in the southern plume because
of their proximity to the Bellamy Reservoir. From the inception of
the RI, a primary concern at the Site has been the protection of this
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QOD DBCISION SUMMARY
DOVER MUNICIPAL LANDPILL SITB
. to monitor the reduction of contaminant concentrations over
time ~- ~-~~~ ~~ ]"sure that groundwater cleanup levels will be
achieved in the predicted time frames; and
. to determine the lateral extent of migration of the
contaminants in the groundwater in the southern plume.
The details of the groundwater monitoring program will be developed
during pre-design and design studies and tailored to the specifics of
the site. Additional groundwater monitoring wells will be installed,
. as needed, in. order to ensure that the objectives of the monitoring
program are achieved. specifically, additional wells will be
installed during pre-design to further define the lateral extent and
depth of contamination in the southern plume. Selected wells will be
monitored quarterly upon initiation of remedial design until
completion of the remediation. All samples will be analyzed for
Hazardous Substance List VOCs, tetrahydrofuran, and arsenic. Specific
wells and analytical parameters may be added or deleted depending on
sampling results and observed trends.
Frequent monitoring of treated groundwater recharge to the wetlands or
discharge to the Cocheco River shall be implemented, as well as
monitoring for the effects of dewatering to limit the impact to the
wetlands.
The groundwater modelling employed .to determine the relative
effectiveness of natural attenuation and extraction/treatment in the
southern plume, as well as the models employed to predict the impact
of the southern plume on the Bellamy Reservoir relied on a number of
assumptiQns which will be tested during pre-design studies. As noted
above, the remedy calls for pre-design studies which include the
installation of additional monitoring wells to. further define the
lateral extent and depth of both contaminant plumes as well as pump
tests to confirm assumptions concerning the rate at which contaminated
groundwater can be extracted from the upper aquifer. If these
studies, and any others determined by EPA to be necessary for further
delineation of the nature and extent of the groundwater contaminant
plumes, disprove fundamental assumptions employed in the models or
produce additional data such that EPA, in consultation with the state,
determines that active treatment of the southern plume may not be
appropriate and necessary to protect human health and the environment,
then EPA, in consultation with the state, and in accordance with the
NCP, will re-evaluate the use of active treatment for the southern
plume.
These pre-design studies will be initiated as soon as possible and no
later than the outset of remedial design/remedial action activities
and will take place before or during other remedial design activities
-------
ROD DBCISIOJT StJMKARy
DOVBR MUHICIPAL LAHDPILL SITB
contamination. Howeve~, the time frames are expected to be shorter
than the estimated 10 to 24 years expected for natural attenuation.
Periodic review and modification of the design, construction,
maintenance and operation of the groundwater extraction and treatment
. system will be necessary. Performance of the system will be evaluated
annually, or more frequently, to determine if EPA's acceptable risk
range and standards of the design criteria are beinq 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 and necessary modifications undertaken. Should
new information regarding the extraction and treatment technology
exist, 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
the cleanup levels have been met and the remedy is protective. If
these levels are maintained for three years and the remedy is
determined to be protective, a long-term monitoring.program for the
Site, in accordance with RCRA and New Hampshire Hazardous Waste Rules
will be implemented..If the risk,assessment indicates that the remedy
has not been effective, the performance standards and/or the remedy
will be reevaluated.
A long-term groundwater sampling and monitoring program will be
initiated during pre-design and continue for three years after
attaining groundwater cleanup levels to assess the effectiveness of
remediation and to confirm that contaminant concentrations in
groundwater attain cleanup levels. If at any time the groundwater
monitoring data indicates that the cleanup levels will not be met in
the eastern plume within 5 to 7 years after the implementation of the
source control remedy then a re-examination will be made of the nature.
and extent of contamination in this plume and this remedy will be
adjusted if appropriate.
The groundwater monitoring program will be developed for the following
purposes: .
. to evaluate the effectiveness of the source control
remediation measures designed to prevent groundwater
contaminants in excess of SDWA MCLs to migrate beyond the
compliance boundary: .
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ROD DBCISIOH SUMMARY
DOVER MUNICIPAL LANDFILL SITB
implementation of the cap and groundwater/leachate collection system
should eliminate risk resulting from the ingestion and dermal contact
with the contaminated surface water and sediments in the perimeter
drainage ditch. Leachate and contaminated groundwater (on-site and
off-site in the southern plume) will be extracted, treated and either
disposed of at the POTW, discharged to the Cocheco River, or recharged
back to the wetlands.
. The remedial actions, as proposed, will be protective of human health
and the environment. Capping of the source area will eliminate
further groundwater contamination resulting from soil leaching.
Toxicity will be reduced through groundwater t~eatment until
contaminant concentrations are protective of human health. Treatment
will also retard the migration of the contaminated plume and halt
further contamination of the aquifer. A long-term monitoring program
will ensure the remedy remains protective of human health and the.
environment. The final groundwater cleanup levels will be determined
as the result of a risk assessment perfo~ed on residual groundwater
contamination after all interim cleanup levels have been met. Unless
the resultant cumulative risk is within the 10-" to 10-6 incremental
risk range and the cumulative hazard index for similar target
endpoints is below the specified level of concern, remedial actions
shall continue, until protective levels are attained. Finally,
implementation of the selected remedy will not pose unacceptable
short-term risks or cross-media impacts since the technologies are
proven and will be field tested to reduce operational risks, and
special engineering' precautions will be used to minimize potential for
air releases of contaminants.
B.
~h. selected Remedy Attains ARARs
This remedy
appropriate
Substantive
those to be
others:
will meet or attain all applicable or relevant and
federal and state requirements that apply to the Site.
portions of environmental laws identified as ARARs and
considered for the selected remedial action include, among
Chemical SDecific
Safe Drinking Water Act - Maximum Contaminant Levels (MCLs)
Resource Conservation and Recovery Act, Groundwater Protection MCLs
. National Ambient Air Quality Standards (NAAQS)
Clean Wa~~r Act Arobient Water Quality Criteria (AWQC's)
New Hampshire Surface Water Quality Standards
New Hampshire Drinking Water Standards
New Hampshire Ambient Air Quality Standards
New Hampshire Toxic. Air Pollutant Regulations
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ROD DECISION SUMKARY
DOVER KUNICIPAL LANDFILL SITE
for the source control and management of migration components of the
remedial actiOn: these studies will not delay any design or
implementation activities. These studies and any proposal to alter
the remedy based on the findings of these studies must be completed
and submitted within fifteen (15) months of commencement of remedial
desiqn activities. In accordance with the NCP, any proposal to alter
. the remedy based on new data must evaluate the chosen remedy against
the proposed remedy on the nine criteria set out at 40 CFR
300.430(e) (9) (iii).
Since hazardous substances, pollutants or contaminants will remain at
the Site, EPA will review the site at least once every five years
after the initiation of remedial action at the Site to assure that the
remedial action continues to protect human health and the environment.
EPA will also evaluate risk posed by the Site at the completion of the
remedial action.
XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Dover Municipal
Landfill Site is consistent with CERCLAand, 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 thes~atutory preference for treatment which
permanently and sfgnificantly reduces the mobility, toxicity or volume
of hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternate treatment technologies or resource
recovery technologies to the maximum extent practicable.
A.
The Selected Remedy i. Protective of Human Health and the
Environment
The remedy at this Site will permanently reduce the risks posed to
human health and the environment by eliminating, reducing or
controlling exposures to human anQ environmental receptors through
removal, treatment, engineering controls, and institutional controls,
more specifically, the capping of the Landfill, the limited excavation
of contaminated sediments, the collection and treatment of
contaminated groundwater and leachate in the Landfill and at the
perimeter ot the waste management area and the extraction and
treatment of off-site contaminated groundwater. The wastes deposited
at the Landfill will remain in place. Migration of contaminants to
surface water, soils, sediments, and groundwater will be b~ocked and
direct contact with contaminants prevented, thus effectively reducing
risks. The pathway for the volatilization of contaminants into the
air will be eliminated due to the removal of the perimeter drainage
ditch as an avenue for contaminant transport. In addition, the
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. ROD DBCXSXOB SUMMARY
DOVER MUNXCXPAL LABDPILL SXTB
1.
Chemical SDecific
a.
Federal and state Drinkina Water standards
It has been determined by the EPA that the groundwater in the upper
aquifer beyond the point of compliance could be a drinking water
source were it not contaminated by substances originating from the
Dover Landfill. The state of New Hampshire has not yet classified
groundwater in the area: however, using the Federal quidelines and
classification system, the groundwater adjacent to the site would be
classified as a IIB potential drinking water. While Maximum
. contaminant Levels (MCLs) and Maximum contaminant Level Goals (MCLGs)
promulgated under the Safe Drinking Water Act are not applicable to '
groundwater, they are relevant and appropriate to groundwater cleanup
because the groundwater may be used as a drinking water source. In
addition, the NCP requires that usable groundwaters be restored to
their beneficial uses whenever practicable. ~ 40 CFR 300.430(a)
(iii)(F). ...
i'
i
In accordance with RCRA, cleanup levels for arsenic in the groundwater
will be set at 50 ug/l or background, whichever is higher. (The SDWA
MCL fo~.arsenic has been deemed relevant but not appropriate and
therefore not an ARAR because naturally occurring levels may be higher
than the SDWA MCL.) Prior to or during remedial design, EPA and the
state will determine the background level of arsenic at this site to
establish the interim cleanup level.
New Hampshire's Protection of Groundwater requlations (Ws 410) do not
establish groundwater quality standards, but do establish groundwater
criteria. Included in this criteria is the requirement that no person
shall cause the groundwater to contain a substance at a level that the,
state determines may be potentially harmful to human health or to the
environment., Because New Hampshire's requlations do not contain a
standard level of control as required by I 121(d) (2) (A) (ii) of CERCLA,
they will not be an ARAR. They are, however, to be considered (TBCs)
and. will be met'.
This remedy will attain these ARARs as well as those identified in the
tables of Appendix E" and 'will comply with those requlations which
have been identified as TBCs by meeting the groundwater cleanup levels
at the site through the groundwater treatment systems and natural
attenuation. Capping of the Landfill will decrease infiltration of
precipitation through the Landfill, thus reducing the volume of
leachate generated. Treating the leachate and contaminated
groundwaters will reduce levels of contamination at the site to the
interim cleanup levels identified in this ROD. Treated groundwater
-------
ROD DBCISION SUMMARY
DOVER KUHICIPAL LAHDPILL SITB
Location S~ecific
Clean Water Act (CWA) (Protection of Waters & Wetlands)
Executive Order 11990 (Protection of Wetlands)
Executive Order 11988 (Floodplains Restrictions)
40 CFR Part 6 Appendix A .
RCRAGeneral Facility Standards for Floodplains/Seismic Areas
Fish and Wildlife Coordination Act
New Hampshire Wetlands Requlations. "
New Hampshire Hazardous Waste Regulations (Facility siting standards)
t .~.
Action S~ecific
Resource Conservation and Recovery Act (RCRA)
HSRA (Land Disposal Restrictions of RCRA)
Clean Air Act (NAAQS and NESHAP)
DOT Rules for Transportation of Hazardous Materials
CWA (NPDES and Pretreatment Standards)
New Hampshire Hazardous Waste Rules
New Hampshire Air.Requlations for VOCs
New Hampshire Standards for Pretreatment of Wastes Discharged
to a POTW "
New Hampshire Rules for Transportation of Hazardous Materials
New Hampshire Requlations for Terrain Alteration
New Hampshire Requlations for Fugitive Dust Control
To Be Considered
New Hampshire Protection of Groundwater New Hampshire Groundwater
QUality Criteria
New Hampshire Groundwater Discharge Criteria
New Hampshire Wellhead Protection Program
EPA Risk Reference Doses
EPA Carcinogen" Assessment Group Potency Factors
NOAA Technical Memorandum NOSDMAS2
Federal Groundwater Protection strategy' Classification Guidelines
Tables 9, 10, 11 and 12, in Appendix B of this ROD, list all ARARs
identified for the site and whether they are applicable, relevant and
appropriate or to be considered. Within each. table is also presented
a brief synopsis of the requirements and the action to be taken to
meet them. Section 2 of the FS, Tables 2-8 through 2-11 lists all
ARARs identified for the site for all the alternatives.
-------
ROD DECISION SUKMARY
DOVER MUNICIPAL LANDPILL SITE
J
groundwater extraction system
active ma~~:e-~~~ ~~n cJeanup
remediation ~bjectives of the
under the, wetland.
In the short term, ccnstruction will be conducted to avoid or minimize
the damage to flora and fauna within the wetland. Additionally, after
construction is completed, restoration of the wetlands will occur in
two phases. The first phase, implemented at the time of completion of
the construction, will consist of restoring the original topography
and establishing shallow rooting vegetation. The second phase,
initiated at the completion of the remedy, consists of encouraging the
original wetland species to reestablish themselves naturally.
in the wetland is necessary because
of the plume is necessary to meet the
Site and the contaminant plume lies
After reviewing the Federal Emergency Management Agency, Floodplain
Insurance Rate Maps for the City of Dover, EPA has determined that a
portion of the site is located in a 100-year floodplain. Executive
Order 11988 (Floodplain Management) is therefore an ARAR for the Site.
These requlations govern construction activities which have a negative
impact on a floodplain.
The portion of the Site that lies within the 100-year floodplain is
the lower portion of the drainage swale, converging with the Cocheco
River. The limited excavation of contaminated sediments in this area
is necessary to meet, the remedial objectives, and has little or no
adverse 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. This
Appendix sets forth principles and procedures to govern work in
wetlands and floodplains so as to minimize the adverse impacts on
these valuable natural resources. These orders, as well as EPA's
policy, will be implemented in the construction and maintenance of the
remedy.
In accordance with 40 CFR Part 6, ,Appendix A, the EPA has provided an
opportunity f~r public comment on the work to be undertaken in the '
wetlands and floodplain by issuing a Proposed Plan for remedial action
at this Site, holding a public hearing and receiving pubic comments
for 60 days prior to this decision. In addition, a Statement of
Findings which determine that there are no practicable alternatives to
these remedial actions in the wetlands and floodplain is included in
Appendix F.
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ROD DECISION SUKHARY
DOVER MDHICIPAL LANDPILL SITE
will also meet federal standards, state criteria for drinking water,
. and the discharge requirements to the Cocheco River and/or of the
POTW. Where natural attenuation is employed, federal and state
standards will be met within the time frame specified.
b.
Federal Clean Air Act and New HamDshire Air Pollution
Reaulations
Federal Primary and Secondary National Ambient Air Quality Standards
(NAAQS) exist for emissions of sulfur oxides, carbon monoxide, ozone,
nitrogen oxides and 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
and, while they are based on the exposure of a select population and
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 specific sections set forth in the tables in
Appendix E, 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.
These federal and state air standards will guide mitigation measures
designed to control the release of particulate matter during the
recontouring and excavation at the Site. In addition, the federal and
state regulations which set standards for VOC emissions from certain
industries will be relevant and appropriate to set limits on the
emissions from any treatment system used at the Site. Finally, the
state fugitive dust control regulations will guide recontouring
activities so that dust is kept to a minimum. In each case the best
demonstrated technology will be employed to meet the federal and state
requirements.
2.
~
a.
Federal and State Wetland and FloodDlain Protection
The Clean Water Act, along with Executive Order 11990 (Protection of
Wetlands) and state wetland protection standards are applicable to
that portion of the remedy constructed in or affecting the wetlands
surrounding the Site. These rules prohibit activity adversely
affecting a wetland if there exists a practicable alternative which is
less detrimental. Constructing the management of migration
-------
ROD DBCISION stJMJIARy
, DOVER MUNICIPAL LANDPILL SITB
the remedy affords overall effectiveness proportional to its costs.
Once EPA i,np."ti,f~ed alternatives that were protective of human health
and the environment and, that either attain, or, as appropriate, waive
ARARs, EPA evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria--long term effectiveness and
permanence: reduction in toxicity, mobility, and volume through
treatment: and short term effectiveness. The relationship of the
overall effectiveness of these remedial alternative were determined to
be proportional to their costs. '
A summary of the costs associated with each of the source control
remedies are presented below. All costs are presented in net present
costs.
COST COMPARISON OP SOURCB CONTROL ALTERNATIVES
I
No Action'
Limited Action
RecontouriMulti-
~yer cap/ Slurry
,Wall/ Groundwater
"Treatment/ .
Discharge to
.Cocheco'River/
Sediments Cover
SC-5A Recontour/Multi-
Layer Cap/ Slurry
Wall/ Groundwater
Treatment/
Discharge to POTW/
Sediments Cover
SC-1
SC-2
sc-s
SC-7
Recontour/Multi-
Layer Cap/
Interceptor/
Diversion Trench/
Groundwater
Treat!!\ent/
Discharge to
Cocheco'River/
Sediments
Excavation
$
capital
Costs
o
44,400
31,266,600
31,334,600
20,014,800
o & M
169,000
177,600
221,400
205,000
239,300
Present
Worth
1,593,400
1,718-,300
33,353,600
33,267,100
22,270,600
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ROD DBCISIOB SUJlNARY
DOVER MUNICIPAL LANDPILL SITB
3.
Action SDecific
a.
State and Federal Hazardous Waste Reaulations
RCRA regulations and the current State of New Hampshire hazardous
waste regulations are relevant and appropriate to the source control
and management of migration portions of the remedy. In those limited
instances these regulations conflict, the more stringent regulation
will be ~ollowed.
Prior to January 1991, the State, by promulgating hazardous waste
regulations which were as stringent as, or more stringent than, RCRA
regulations, had been authorized by EPA to administer and enforce the
hazardous waste program in New Hampshire. However, New Hampshire has
promulgated an entirely new set of regulations this year. Some of
those regulations are less stringent than RCRA regulations. This new
state program i~ still undergoing revisions and has yet to be approved
by EPA. As a result, both federal and state hazardous waste
regulations existing at the signing of this ROD must be consulted to
employ the more stringent requirements. .
Since RCRA-type hazardous wastes were disposed of in the Landfill
during its operation and it is Suspected that full barrels of RCRA-
tyPe substances were buried and may still be leaching inside the
Landfill, the cap design and construction for this unit will meet both
RCRA and New Hampshire hazardous waste standards. In addition, during
the recontouring of the Landfill, hot spots may be encountered. The
substances in those hot spots must be removed and treated,
transported, and disposed of in accordance with RCRA and New Hampshire
requirements. Sludge generated by the groundwater treatment unites),
if determined to be RCRA-type waste, must also be removed from the
Site, transported, and disposed of in accordance with RCRA and the
state requirements.
The land disposal restrictions of Hazardous and Solid Waste Amendments
of RCRA will apply to those RCRA-type hazardous substances removed
from th. Site, including those hot spot substances and the treatment
unit sludges. Land disposal restrictions will not apply to the
mov.mentof sediments from the swale to the area of the Landfill to be
capped because, among. other reasons, this movement does not constitute
placement for purposes o~ the land disposal restrictions. The
contaminants in the swale have been caused by and are contiguous to
the Landfill, and their movement back to the Landfill constitutes
consolidation within the unit.
C.
The Selected Remedial Action i. Cost-Bffective
In the Agency's jUdgment, the selected remedy, is cost effective:
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ROD DECISION SUKKARY
DOVER MUHYCIPAL LANDFILL SITB
1 The total presented does not include $928,400 included in the FS for"
, long-term groundw~ter, surface water and sediment monitoring over 30
years. Long-term monitoring costs for these media are included under
the costs for management of migration portion of the selected remedy.
A summary of the costs associated with each of the management of
migration remedies are presented below. All costs are presented in
net present costs.
COST COMPARISON OF KAHAGBKBHT OF MIGRATION ALTBRNATIVES
MH-1 No Action
Capital O&M Costs Present
Costs ($/Yr) Worth
$ 0 142,800 1,346,500
9,400 176,500 1,673,600
1,452,200 78,800 *
2,828,700
MM-2 Limited Action
MM-J Groundwater Interceptor
Trench/Recharge Trench/
Groundwater Treatment
. MM-4 Groundwater Extraction
Wells and Treatment
System .
. Present worth costs for MM-J and MM-4 include an additional
$892,147 for long-term groundwater monitoring (30 years) that is not
accounted for in columns headed "Capital Costs" and "0 & M Costs".
1,503,700
394,200
*
4,818,000
Three of 'the management of migration alternatives attain ARARs, MM-2,
MM-3 and MM-4. Comparing these alternatives, EPA's selected remedy,
portions of MM-2 and MM-4, combines the most cost-effective remedial
alternative components while also providing sufficient protection to
human health and the environment. This portion of the remedy provides
a degree of protectiveness proportionate to its costs." "
The least expensive alternative, MM-1, no action, would meet ARARs in
the long term through attainment of groundwater cleanup levels by
natural attenuation processes. It does not provide protection of
public health and the environment in the short term because use of
the contaminated groundwater would not be restricted and the cleanup
time frame is not reasonable. Alternative MM-2, limited action,
allows for natural attenuation processes ,to attain groundwater cleanup
levels and includes institutional controls to prevent short term usage
of groundwater. "
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ROD DECISION BUKKARY
DOVER MUNICIPAL LANDFILL SITB
SC-7A Recontour/Multi-
Layer Cap/
Interceptor/
Diversion Trench/
Groundwater
Treatment/
Discharge to
Cocheco River/
Sediments
. Excavation .
Two of the above alternatives are protective and attain ARARs: SC-5/5A
and SC-7/7A. Comparing these alternatives, EPA's selected remedy, SC-
7/7A, combines the most cost-effective remedial alternative components
that were evaluated. The remedy provides a degree of protectiveness
proportionate to its costs. Alternative SC-5/5A is 50 percent more
costly than SC-7/7A without providing a commensurate increase in
protectiveness. Alternative SC-7/7A, like SC-5/5A, involves the
construction of a cap over the landfill and the installation of a
groundwater/leachate collection system, but without threatening the
integrity of the marine clay layer. The less expensive alternatives,
SC-1 (no-action) and SC-2 (limited action), did not meet all ARARs
nor were sUfficiently protective of human health and the environment.
A summary of the costs for each of the elements of the selected source
control remedy is presented below. All costs are net present worth.
20,174,700
211,862
22,171,900
Total Costs of Selected Source control Remedy
C~mDonent of Remedv
Present Worth (8)
MUlti-layer Cap
Groundwater/Leachate Collection System
14,079,100
1,347,600
Groundwater Treatment System (PACT"I)
Limited Sediment Excavation
1,692,700
7,900
Miscellaneous.
TOTAL 1
4.215.000
21,342,300
. Miscellaneous includes the following: facilities, a drum removal and
disposal contingency should hot spots or drums be encountered during
recontouring activities, contractor allowances, contingency allowances
and general administration.
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ROD DBCISION SUMMARY
'DOVER MUNICIPAL LANDFILL SITB
TOTAL COSTS OF SBLECTBD KANAGBMBNT OF MIGRATION REDDY
PORTION OF REMEDY
PRESBNT WORTH COST (S)
I.
capital Costs
a. Fencing, Gates, Signs
b. Groundwater Extraction Wells
c. Groundwater Treatment System
(PACT~ System, pipe line and
d. Miscellaneous.
discharge)
63,300
9,000
671,500
379,200
'~
II.
Annual operation and Maintenance
(@ $157,680 per year, for 10 years)
III. Long-term Groundwater Monitoring
(@ $76,600) per year for 30 years)
968,800
721. 600
TOTAL
2,813,400
. Miscellaneous includes the following: miscellaneous facilities
(site trailers, etc.), institutional control administration costs,
contractor allowances, engineering, contingency allowances, and
qeneral administration.
The costs, taken from alternatives SC-2 and MM-2 in the FS, for the
fencing, gates and 'signs were summed to obtain the costs presented in
the above table. The long-term monitoring costs associated with the
selected remedy were calculated by EPA using the long-term monitoring
of groundwater, surface water and sediments as shown in the FS for SC-
2 and MM-2. specifically long-term monitoring costs include the costs
for quarterly sampling of 12 wells (as estimated by SC-2 in the FS)
for VOCs, metals and tetrahydrofuran as well as the associated labor,
data validation, report writing and administration costs. The actual
number of wells sampled, which may be greater than twelve, and the
location of these wells will be determined during design.
Note that at'the request of' EPA, HMM' Associates, the FS contractor,
submitted an analysis of the costs for the extraction and treatment of
a) the eastern plume and b) the southern plume. The costs from this
analysis, available in the Administrative Record, have been used to
compile the cost table above. A detailed accounting of costs for each
source control and management of migration alternative is contained in
section 4 ot the FS.
,While analyzed separately in this. document, the source control and
management of migration portions of this remedy are interdependent.
Source control measures are necessary for, among other things, the
prevention of future contaminant migration into the eastern and
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ROD DBOI8IOH 8UMMARY
DOVBR MmJIOIPAL LAlmPILL 8I'1'B
Both MM-3 and MM-4 take active measures to cleanup groundwater and to
prevent short term and long term impacts of the contaminant plume on
the Bellamy Reservoir. Alternative MM-3 involves a passive collection
that intercepts and treats contaminated groundwater. Alternative MM-4
actively extracts and treats contaminated groundwater from the
aquifer.
Alternative MM-4, which is 187 percent more costly than MM-2, and 70
percent more costly than MM-3, is expected to attain groundwater
cleanup levels in a somewhat shorter time frame than MM-2 and MM-3,
due to active extraction and treatment. The time frames to attain
groundwater cleanup levels in the eastern plume are approximately 5 to
7 years for MM-2, and 3-4 years for MM-~ and MM-4. Since the time
frames to achieve the cleanup levels are not significantly different,.
and because during this time frame the eastern plume contamination is
not expected to affect a current drinking water receptor, the EPA
selection of natural attenuation (MM-2) for the eastern plume is most
cost effective while providing adequate protection of human health and
the environment. .
The time frames to attain groundwater cleanup levels in the southern
plume are approximately 10 to 24 years for MM-2, and less than the 10
to 24 years for MM-3 and MM-4. The FS simulations of the time frames
to achieve MCLs for the MM-4 alternative did not take into account the
increased hydraulic gradients and groundwater velocities resulting
from the greater drawdown created by the extraction wells. The
increased groundwater velocities near the extraction wells may result
in a remediation time frame somewhat less than that for alternative
MM-3. The actual effect of the extraction wells under MM-4 on
increasing the groundwater velocities will be a function of the pump
rate and aquifer drawdown created by the extraction wells.
"-
In addition to shortening the cleanup time, MM-4 provides immediate
protection to the Bellamy Reservoir from the southern contaminant
plume. The plume has moved to within 900 feet of the reservoir and,
if left to naturally attenuate, contaminants could reach the class A
waters of the reservoir. Because.of the levels of current groundwater
contamination .in the southern plume, the time frame for allowing --
natural attenuation to clean up this plume, and the threat to this
important drinking water resource, the costs associated with employing
an extraction well/treatment system to remediate the southern plume
are justified.
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.
-------
ROD DECISION SUMMARY
. DOVER MUNICIPAL LANDFILL SITE
treatment of the contaminants in the groundwater. Natural attenuation
process;~, ~=~i~: in the groundwater, may eventually result in the
attainment of groundwater cleanup levels, but this would take many
decades.
Alternative MM-2 and selected elements of MM-4 were chosen as the
management of migration portion of the remedy because of the combined
long-term effectiveness and permanence and ability to reduce
toxicity, mobility and volume of contaminants through capture and
treatment was the most efficient of all alternatives in light of
implementability and cost concerns. The principal elements of the
remedy consist of extracting groundwater in the southern plume, which
has migrated from the Landfill toward the Bellamy Reservoir, and
. treating the groundwater through the use of a PACTTM process or an air
stripper, prior to discharging it to the Cocheco River and/or .
recharging it back to the wetlands to off-set dewatering. The PACTTM
process and the air stripper are proven techniques which provide
permanent solutions for contaminated groundwater and have been used
successfully at other cleanup sites. Groundwater in the eastern plume
is expected to attain groundwater cleanup levels through natural
attenuation in a reasonable time frame (5 to 1 years) after
implementation of the source control remedy; unlike the southern
plume, the eastern plume does not threaten a current drinking water
source during the period natural attenuation is to attain groundwater
cleanup levels. .
Alternative MM-3 is similar to MM-4 in long-term effectiveness and
permanence and its ability to reduce toxicity, mobility and volume of
contaminants through capture and treatment and also in
implementability and costs. However, when short term impacts are
considered, MM-4 provides greater protection ~o the wetlands during
installation. In addition, because MM-4 actively extracts the
contaminated groundwater, where MM-3 relies on the natural flow of
groundwa~er, cleanup time frames are expected to be faster for MM-4.
Alternative MM-l is similar to MM-2 in long-term effectiveness,
permanence and cost. MM-2 is selected because it provides greater
protection of public health and the environment through institutional
controls. These controls are especially important to prevent ground
water consumption in the short term.
The Selecte4 Rame4y Satisfies the Preference for Treatment
Which Permanently an4 significantly re4uce. the Toxicity,
MObility or Volume of the Bazar4ou. Substances as .
Principal Blament
The principal element of the selected source control portion of the
remedy is the containment of wastes in the Landfill. The principal
B.
-------
ROD DECISION SUKNARY
DOVER MUNICIPAL LANDPILL SITE
southern plumes and the management of migration measures are needed to
protect the Bellamy Reservoir from the existing southern plume
contaminants and any expansion of that plume during the design and
implementation of this remedy.
TOTAL ESTIMATED COST:
$24,155,700
D.
~he Selected Remedy Utili.e. Permanent SOlution. and
Alternative ~reatment or Re.ource Recovery ~echnoloqie. 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. This determination
was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of: 1)
long-term effectiveness and permanence; 2) reduction of toxicity,
mobility or volume through treatment; 3) short-term effectiveness;
4)implementability; and 5) cost. The balancing test emDhasized long-
term effectiveness and permanence and the reduction of toxicity,
mObility and volume through treatment; and considered the preference
for treatment as a principal element, the bias against off-site land
disposal of untreated waste, and community and state acceptance. The
selected remedy provides the best balance of trade-offs among the
alternatives.' >
The selected source control alternative SC-7/7A, is similar to SC-S/SA
in its long-term effectiveness, permanence, short term effectiveness,
and reduction of toxicity, mobility and volume of contaminants through
treatment. The selected alternative is far superior to SC-S/SA in the
areas of implementability and cost. Alternative SC-S/SA costs 50
percent more than SC-7/7A without providing a corresponding increase
in protection. Alternative SC-S/SA also requires the securing .of the
slurry wall into the marine clay layer which separates the upper
contaminated aquifer from the lower drinking water aquifer. This
would be a difficult procedure and could affect the integrity of the
clay layer. SC-7/7A provides for an interceptor trench/extraction
well system which will not affect the clay layer. In addition, the
limited sediment excavation of SC-7/7A is easier and quicker to
implement, less expensive, and provides a more permanent remedy than
the swale cover examined in SC-S/SA.
Alternatives SC-1 and SC-2 are far less protective than both SC-S/SA
and SC-7/7A for the long-term. Both alternatives SC-l and SC-2 do not
prevent the migration of contaminants into the groundwater nor do they
provide for the reduction of mObility, toxicity or volume through
-------
ROD DECISION SUMMARY
DOVER MUNICIPAL LAHDPILL SITE
4
In the Proposed Plan the estimated total cost for the preferred remedy
was $25.9 million. The estimated total cost of the remedy in this
Record of Decision is $24.2 million. The reduction in costs is in
part based on the correction of accounting and overestimated long-term
monitoring costs. In combining alternatives to obtain the selected
remedy long-term monitoring costs were double counted. Long-term
monitoring costs associated with SC-7/7A and MM-4 have been deducted
because they are also included in the costs associated with MM-2. In
addition, MM-2 included costs for full HSL analysis of groundwater,
which has been deemed inappropriate by the EPA because there is no
indication that pesticides, poly-chlorinated biphenyls (PCBs) or base-
neutral and acid extractable organic compounds (BNAs) are contaminants
of concern at this Site.
The SDWA MCL for arsenic in groundwater has been determined to be
relevant but not appropriate to this Site and therefore not an ARAR as
a result of the possibility of naturally occurring background levels.
which may exceed,the SDWA MCL. The RCRA groundwater cleanup level for
arsenic remains both relevant and appropriate because it sets cleanup
at 50 ug/l, or background, whichever is higher.
Other minor changes in ARARs may be found in the tables in Appendix E
of this ROD Decision Summary.
XIII. STATB ROLE
The New Hampshire Department of Environmental Services has reviewed
the various alternatives and has indicated its support for portions of
the selected remedy. The State has also reviewed the Remedial
Investigation, Risk Assessment and Feasibility Study to determine if
the selected remedy is.in compliance with applicable or relevant and
appropriate State Environmental laws and requlations. The New
Hampshire Department of Environmental Services concurs with the source
control and eastern plume management of migration portions of the
selected remedy for the Dover Municipal Landfill Site and has reserved
a concurrence decision on the southern plume management of migration
. portion of the selected remedy until pre-design studies have been
completed. A copy of the declaration of concurrence is attached as
Appendix D.
-------
ROD DBCISION SUKNARY
OOVER JItDlrCIPAL LAlmPILL SITE
element of the selected management of migration portion of the remedy.
is groundwater extraction and treatment. These elements address the
primary threat at the Site, contamination of the groundwater with
VOCs, tetrahydrofuran and metals (arsenic). The selected remedy
satisfies the statutory preference for treatment as a principal
element by minimizing leachate from the Landfill, collecting and
treating leachate and the contaminated groundwater migrating from the
Landfill, and actively extracting and treating the contaminated.
groundwater posing a potential threat to the nearby drinking water
supply reservoir. Treatment is not used for the cleanup of the
Landfill because treatment of this large volume of heterogeneous waste
is not practical or cost-effective in comparison with capping the
waste in place. .
XII. DOCUMENTATION OP NO SIGNIPICANT CHANGES
No significant changes from the Proposed Plan have been made to the
selected remedies as detailed in the Record of Decision. Minor
changes from the Proposed Plan to the Record of Decision include
incorporating an arsenic cleanup level for sediments which is
protective of the environment rather than simply protective of human
health. In addition, accounting errors have been corrected and long-
term monitoring full HSL analysis was deemed inappropriate. These
corrections reduced the cost of the selected remedy by approximately
$1.7 million. Minor changes also include some changes in the ARAR
tables to better reflect the actions to be taken at the Site to meet
these ARARs and some alterations in the status of the ARARs to
accommodate site specific features. Also, EPA has determined that the
SDWA MCL for arsenic in the groundwater is not appropriate for this
Site and therefore not an ARAR. The RCRA MCL for arsenic will control
the setting of this cleanup level.
The selected remedy provides for the limited excavation of
contaminated sediments in the drainage swale for the protection of the
environment, specifically due to the presence of arsenic in the
sediments. An arsenic cleanup level in sediment has been set at 50
ppm, based on Site exceedances of the NOAA Effects Range Low of 33
ppm., and taking into consideration the Effects Range Median of. 85 ppm
and site-specific data (TOC and grain size). This level is considered
protective for fish, waterfowl and other biota inhabiting the Cocheco
River. The proposed plan stated a cleanup level for arsenic in
sediments for the protection of human health. Since the risks via
ingestion and dermal contact with these sediments are within EPA's
acceptable risk standards, protection for human health was not
justified.
-------
'-
~
, I
'7 ,~
SCALE IN FEET
BASE MAP ISAPORnoN OP11IB u.s.G.S. DOVER WES'tHH QUADRANaUi
7~ MJNt1IE SERIES -1956 (pHaro REVISED 1973) .
FIGURE 1
LOCATION OF DOVER LANDFILL SITE
hID
. !
. j
. -., .
. ". . .
. ..-_.._~.
.-. -- "',
1-3
-------
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
FIGURE 11
FIGURE 12
FIGURE 13
FIGURE 14
FIGURE 15
"
,.
Appendix A
FIGURES
LOCUS HAP
SAMPLE LOCATION HAP
WETLANDS AND FLOODPLAIN DELINEATION
TOTAL VOC & DNA CONCENTRATIONS - UPPER AQUIFER
TOTAL VOC & BNA CONCENTRATIONS - LOWER AQUIFER
ARSENIC CONCENTRATIONS - UPPER AQUIFER
ARSENIC CONCENTRATIONS - LOWER AQUIFER
ESTIMATED EXTENT OF DETECTABLE TOTAL VOCS IN UPPER AQUIFER
WATER ELEVATION CONTOUR MAP
RESIDENTIAL WELL CONTAMINATION
TYPICAL MULTI-LAYER CAP CROSS SECTION
PROPOSED GROUNDWATER/LEACHATE TREATMENT SCHEMATIC
CONCEPTUAL INTERCEPTOR TRENCH LOCATION - MH-3
CONCEPTUAL EXTRACTION WELL LOCATION - MH-4
CONCEPTUAL GROUNDWATER DEPRESSION
-------
FIGURE 3 . nON
PLAIN DEI.INEIt
AND FLOOD
-------
-......,..
i."
"
.0
.,0
o
j
1
)'
9
:::1 :'
.... L
:....
. .....
1.,. .
+~::~
'''I' .
.. .
.-.
.-
.r
200
400
.
800
...
,
hrn"
-.----.- .' FIGURE 2
WE'ILANDS mmy SAMPUNO LOC,A'"ONS FOR SEDIMENT AND SURFACE WATER
... .. ..._... -. .",. ...
/
j
-------
"
o
:;;0
(,)
-
z
~
J
/ ~.
...
..
AU.APRL 1990 Rm OCT AND NOV 89 VOC & BN~ RESlUS ARE
FROM HUM SAMPUNO EPISODES OF GROUNDWATER AND
WE11AND SEDIMENTS. AlL OTHER VCC & BNA REsu..TS ARE
FROM tHE 1988 REMEDIAl. INVeSTIGATION VOlUME IV BY
WEHRAN ENOINEERSAND SCIENTISTS.
VOC. UNITS PARTS PER IIIWON (PPB)
BNA. UNITS PARTS PER Ł;IWON (PPB) "I:
r;;;j SHADED WELL NUMBERS INIIICATE EXCEE~E OF MCl's.
\'
...
.. .....
", .
'H'
...,
...,
,."
6
,
.
,
.
.
~...
. . . ,"".
...,
. ...
.'
.,'-'...,
. ... .
:. ....'
'.,
'IE:
BASE MAP IS ADOPTED FROM VOlUME... OF tHE
REMEDIAL INVEST1OATION WRITTEN BY WEHRAN
INEERS AND SCIENTISTS.
.
"'.
NL
voca
II
- II
SCALE IN FEET
,
.
f'
200
~oo
I
.800
~..,
. -
/'
~)
hm
FIGURE 5
-------
..
0'
hU
~ i ,1=
-18 S
AU.APRL 1990 AND OCT ANDNOV 89 VOC & BNA RES\A.TS ARE FROM HMM
SAMPlING EPISODES OF GROUNDWATER AND WE11.AND SEDIMENTS. ALL
OTHER voc a BNA RESU.TS ARE FROM THE 1988 REMEDI~ INVESTIGATION
Ya.UME IV BY WEHRAN ENGf,lEERS AND SCIENTISTS. 0
voc. UNITS PARTS PER BIWON (PPB) 0
BNA . UNITS PARTS PER BilliON IPPBI
8HADEO WElL NUMBERS INDICATE EJtceEDANCE Of MCl'l.
RESIOENTW. WELL lOCATIONS (ASTERISK INDICATeS THAT 1HE WELL
IS STU" USE)
LOCATION WHERE SURFACE WATER SAMPlE WAS TAKEN FOR AIR
QUAIJTY S1UDES.
~
8AW-t
$c.t:
1
I. -. ~
o~ .
...
~ .-,..
.. ....
1.-..
~'SI
... . voc ND 1'=
-II 1=
OIN"
..- voo I ei
...
o. .
~..
.I."I~'. ...". .........
."'01 ,...e....... 1.0('.'0-
SCALE IN fEET
200
400
I
800
. .
~-~I
FIGURE 4
TOTALI voc AND DNA CONCENTRA -nONS I
. OF THf' "ER AQUIFER
-------
r
'.
}-.
..
... .
:"'"
"' .
,.. "
....
~":~~l
.. -II
..
~
ARSENIC UNITS ARE PARTS PER "WON (PPM)
SHI.DED BOX I~ :lICATES .EXCEEDANCE OF ~'CL '8
Of '!.OS PPU FR 1M THE NOVEMBER 19i!9 S~MPLING
EPnODE.
~..
:~~~
.-
.. ..
OlIO
",.
6.
.
:
"" ,-...,
" (:,.',;':.. . "
.. " :.:~, '.'''.
.' \. :t" ;,.- '"...'''
".. :
-'..
6'.""....,
,
.
"
-
....
...
....
, ..,
"
,"'.",
, .
...' I
:. "..
",
,':&.t .
r:. : .
i.:')...
,,!. ,'.
! '..'0
.. ~:. . ,",t ..
_.~.
I
800
. .
FIGURE 7 .
ARSENIC CONCENTRA110NS FROM '11m LOWER AQUIFER
o
him
:'.,( I'. Ult
\ I J-\.
. OR\G\NAl
-------
--
... ~~
0".-"
1
I ..-
M'
~
It ",... .
~. UCP 1\
I..I.-!:!!!-l!!,.. II ~ ------.!! ~!,-:-.
. 'W...
... I
I
..
".. -
. . -,..
.....
t,.,
AU.APRIL 1190 Nm OCT AND NOV 89 ARSENIC RESl1.T8 ARE
FR<* HW SAMPUNO EPISODES OF GROUNDWATER AND
WET\AND SEDIMENTS. AU. OTHER ARSENIC RESl1.TS ARE FROM
THE 11188 REMEDIAL INVESTIGATION VOLUME IV BY WEHRAN
ENGffEERS AND SCIENTISTS.
Sf . 10TAlARSENIC N WETLAND SEDIMENTS (PPM)
T . TOTAL ARSENIC N GROUNDWATER (PPM)
D . DISSOLVED ARSENIC IN GROUNDWATER (PPM)
ARSENIC UNITS ARE PARTS PER MilliON (PPM)
SHADED BOX NDICATES EXCEEDANCE OF MCl..
~ a: 0.05 PPM FROM APRIL 1990 AND NOVEMBER 1989
. . SAaFlINO EPIS0CE9 .
.-
, ..-
I::
D ..-
iil
....
......,." ...... ......"
.w... ...aca..,. Lot....-
.....
-.
,...
A.
,".
."'"
.
.
.
.
~...
,.~......,~'.
ft...
(
".
.. .
1'1
. ..'
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, ,'.
. ,',. Of NU
'0":'''': ''O. D IJC)
00. .
~II
IT 11.0 I
:.. .. .. . . .'
..
.
~~
TO DOVER .'
.
SCALE IN FEET
. .'. ...,..
,,',
A"'.
.
-e..
,.
.
.
...-'
NOTE:
THIS BASE MAP ISADOP'Im FROM VOlUME . OF
THE 1188 REMEDIAL INVES11OATIOH WRf1TEN BY
WEHRAH ENOINEERS AND 8CENTISTS
200
400
I
800
~I\
IT 8.10 I
...IU
..1117 I
. .,
hm
~;OOR QUALITY
.. , .,.. FIGURE 6 " .. . . . ... .
ARSENIC CON~110NS FROM 11IE UPPER AQUIFER AND WE'I1.AND SEDIMENTS I
o
I.
-------
-
'/-.~~
... .
:::1 :'
..., "
.....
. ...
:"!'..'\
."" .
. .
'. Of.-
-.'
NOTE:
WATER ElEVATIONSAAE RELATIVE 10 ..... .
'0119 BASe MAP IS ADOPTED -
'1188 REMEDIAL IN\/E FROM VOlUME. Of' THE
ENGINEERS AND sc:~~ WRf1'1EH BY WEHREN
",
.
'.-.
.'
..
"
f'
. ..
hm]
FIGURE 9 .'
WATER ~A110NCONTouR MAP
-------
..-.,
'" .
'f .
._- .
~ ... I.,..
. :::1:' t.... .. ~::~
J ~ ,.u ..
.....
. .".8.
/ i ... ...
. .
: ...
IV DtJIIIBl
. ...
200
400
.
800
.-.- -
. ,
--
--
--
- --
ES'I1MA TED EX1'ENI' C'
VOCCONTAMINA110N,
FIGURE 8
'TECTABLE TOT p
! UPPER AQUIFl
m
..
M-.'
..-,
... .
...
...
,.
-------
FIGURE 11
Typical Multi-layer Cap Cross Section
A.............................
.............................
..............................
.............................
..............................
.............................
..............................
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
..............................
.............................
..............................
.............................
..............................
.............................
..............................
.............................
..............................
- - . .. .. . . . .. . .. . .. e.. . . . . . . . .. . . .. . . .. ..
..............................
.............................
..............................
.............................
..............................
.............................
..............................
.............................
..............................
.............................
..............................
.............................
..............................
..............................
..............................
. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .
...... ............. ............
...... ............... ..... ....
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
........ ....... ...............
. . . . . . . . . . . . . . . . . . . . . . .". . . . . . . .
............ .......... .... ....
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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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[[[
[[[
[[[
[[[
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-------
~--.,...
1111.BXT6NTOpmNTAMlNA110N
. RBSJDBN'I1AL WEU.l.OCA11ONS
- DOVI!R LANDFnJ. .
n~
, .
i "'TGURE 10
EXPANDED BX1ENT OF CONTAMlNAn JLUMB AND RESmENTIAL wnL WA~R'QUALiTY
-------
J ~ ; ,:;' t~::'. - IIOTHNOPl.UMECONTOURSAREESTIMAT~BASEDON ~
. KNOWN TOTAL YOC CONCEtfTIV.TIONS.
.J - - - - ESTIIMTEO YOC CC'NCENTRATIDtI CONTOURS! 'SED ~
11189 DATA CG.LEC':EDBY tUN.
.. ' " ".,",~"" ,.... ".','" SW', SURFACE WATER S,\MPI.IIGPOINr WlTHTD1A' IOCOOHCENTRATIONS I
... '" """:..: v..', ":""!" TDTHELEFTBASEOONIII8INQ'.,gejDATAC1,lECTEOBYtUoIM. I
'... ~ .., "', ~'"'' -- I hi 184147'1 REPRESENTS TOTA..YOCc:oNC:= fTRATIONSA' ':iAM'llDmoMA I'
,. '.. . ... . Noen", -::.... ,II .. 47.fOOTDEF.PMOM1CRINGWEU,.BASEDOU. 99NfD.,gej
, ' '. , , ;. ,f ';.< '~~. .~ 'W' . DATAOOlLECTEDB'HMM. . I
", ..' " h' -;, ,~:';:::, ,,'i ,RW.7 RESIDENTIALWELLi-lOCAT!OH!;\REAPPRCIXI..TE . I
", .' " ' " ...., ~ ~? I . '\. ..' " "
I" '. ... .., ' ' ,n, ... ~~;..; rr:?;j: ": , 1!': ';~i"" ,: . hi" " :!,-: ,- . ~~,;, 181? ':: ''''o~';:~':l.~ '
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-------
...
""
~
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f
f
l
. Af...""
OnIundwater'l8ach81t
Inlluent
FIGURE 12
Proposed Groundwater/Leachate Treatment
General Process Diagram
.
I ~
I'
I'
I
i,
. .
0v8rft0w
Fha.. R
Pclyeleclrolyle .
SIonIge
SeI8ng
Tank
.......
.......
.......
Ellluent Discharge
to Coc:heco River
Contact. Aeration
Tank
Backw88h
& Supply
C8Ibon Rec:yde
Off-Slte
-------
8
F.L 185'
/\
EL. 147.0'
C
EL 154.5'
t
..
A'
: 151'
--r-
3,5'
144.0'
---------:..-=--:::.~-
----
----
.,,'" .,,'" .
." ~."
.." ." 3~
WC~ DRAINAGE SLOPE
5~
.
123.
El148.4
1 ---==::::--------
I --
--
I ---
I -~
I DRAINAGE SLOPE ~ /
I
I
I
I
I
I
I
I
..~
I
EL 131.5'
LEGEND
-870 FT
-870 FT
LENGTH - 240FT . 1 IN.
DEPTH - 5 FT . 0.21N.
- 25FT . 1 IN.
1112
hm
FIGURE 15
CONCEPTUAL GROUNDWATER DEPRESSION
-------
)
)
~
. .. 8'
.01.
. -"
. I..
4' "': .~.
.. ..
...
F'
,
/ ESTIMATED EX'rnNT OF DETECTABLE TOTAL
" ""4-VOC CONTAMINATION IN THE UPPER AQUIFER
--
-
-<.
hOO
. FIGURE 14
MM-4: CONCEPTUAL (OFF-SITE) GROUNDWATER EXTRACfION WELL
. LOCATION MAP
-------
TABLE 1
INDUSTRIAL WASTE SURVEY (1976-1977)
DOVER MUNICIPAL LANDFILL
Waste Material
Ouantitv/Year
Plastics
Urethane foam
. Paper
Cardboard
Varnish
Hydraulic oil
Synthetic plastic
Leather trimmings
Fiberboard
Wood'
Paint sludge
Cement sludge
. Paint filters
Plasterso1
Solvents
MEK
(Methyl Ethyl Ketone)
Triethanolamine
Isopropyl Alcohol
Diethylene glycol
Anhydrous butadiol
Urethane elastomer
, Cutting Oil
"Turco vitroclean"
"Turco 4432"
"Turco 4368"
"Witch Oil"
"Black passiwater"
Xylol toluol
Spent hydrochloric acid
Tin .
Emulsifier sludge
"Cellular crepee"
Latex cement sludge
Leather
Rubber
144 yd. & 57,200 lb.
1,860 gal.
3,468 yd3 & 30
1,548 yd3 & 18
132 gal.
300 gal.
3,120 yd3
4,160 yd3
1,872 yd3
5 yd.
169,380 gal.
3 yd3
16,432 ft2
2,860*
1,100 gal.
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
500 gal.
30 gal.
30 gal.
30 gat.
Unknown
Unknown
Unknown
540 gal.
104 yd3
52 yd3
416 yd3
130 yd3
180 yd3
360 yd3
Notes:
Waste Material
Ouantitv/Year
Oil 6,260 gal.
Ink 10 lb.
tons Lacquer 12 gal. **
tons Film developer 30 gal. **
Hypocle~ning agent 32.5 gal.**
Glacial acetic acid 2 gal.**
Color stabilizer 15 gal.**
Paper developer 6 gal.**
Kerosene 208 gal.
Wooden boxes 520 yd3
"Crepe trimming" 1,040 yd3
Polyurethane foam 104 yd3
"PVC box filter" 12 yd3
Fabricated plastic 1,560 yd3
Galvanized steel 78 yd3
Polyethylene 130,000 lb.
Fiberglass.
Sawdust
"Leather trim"
"Chrome leather shavings
"Chrome trim"
Tanning sludge
"Chem tan H"
Leather scraps
Degreaser
Toluene
Plating rinse
Plating filter media
Paint thinner
Spent hydrofluoric acid
Spent nitric acid
Caustic soda
Mold wax
Mold material
Dust collection sludge
1,200 lb.
204 yd3
91. 25 ton
3,650 yd3
104 yd3
78,000*
156 lb.
5,200 yd3
600 gal.
2,860 gal.
130 gal.
780 lb.
Unknown
180 gal.
360 gal.
12,000 lb.
240 lb.
862 tons
45,375 gal.
Table 1 has been compiled from the "Remedial Action Master
Plan, Dover Municipal Landfill, Dover, New Hampshire"
prepared by NUS corporation of Pittsburgh, Pennsylvania in
September, 1983.
A total of 6,468 drums per year were noted in this New
1.
-------
Appendix B
TABLES
TABLE 1 INDUSTRIAL WASTE SURVEY
TABLE 2 CONTAMINANTS OF CONCERN
"
RISK ESTIMATES:
TABLE 3 FUTURE USE OF GROUNDWATER
TABLE 4 FUTURE USE OF BELLAMY RESERVOIR
TABLE 5 INGESTION OF SURFACE WATER - COCHECO RIVER
TABLE 6 DERMAL CONTACT WITH SURFACE WATER - COCHECO RIVER
TABLE 7 DERMAL CONTACT SURFACE WATER - SWALE
TABLE 8 INGESTION AND DERMAL CONTACT WITH SEDIMENTS - SWALE
-------
TABLE 2
contaminants
of Concern
Maximum
Concentration
ppb (ug/L)
Frequency
of Detection
RI
(Wehran. 1988)
FES
(HMM. 1991)
Acetone
Arsenic
Benzene
Cadmium
Chloroethane
1,1-Dichloroethylene
1,2-Dichloroethane
Mercury
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Tetrachloroethylene
Tetrahydrofuran
Toluene
Trichloroethylene
vinyl Chloride
130
1300
80
o
38
13
76.3
o
360
230
360
6
1707.5
470
11
62
6/10
3/4
6/10
ND
ND
2/10
3/10
ND
ND
6/10
8/10
1/10
9/10
9/10
1/10
1/10
3/10
5/5
6/10
2/10
1/10
ND
1/5
1/10
2/10
4/10
1/10
NA
9/10
1/10
3/10
The table lists the maximum value of contamination found in selected
monitoring wells during the FES activities except for ~wo compounds. Data
from the RI was used for tetrahydrofuran which was not analyzed for in the
-------
Hampshire waste survey as being produced by these
industries.
*
Unit not given
Sent to Dover Wastewater Treatment Plant. Ultimate
disposal of wastewater sludge was the Dover Municipal
Landfill.
**
" II
. . .
Waste names obtained directly from New Hampshire survey.
Unknown
Exact composition unknown. Amounts produced per year were
-------
I
TABLE -4
RISK 'F_CITIMA TE.S POR 'FtmJRE USE OF .
BF.LLA.MV RP.S~VOIR
turfln van,. . hi ,I"'Ą ,",,.volr -.- _.
IftI..,I~ of Drt~;~' .."r
~t""obIDI' 8"G .D",~':II'
COIit LITI lCD' ItO CAltlll
tCllllPOl"d ICED .0" '" CALC CALC
II
AcIe~ 1.011-04 2 70 1._-06 1_001-111 tIA 1.061.05 0.001.00
ArHfIle '.5Z1-04 2 70 4.141-06 1..-01 '.7'51-00 4.141'01 7.601'06
hftIlN '.901.05 2 7D 2.5'1.06 .. 2.901'02 0.001-00 7_171.08
CedI"'" O.~ 2 7Q 0.0lIl.00 . 5.8'04 .. 0.001.00 0.001-00
Cllt8...ttfllN '.461.05 Z 7Q '.ISI'06 .. . 1.101,02 0.001.0<1 1.401'08
1,1'OleftLOrOltflytene 0.001.00 Z 70 0.001.00 ...-01 '.001'0'. .0.001-00 0.001-00
. '.Z'Oleftt8rOltklftl 8.601.05 Z '7D 2.461-06 .. ,.1.'02 .0.001-00 2.241.07.
MIf'C\IfY 1.1..06 Z 10 1.141'08 '.401-01 . tIA 2.241.05 0.001-00
. Mltflytene Chtorldt 0.001.00 .2 '70 . 0.001.00 '.001.02 7.'01.01 . 0.001-00 0.001-00
Mellyt IIftyl "ttOnt 1.601.04 2 10 4.571-06 5.001'02 .. .. "1.05 0.001-00
Mellyt 'Iotuty' rltOnt 1.80E'01 2 10 5.1101'05 5.001-02 "A '.031'01 0.001-00
'.trlCftlcrOl!~yl~ O.OOt.oO 2 '7D 0.001.00 1.001.02 5.1.-02 0.001-00 0.001.00
Ttt,ltIydrot""lft 2.941.01 2 10 '."'-05 2.001.01 .. 4.201.02 O.OOE.oO
Tilt""" J.~6I-03 1 70 '.OZl-Oio '.001.01 .. 1.191.010 0.001-00
.., :lefttorOltflytlN 0.001.00 Z 70 0.001.00 IA '.'01-02 0.001.00 0.001-00
VI..,t ctILorld8 0.001-00 2 10 0.001.00 .. 2.301.0<1 0.001.00 D.OOE-oo
I!E!ii lilk 1o.19~
. .
CYlI:
1e01t,'r_lIt. cae - worst.cae ",IUIt tII. ... cont..tntnt nncentratten.
I., C.te . Ave"" Dal ty DOSt of COftt.."wnc
ltO V.t", . .,f.,..,.. Dos. for ....dcutar COftt8llntnt
Carel" 'oe8I\CY . Carcl""",C .ot"," .. tilt partlcut.r cont..INftt. flOW tIftMIft .. tile .1. foecor
If 0 Cllc . "~'C8'clftOtl"IC II.t E.CI..Ct
Coret" Calc. Caf'C,,,,,,,,tc "tt 18Ct.."
.. . lOt AvallablO
. .
-----. .------
.I
.' .
..-.-- - --
..0' .-.-... .. .......
.- _00 .-
--...... -'...
2512.121HA714S54
4-21
i
J
i
I
-------
I
TABLE -3
RISK ESTIMATES FOR USE OF GROUNDWATER
IN THE AREA OF FUTURE DEVELOPMENT..
GrOll'ldw.c,r - .flit"'" :~'.-nc '. '
, -
I ",tiC Iorl of :r;"'~"'1 .,c,r. ROSC"robIbl' Call
:"''''NC 2 UTI lCD' CAICIII IfD CAlltlli
C~ "10 OAT WT .oTEIIC' '" CALC CALC
II ( III Iday).1
Ae,cON 01.0235 2 70 6.71!-C14 1.001'01 IIA 0.001 ~.~oo
Arlenle 0.3535 ' 70 1.01Ł'02 1.00E'03 1.nl.oa 10.100 1.771,02
ItI'IIII'II 0.0Z33 - , -' 70 ,6.661'04 '.' 2..-02 ' 0.000 1.931'05
C.IIII", 0 2 70, O.DOE.oa 5.DDE-04 IIA 0.000 0.001.00
CM orontllftt . 0.006 2 "'70 1.711-04 ,IIA 1_JDl-02 0.000 2.23E'D6
1.1'Olchlor..~'8ftI 0.0013 2 70 '.711.05 '.OOI'OS 6.001-01 0.004 2.DI'OS
1.2'Olc~lor"Ch8ne 0.0157 2 '70 4.491'04 IIA '.101-02 0.000 4.0IE'OS
...rcury 0 2 70 0.001.00 1.401.0] IIA 0.000 0.001.00
",c~ylll'll Chloride O.DS6 Z 7'D 1_m-os 6.001-02 7.SOI-OS 0.01' 7.111'06
".~y\ Ic~yl It.CON - 0.035 "'2 7'D 1.001-03 S.OOI-02 " IIA 0.020 O.DOE.oa
"ec~yl IlotIUtY'I CICON ,0.0698 2 70 1.991.03 5.001-02 IIA 0.040 0.001.00
Tecrle~lor"~Y'Itni 0.0006 2 70 1.71I'OS 1.001'02 . -5. 101.02 0.002 . 1.11.1,01
11crehydrofuren 0.429 2 70 1.231-02 '.001-03 IIA '.129 0.001.00
Tol- 0.1094 , 2 "1'D ' '.131-03 '.001-01 .IIA . 0.010 ' 0.001.00
Trte~loroec~Y'l,", .0.0011 Z '70 ,' ,'.14.-05 ." 1.101'02 .0.000 '.461,01
Vinyl chlorha 0.01" 2 ''70 '~T4I-04 " IIA ' 2.301.00 '0.000 1.611'04
I'eviled list ,m 1.861-02 ,
GrOllldw.ur - Flit"'" O~I.....,t
I",HClorI of Ori'*h'l WlCI,.. WClr8C-c...
CONC Z LlTI lCD' .fO CAICIII
COIIIPOIN MD ' .OA1 ." CALC CALC
II
AutON 0.13 Z 70 3.711-0] 1.DOE-01 IA 0.031 O.OOE.oo
Arlenle 1.3 2 70 '.711-02 '1.0DE'OS :1.751.00 37. "3 6.501'02
ItI'II'"' 0.08 2 70 2.291-03 IIA 2.901-02 0.000 6.63I'as
C'lIIillll 0 Z 70 0.001.00 ".0DE.04 IIA 0.000 0.001.00
" CMor..t~- 0.031 2 70 1.09I'OS IIA 1.101-02 0.000 1.411-05
\ 1. 1,'Dfchloroe~Yltni 0.013 2 ''70 3.~1-04 '.001.03 '.001'01 0.041 2.231-04
1.2-DlchlorOltb8ne 0.0763 Z 70 2.18-03 ,IIA t.101-02 0.000 1.981.04
Mercury 0 2 70 0.001.00 1.l.cll'03 IA 0.000 0.001.00
Me~yltnl Chloride 0.36 Z 7'D 1.031-02 6.001-02 1_SOI-03 ,0.'" 1.71I-OS
...c~yl It~yl It.CON 0.23 2 7'D '.571.0] 5.001-02 IIA O. '" 0.001.00
...~yl .loI:IIItyl «It ON 0.36 2 ': '70 1.031-02 5.001-02 IA 0.206 0.001.00
TetrKIIloroetllyl- 0.006 Z ,'70 1.711-04 '.001'02 '.101-02 0.017 1.141-06
T.trehydrOfur8ft 1.101'5 - Z -10 4.111,02 2.001-03 IA 24.m 0.001.00
.I.ToIUlflt ' 0.41 Z 7'D 1_341-02 3.001'01 IA 0.045 0.00Ł.00
Trlchloroetlly\8ftI 0.0'" Z iu ,_..- ~.141'04 IIA 1.101'02 0.000 3.461-06
vtnrl Cfttortdl CI.06Z .'. Z 70 '.m-as ItA UGI.oo 0.000 4.071'03
'Reyiled l;sk ~
. .
I
I
1
IOTES:
Mou,'roblbt. Cas. utll II" tile .ver... cont_frllnt concentrlttorl fr08 IU "UI
uMbltl", vac corIt_iNttorl In tile .11 .
worst 'Clle utU 11.1 the ...1- corIt_iNM concentretlon detected fra8 ""I
uhtblti", vac COftt_iNtlorl 1ft tile FII.
- lap Calc. A..,.... DIUy 008. .f cont_t...c
.to v.l'" . ..ferenc. 001. for ..rttculer COfIt_INflt
Caretn 'oteney . CarclftOll"tc 'oteney of the partlculer corlt_INnt, flOW UIIDIIfI .. the I\ope fector
liD Calc. .on-carchlOl",te Iflk Iltl_t.
Caretn Calc. carctflOlenlc Itst Iltt_t.
IA . lOt AveU".
,
1
,
4-19
1122'"
-------
TABLE -6
RISK Ec:TIMATES 'FOR nJ::RMAL roNTACTwmI
S' TR J: ACE W A TPR - rnt"R'F..CO RIVER.
..
.. -... -_.- ..--....
I"fec. WlI.r - C8Ct1teO II VIr .
0'1'881 COI'IlaCI .1111 Surfac. iMl.r. ..on .rCltl8bta Call
C~
t:*C
ICD
11.1 1(111 11111 HIM. S 10'
1000 dU IWT can nIIT 'A" WT
ca'J CI8Z Cllllllr " 'IAI II
CAlC IfD
..oTlII -' - CALC
It Iday.1
tAICI.
CALC
ac'ION 5.991.115 0.001 10000 , 81-04 11 365 Ł0 J.tU." 1.621-" '.001-01 ... 1.941'09 O.OOI.OC
ars8fllc 1.001.05 0.001 10000 1 81.04 12 165 40 1.951"0 5.641'" 1.00I.OJ 1.751.00 '.95E.01 9.861'"
IIN'" 1.101.115 0.001 10000 1 0.041 11 165 Ł0 1.181-08 1.681.09 u 1.90Ł.02 0.001.00 '.89Ł'"
C_h. 0 0.001 '0000 1 8-04 11 165 Ł0 0.001.00 O.OOE.oo 1.001-04 u 0.001.00 O.OOI.aO
. CMONtI""" '.6.11-05 0_001 '0000 , .-04 12 J65 Ł0 1.111'" 1.191'" .. 1.JOI'1I2 O.OOE.oo 4...,Ł.13
1.1.,Iclltoreetllyt. 0 0.001 'CIOIICI , .-G6 11 J6S 40 e.aaMIO 0.001.00 '.DOI-OJ '.001-0' 0.001.00 o.OOI.ae
,.Z'OICII,.,..ltItN 4.101-115 O.CIO\ 'GOOD , a-or. 11 565 40 1."'10 4.11.-" . U '.101'OZ 0.001.00 4.101'12
",rcury 4.001'07 0.001 '0000 , ..04 12 'IS Ł0 l.m'11 '.761.11 1.~'OJ u 1.111.09 0.001.00
"'111"... Clliorlde 0 0.001 10000 1 8I'OIt 11. 165 Ł0 0.001.0<1 0.001.0<1 1.001-01 -'.101.03 0.001.00 0.001.0<1
"'III" ItII" «.101'1 '.001-115 0.001 10000 1 .-04 11 J6S Ł0 s.m'" 8.451-" 5.00I'OZ u 1.1..08 0.001.00
tlttllY' IsatutY' I. 1.011'03 0.001 10000 1 8I'OIt 11 165 40 1.641-09 '.'91.10 S.00I'02 u '.m.07 0.001.00
"lr~'er..tll,'8ft 0 0.001 10000 , ..04 11 165 Ł0 0.001.00 0.001.00 1.DOI.1I2 1.101.02 0.001.00 0.001.00
T.lrallydrofuren - 1.64I-OS 0.001 10000 - 1 ..0It 12 165 Ł0 1.011-08 1.541.09 I.OOI'OS u 5.J9Ł.06 0.001.00
,.,.... 1.401.01 0.001 10000 1 tI.OIt 12 J6S Ł0 1.041.08 1.481.09 1.001.01 u ,.,5Ł.08 0.001.00
Tricl\'oroetll"... 0 0.001 10000 1 8I'OIt 12 165 40 0.001.0<1 D.OOI.aO u 1.'01.01 O.ooE.oo 0.001.00
VI.." ~'oride 0 0.001 10000 1 8'0It 12 165 Ł0 0.001.0<1' 0.001.0<1- --u I.SOE.o
-------
TABLE .S
RISK 'F_c;TIMA TFS FOR INGP.STION OP
SURFACE WATER. - COCHECO 1UVIm
,faco weur - CocfIeco liver
....nion of SUrfac. "Iter. ...., "'o8I8b\. en.
IfD
CALC
CAICI.
CALC
GIIIDCU'CS
COlIC
M!D
WATEI .
'.CUT IVIITI
"fOOtOflt "al
tr:F J6S ICDY
D." vr
"AI . k
.,:.tON S.99E-OS 0.05 12 1 165 40 2.WI'09 1.111-'0 1.001-01 IIA 2.461-01 0.001.00
,rs",le 6.CICII-05 O.OS 12 1 165 'CI 2.471.09 1.IU"0 '.001.03 1 . "1.00 2.471.06 6.161-10
"",.. ,- I.IDE.OS 0.05 12 , 165 'CI .1.441'09 2.051-10 8~ 2.901'02 0.001.00 '.961,12
:ec8l1'" , 0 0.05 U 1 J6S 'CI O.ODE.oo O.ODE.oo 5.0DE'04 8~ I.ODE.OO 0.001.00
,,\ oroottl8M 1.611-05 0.05 12 ' 1 165 40 1.411.09 2.121-10 .. '.101.02 ' 0.001.00 2.761"2
1.1'Dictllorootllyt... I 'O.OS 11 1 165 40 O. CICII.oo 0.001.00 '.001-03 6.001-01 0.001.00 O.oar.oo
1.2'D'~\Oroottl8M 4.101.05 .0_05 12 1 165 40 '_'71-09 2.121-10 IIA ' 9. '01'02 O.DOE.oO Z.561'"
~ 4.00E-07' 0.05 12 '1. 165 40 1.641-11 2.151-12 1.401.03 IIA '.171-01 O.oar.oo
-ttlv\.. CM8I". 0 ' 0.05 'Z. ' 165 40 0.001.00 0.001.00 6.001-02 7.501-03 0.001.00 0.001.00
,..ttIv\ IttIv\ cotone '.001-05 0.05 "2 , J6S 40 1.701-09 5.211.10 5.CICIE-02 IIA 7.401-01 0.001.00
,..ttIy\ ...,,,\ btOl'l 1_011-03 '0.05 .12 1 165 40 4.15..01 5.931-09 5.DOE-02 IIA 1.101-07 .0.DOE.oo
rotl'8Cll\ oroottly\... 0 0.05 12 , 165 40 0.001.00 O.DOI4 1.0DE-02 I. '01-02 0.001.00 0.001.00
1\tr8llydrof!lt8ft '."I-OS 0.05 12 , 165 40' 6.741-01 '~6J1-09 2.DOI-OS IIA 1.171-05 .0.001.00
TD\UIN '.401-03 0.05 12 1 165 40 5.751.01 I.ZZI-09 I.CICII-01 8A 1.921-07 0.001.00
Trt eft \ oroottly\.. 0 0.05 12 1 165 40 0.001.00 0.001.00 IIA 1.101'OZ 0.001-00 0.001.00
wl,.\ efILOt't. 0 0.05 12 1 J6S 4G 0.001.00 0.001.00 IIA 1.101.00 ' 0.001.00 0.001.00
l..,illCl Illk ~
surf8CO ""tor - COCtIeco Itwr - -..-..
."18"101'1 of Surfaco ""tor. ",...t-ea..
COlIC WAUl . TCF J65 ICDY ItD WCI.
CIIIIPOIftS MIl .IGlIT I'MI DATI vr CALC CALC
"f..,."t ftAI 'FIAI II
Ant8M I."'-OS 0.' 14 1 J6S 40 '.141-09 1."'1-09 1.001-01 IIA 9.141-01 0'.001.00
af'88ftlc 6.001-05 0.1 14 , 165 40 '.161-09. '."11-09 1.001-03 1."1.00 '.161-06 2.471.09
I_8M 1_501-05 0_' 14 1 165 40 1."1-09 1.221-10 ,IIA 1.901-02 0.001.00 Z.SIE.1'
C88hlil' 0 0.1 14 1 J6S 40 0.001.00 0.001.00 5.001-04 IIA O.ODE.oo 0.001.00
.,.,.....tt\IN 1.'''-05 0.1 14 1 J6S 40 s.m-. 1.411-10 IIA 1.101-02 O.DOE.oo 1. 'OI~"
1.1-Dteft'.r~Y'8M 0 0.1 . , J6S 40 0_001.00 0.00I.cI0 '.OOI-CIS 6.001-01 0.001.00 0.001.00
1,Z-DtcM8f'8lttI- '.101-05 1_' 14 , sa 40 1_"-09 1_1.-09 -IIA 9- '01-02 0.001.00 ,'_O!!.~:
...rcury 4.001'07 0.' 24 , '" 40 ,.,.." '.S9I-12 1.6III'OJ IA 4.101-01 0.001.00
...ttIv\8M ""8I'i. 0 0.1 14 1 Sd 40 0.001.00 0.001.00 '.001.02. 7.SOI-OJ 0.001.00 0.00Ł.00
...ttIy\ It"y\ CotON ...-OS 0.' 14 1 J65 40 1_411-01 2_111-09 1_001-02 IIA 2.961-07 O.OOI.oa
..ttIy,. 11ItIIICY' btOl'l 1.01''' ''' a , 165 60 '."'-07 1.171-01 1.001-02 IIA I.m-" 0.001.00
Totr.'oroetIIY'... 0 I., 'M 1 J6S 40 '.OOHO 0.001.00 1.001-02 5.101-02 o..1M!I.oo 0.001.00
Tetr8llydroful'8ft 1.64I-a 0_1 14 1 165 40 2.701-" S.I5I-OI I.OOI-OS IIA, '.151-04 0.001.00
, 0''''''' ,._-a 0.1 '" 1 S6S '" 2.SOI-07 S.29I-0I 1.001-01 .A 1.671-07 0.001-00
'rt~'oroottlv'''' 0 0.1 Z4 , 56S '" 0:001.00 0.001.00 IA 1.101-02 0.001.00 O.ODE.oG
v,~ ell,,,,.. 0 0.' 14 1 165 40 0.001.00 0.00I.0D IIA 1.101.00 0.001.00 0.001.00
)...,illCI . Ilk ,.4~
leOR QUALITY
',ORIGINAL
2512-1~4SS4
4-22
~
-------
, . .......--
~.
-
-
-..
-
-
---'.., .
~ . . ~ -'. ....~J
TABLB -8
RISK ~TPS FOR INOP-~ON AND DPRMAL mNTACf
wrmSBD~ - SWAJ..B . .
ledl.. . ...,. .
So" . .....tl- ... ...... ~. ....,.~. C8M
IIIIC lIP IOI~ '"f -DA 'I["N I.."' .' 165. .'_11 ..... Ufl LIf" ...
- .,.,.., DIll I. '001 II1II11. VI .." we we IIGIII . ..... VMUlI
c8l II ftM II ! II
Ac8t- I 51 .. II I.SI '.25 , I..'" 41 165 I.." ..... . . 1.001-01 IIA
ar..,c ".S 51 1- II I." I." I.S I..'" 41 165. 6..'" '.J.'" 5..'" 1.191.01 I..'OJ I.N"
1enI- I 51 1- II I." 1.25 , I..'" 41 J6S I.." ..... I 0 ... Z.....IZ
C8d11U8 7.' 51 .. II I." ..., 1 I."'" 41 165 '.111'" I.J5I'" 1.121'" I.9J4I.., S..'.' ...
0'.......... I 51 1- II I." '.25 1 I."'" 41 165 I..'" I.." I . ... 1..'1Z
1.1'1''''''''''''- I 51 1- II ..,. 1.25 1 I."'" 41 165 I.." ..... I I ....OJ ....."
I.Z'II"'.......... I 51 1- II I." 1.25 1 I."'" 41 J6S I."" I.." I 0 ... '.1.'01
IIIrCI8'Y 1..11 51 1- so ..,. 1.1 1 I."'" 41 565 1."'" 1.151'" 1.6lE'" 1.49lE.I' 1.4..IJ ...
........- a.,...I. I 51 .. so '.51 1.25 I I..'" 41 165 I.." I."'" . '..,81 1.5OI'OJ
......,. I"'" ht- I.. 51 1- SO' ..,. 1.25 1 I..'" 41 165 Z.91I'. '.411'. 6.151'" I.IS9I-OI 5..'1Z ...
........ .1GIIutJI Ie,.. . 51 1000 so I." I.~ I I..'" 41 165 I.." I..'" I I 5."-OZ ...
,.,,-,,'or..8IIr'- I so .. II I." I.: 1 I..'" 41 165 I."" I..'" I . I.OOI-OZ 5.I.'OZ
'."""'.'unI! '1 so 1001 II ..,. I.. I I.". 41 165 I.." I.." I 0 z...-OJ ...
,..- . SO ' 1100 so ..,. '.25 . I I."'" 41 165 ..... ..... . . . J....OI' ...
'r'''''''''''''- I so 1- so ..,. 0.25 1 I."'" 41 165 ..... ..... . . IIA 1.1.-1Z
VI.." ",...'eII . so 1001 so ..,. '.25 I I.."' '' 165 I.." I..'" 0 IIA Z.JOI'"
Ic-.-. '_11 '_11 II'" :::1
... we CM eM. ... we
ac.,- ..... ..... ..... ..-...
b ar...c ....OJ 1.021'" ...... Z.OII'" .
.0 18nI- ...... ..... ..... '.ODE"
~~ C881.. I."'OJ '.001" z.nl'OJ .....
0'"'''''''' I.." '.001" ..... I.."
1.1'1''''''''''''''- ...... '.001" I.." '.001"
f10 I.Z'I'''''''''''''' I."" ..... I.." 1.001'.
IIIrCI8'Y r.sq." 1.001" 1.491'" I.."
lr' ........- III'..... I."" I~OOI" I.." I.""
~- ........ II'" 181- S.tH-" I.." 1.411'''' I.""
r- r-- j ......" ......." h... I."'" ...... I.." I."'"
- I..redlloroe8llr'- I..'" ...... ..... I."'.
~ ,..,......,... I."" . ..... ..... ......
,.,- I.." I.." ....01 1...00
1'1"1..........- I.." 0.." ..... '.001'"
VI"" "Iorlell I.." 0.001" 0.001'" '.001.00
,
.1"IMd liall 5.65f.OJ 1.021.06 J.S4I'OJ 1..'07. '
'f.
. ' ,
-------
JABLE -7
BISK F~c;TIMATES POR DERMAL roNTACTwrrH
SURFACE WATER - SWAt P.
.~flc' Wlter - IĄI"
._1 ContICt. tlost','r""', :1..
COlIC 1LI IICII ffIJ "'It! II :us BY '.'01 IX'OSE IfD CAlC IfD CARCIII
:.....- - . . -tIED 100D dlA IV! COlI Iwt DATI WT 0.' . "IF. . VA&.\81 POtU ...CALC CALC
IICft CIII'1 cIIIZ CIII/tI r n YEAR t, ..,t"dIy ..,t"dIy ..,tl'CS,y ..,.."CS8y' 1
acetON .. ~ 0.0026 0.001 1100 1 .-04 12 165 40 1._-09 4.401'10 1.001-01 11& 1.011-08 0.001.00
'rs",lc 0 0.001 '100 1 U-04 12 165 40 0.001.00 0.001.00 1_001-03 '.751-00 0.001.00 0.001.00
I8ft1IN 0.OCK2 0.001 1800 1 0.0l01 12 165 1.0 2.551-01 1.""'08 IIA 2.9OI'OZ 0.001-00 1.061-09
c:.aaIWil 0 0.001 1100 1 8-0l0 12 J6S 1.0 0.001.00 0.001.00 5.00I'0l0 IIA 0.001-00 0.001.00
Ct\'oreetNN 0 1_001 1800 1 8-04 12 - 40 0.001.00 0.001.00 ... 1.101'OZ 0.001.00 0.001-00
1.1'DI~loroeC'Yle 0 ".001 '" t .-010 \2 - 10 0.001.00 O_oaMMI ..001-0, 6.001.01 0.001.00 .o.OOMIO
"Z'DI~lor~ 0 0.001 ,M 1 .. 12 165 40 0.001.00 0.001.00 IIA t.101-0Z 0.001.00 0.001.00
fIet'CU"Y 0 0.001 1800 1 8'01. 12 165 1.0 0.001.00 0.001.00 1.I.OI'es IIA 0.001-00 0.001.00
"'ttlyl IN eM or I cte 0.0031 0.001 1800 1 .-04 12 165 40 1.671.09 5.241'10 '.001-02 . 1.501-01 '.1U'08 1.931'12
Nttlyl I tt\y\ Ceton 0.'" 0.001 '800 1 11-01. 12 165 1.0 2.001-01 2.161'01 5.00I-OZ IIA 1..001-06 O.OOI.oa
"'C'YI 110. Cet. . 0.0556 0.001 1100 1 U-04 12 165 40 '.5a-0I '.401-09 5.001-02 IIA 1_1U-06 0.001.00
tetr8Chloreethylen 0.001 0.001 .1100 1 U-04 12 J6S 40 1.1.-09 1."'.10 1.001-02 5.101-02 1.111'01 1.621.12
'etrlllyarofUl'Ift O.am 0.001 1100 , U-04 12 J6S 40 J.DI-oa 4.621-09 2.00I-a 8IA 1.621-05 0.001.00
10lUlftl 0.0114 0.001 1800 , tI-OI. 12 165 40 1..1.-01 5.,.,.-09 J.00I'01 8IA '.191.01 0.001.00
trl~lor..thy\1N 0.0065 0.001 1800 1 11-01. 'Z 165 1.0 1.691-09 1.'01-09 IIA 1.101-02 0.001.00 1.Z1I'"
vl",,1 ~Ioricte 0 0.001 '800 1 .-04 12 165 40 0.001.00 0.001.00 8IA 2.SOI.oo 0.001.00 0.001-00
a,vi..d ai.1t ~
-
WI;),
tYrflce Wlt,r - SMale
DI'" ContICt. worst.cas,
COlIC 1LI .111 1111 'IIIC . 165 101 IXPOS IXPOII IfD CdC If 0 CUCIII
~ - 1000 AlIA M COlI IVIIt 0'" vr OAT Lln YALUE' POTIII CALC CALC
J .. CII'S CIIZ CII/IIr n flAI ti ../t"dey ..,ki/.Y ..'t".y ..,It".y-1
Acet- 0.021 0.001 1100 ,- .-04 12 165 40 I.S11-0I 4."1-09 1_001.01 IIA S.S11~01 0.001.00
,......Ic 0 0.001 1800 1 .. 12 165 40.0.001.00 0.001.00 1.001-01 1.1'51.00 0.001.00 0.001.00
IIftIIN O.01J 0.001 1800 1 0.041 12 165 40 1."'-01 1.111-01 8IA 2._-02 0.001-00 1.Z1I-09
ee.h. 0 0.001 '800 1 .-04 12 J6S 40 0.001.00 0.001.00 5.001.04 8IA 0.001.00 O.OOI.oa
CIII"",tYw .. 0.001 1100 1 .-01. 12 165 40 0.001.00 0.001.00 IIA 1.SOI'02 0.001.00 0.001.00
'.1'Oichl.....C'yle 0 0.001 1100 1 .-04 12 165 40 0.001.00 0.00I.0G '.001-01 6.001.01 0.001.00 0.001.00
'.2-01~1.....~1ftI 0 0.001 1100 1 .-" 12 165 40 0.001.00 0.00I.0G IIA ".101-02 0.001.00 0.001.00
tIet'CUI'Y . 0 0.001 1100 , ..... 11 165 40 0.001.00 0.001.00 '.401-01 IIA 0.001.00 0,001.00
"'tll,I'" 01""'. 0.- 0.001 1100 , ..... 11 165 40 1."'-01 ,.a-Of '.001-02 1.501-01 4.911.01 S.171.11
...ttly\ Ittlyl let'" 0.714 0.001 1100 , .-04 12 165 40 ,._-01 1.DI-01' 1.001-02 IIA 1.161-05 O.OOI.oa
IIIttIy\ '18. I.~. 0.2'. 0.001 '800 , .... '2 S65 40 2.531-01 1."'-01 5.001-02 IIA 5.061006 0.001.00
t'tractll.....thYI8ft 0.011 0.001'100 , ... 12 S6S 40 '.SOI-. ,."'-Of '.OOI~OZ ,.,QI-OZ '.101-06 '.'''-''
TetrlllydrofUl'lft 0.014 0.001 '100 , .-04 12 165 40 1.161-01 1.251-08 2.001-01 .IIA 4...05 0.001.00
'el... 0_152 0_001 1Il1O. , .-04 12 J6S 40 2.021-01 2.191-01 J.00I-01 8IA ..?S1-01 0.001.00
Trl~i.....ttlyI8ftl O.CIJIt 0.001 '101 , .-04 12 J6S " 4_601-01 '.511-" IIA 1.101-02 O.oOE.oo 1.231'"
VI..,I chler'. 0 0.001 ,lOG , .-" 11 165 40 0.001.00 0.001.00 8IA I.JOI.oo 0.001.00 '0.001.00
~t 7.0~
- .-." _... .... - . . . " . .... ... ..-. ... - --
-. ..-..
~ QU~\.\ \ 1
!oO \IG~\'\~\..
,O~\
2S12-12/HA7J4SS4
4-24
-:
'"
t
-------
/'
~.
. ,(
-
.
.,'
: :.
. -~ J:..
~
. 'mBLE9
R~~=J;R~~J~~RAFn INDUSTRIAL DISCHARGE
r Q NTS FOR THERDVER WASTEWATER
TREATMENT FAcn..ITY
Discharre T mit - Industrial DischarJe
Determined on . case-by-c:ase basis, aDd contingent
upon sewer line capacity
Parameter (UDits)
Physical Parameters
,
Flow
pH
. Temperature C'frC)
Color
6.5 ~ 11.0
l~I6S
No deeply ItaiDing dyes
CMmical PlU'3lDetel'S
Total Solids (mg/l) - Avg./MD..
Tow Volalile Solids ('II of total) .
Total Suspended Solids (mg/l) - Avg./MD..
Total Dissolved Solids (mg/1) - Avg./MaX.
Senable Solids (mg/1)
Acidi~
Alblinity (mg/las ClC03)
S-Day BOD (mg/1)
COD
Oil aneS Grease (mgll)
Petroleum Soils in Wastewater (mg/1)
CbJorieSe as Cl (mgll)
Sulfate as 904 (mgll)
Sulfites (mg/1)
S~de as 9 (mgll)
AneDic (mgll)
'BayUium (mg/1)
Boron (mg/1)
Cadmium (mg/1)
OIromium crotal) (mg/1)
Chromium (Hexavalent) (mg/1)
Copper (mg/1) .
,,' . Leid (mg/1) .
Meraary (mall>
Nickel (mg/1)
Selenium (mill)
Silver (mg/1) ,
Cbloridel (mall>
Cy......:,!v,," fr:'\-'"
..........--.. "-'Oo-J
PbeDola (mg/1) .
Total Toxic OrglDicl (mg/1)
7JDc (mall)
1.20013.000
-
400/847
60011.500
30
75
300 (BOD - 791 mg/1)
.'
100
15
SOO
150
2.0
0.1
.400
2.0
0.1
0.020
4.03
1.15
0.2
-..-.. .ow -------
0.004
1.07
80SS
.713
500
.363
182
5.0
4.33
1.
Proposed Pretreatment S~dard8 Ire draft u of April. 1990. (updated based on new operating
permitS U of November, 1991).
.,t;'''..~ If' A'" '2 C'7'2
Lit 1
-------
_. .--- ~. ..
-----........... . -_..-___4..'''.- ....--..-~I--
. .'~. .
, .
. ,
. .
.
....I_t - ...1.
"~I ,....al. ~..... .....t. ""'-C8M
CIII8C - lOlL Ilf-IlA, Ilf'U .... ." J65 IIIIiEII
.. ...., CIII' I. 1001 "'" ur tan we
C8Z , HAl
acot- . M ~ II 1.5 '.5 I I.." g J65 ..... ..... . . I ..... IIA
",..Ie ~O ~ M 4tOO .: II '.51 0.05 I I.." g 165 1.1'E'" 1...05 5..,15 '.25IE'05 1...tJ l.lSEoCIO
--- J5I 4108 II '.51 0.5 I I.." g J65 ..... ..... . . M I..'OZ
C881.. 11 M 4GGO II '.51 0.' I I.." g J65 1.151.05 1.111'" 1.6'1'" 1.mE'lS S..'. IIA
eIIlor."" . Z58 4108 .. '.St 0.5 I I.." g J65 ..... I..'" . M' 1..'OZ
1.1'8101_",,- . M ~ II '.St '.5 I I..'" g J65 '..oCIO ..... . . t..'U '..-01
1.1'lle~Ier.~ .' Z58 4GGO II ..St '.5 I I.." g J65 I.." ..... . . M t.1Of'OZ
llereury '.11 Z58 ' 4108 II '.51 '.5 I I.." g J65 5.0IE'oe 1..'07 4.4CII'. 1.JINE'" UOf.tJ IIA
"t~,18nI CIIlorld8 '. Z58 4GGO II '.St 0.5 I 1.." " J65 ...oCIO ..... . I '..'11 7.5Of-OJ
"t~,1 I~" rot- ' 1.7 Z58 4108 II '.51 0.5 I I.." g 165 I.m... 1.01l'OS 5.741.07 1.5211'" S..'1l M
..~,I ....." lot.. . Z58 4tOO " 0.51 1.5 I I..'" 41 J65 0..'" ...... '. . S..'1l M
'ot,~Ier..,~,I- . Z58 4tOO " '.'1 '.5 I I.." g J65 ..... ........ . I 1...N 5.1Of-OZ
'ot,"'''.'",. . Z58 4GGO II '.St '.5 I I.." 41 J65 ..... ....... . . 2...tJ IIA
101- . Z58 4000 II '.51 '.5 I I..'" 41 J65 ...... ....... . . S.."1 'M
I,ldller.....,I- . Z58 4000 .. O.St 1.5 I 1.." g J65 ....... ....... . . M t.IOf-OZ
'I~I dI~erl. . Z58 400t II '.St 1.5 I 1.." 41 J65 I.." ...... . . M 1..oCIO
Ic.....- I.1f '_5' .... ~I
I" w.e CM CAl I" eMC
acot- ....... .....' ...... ,..oCIO
.,..Ie .., 1.1'E'" S..-OS '..-11 2..-OS ~
-a --- ....... ..... ...... .....
0 C881.. S.laE'OZ ... eGO 1.411'" ,..oCIO
eIIler."" ....... ...... ..... .....
00 1.1'lldller.""- ....... ...... '..oCIO .....
~~ 1.1'8Ial_'~ ....... '..000 '..oCIO .....
90 "'cwr 1..-15 '..eGO I..'" .....
..,~,I- CIIlerld8 ...... '..000 ...... .....
zc "'h,I Ithyl lot- S.Z4I'OS ....... Z.141'. .....
»» "'h,I .....,1 lotan I.." '..000 ..... .....
'otreal_'hyl- ....... '..eGO ...... .....
r-!:: 'o"8hv*o',,,. ...... ....... ...... .....
:
-------
. .
.~ If.,#.
.(Sl'
..~ ~~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL CRITERIA AND ASSESSMENT OF,.ICE
CINCINNATI. OHIO 45268
May 3, 1990
SUBJECT :
Provisional RfD for Tetrahydrofuran (THF)
FROM:
Pei-Fung Hurst /J "I , J -r
Biologist "'"" .. oI_~ I~
Chemical Mixtures Asse~ment Branch
Rodger Duart
U.:: EPA
Region I ~
w. Bruce peirano /1Y'. AH. -cc ~~~--.r--
Acting Chief
Chemical Mixture Assessment Branch
TO:
THRU: .
/
....: : .... .
This memo is a draft response to your request for an oral
assessment ot the toxicity of tetrahydrofuran (THF) for the Mottolo
NPL site. Although an oral RfD for THF was prepared and presented
to the RfD Work Group on 01/28/87, it was not verified and was
placed under review until a complete translation of the critical
study (Katahira, 1982), published in Japan~e, could be obtained.
(An inhalation RfD for THF, based upon this same study, has been
verified on 1/19/90.) Consequentially, ECAO has obtained a full
translation of the Katahira (1982) study and based an interim oral
RtD for THF ot 0.002 mg/kg/day upon this data. Below is a summary
of the Katahira(1982) study and oral RfD computations.
Male SD rats (11-12/qroup) were exposed to o~ 100, 200, 1000 .
or 5000 ppm (0, 295, 590,2449, or 14,744 mg/m) 4 hr/day, 5
day/week for .12 weeks. Rats exposed to 100 or 200 ppm had no
etfects other than redness about the eyes and nose. Increased
levels of SGOr, indicative ot liver damage, were observed in the
rats exposed to 1000 ppa. Rats exposed to 5000 ppm had marked
local irritation (edema or opacity ot the cornea, salivation,
discharge or bleeding from the nose), morphologically defined
da~ag~ to the respiratory mucosa, signiticant alterations in blood
counts and blood sugar, increased levels ot SGOT, SGPT, and
bilirubin and eNS ettects (clonic muscle spasms, coma, cataleptoid
posture). The rise in SOOT levels was dose related. Although a
statistically significant increase in SOOT levels in rats exposed
to 200 ppm is indicated in a table presented in the publication,
-------
-------
D.~.:
Subj:
Prom:
'1'0:
II.
u.s. ENVIRONMENTAL PROTECTION AGENCY
. J.P.E. FEDERAL BUILDING
BOSTON, KA 02203
December 21, 1110
Mo~~olo Si~. Feasibili~y S~udy
Maureen R. McClelland, EnviroDmen~al Scientist
Ground Water Managemen~ and Wa~er supply Branch
Roger DUvart, R.P.M.
New Hampshire
I have reviewed the Mottolo Site Feasibility Study and
have the following comments for clarification/revision.
I.
In regards to setting a TCL for tetrahydrafuran: The US
EPA approach to analyzing systemic toxicity data follow
general format set forth by NRC in its description of the
risk assessment process. The determination of the
presence of risk and. potential magnitude is made during
the risk assessment process which consists of hazard
identification, dose response assessment and risk
characterization. .
In general the Rfd is an estimate with uncertaintv
sDannina DerhaDS an order of maanitude of a daily
exposure to the human population including sensitive
subgroups that are likely to be without an appreciable
risk of deleterious effects during a lifetime.
Having been appraised by the risk assessor that a
potential risk exists, the risk manager considers control
options available under existing stat.utes and other
relevant non risk factors (e.g. benefits to be gained and
costs. to be incurred). All of these considerations go
into the determination of a TCL. .
,Therefore, use ofoa conservative, oral Rfd of 2.0 X10'2
o :mg/kg/day calculated with an uncertainty factor of.
i 1,000 (adjusted one order of magnitude) results in a
/ action level of 0.77 mg/l for THF, a level considered to
be protective of public health.
pg.2-12 ...within the EPA acceptable hazard index range
of 1 to 10.
Comments: The EPA does not use a range of 1 to 10 for the hazard
index. EPA policy is a hazard index less than or equal
-------
observed in the two hiqhest exposure levels. There were no chanqes
in relative or absolute organ weights and no histopathological
alterations in the brain, lunqs, liver, spleen, kidneys or femur
were detected in the exposed animals. Thus, the NOAEL for liver
effects is 200 ppm, which is equivalent to an oral dose of. ..22.
mq/kq/day. Application of an uncertainty factor of 10,000 (10 for
use of a subchronic study; 10 for interspecies extrapolation. 10
for intraspecies variability, aDd 10 to account for the limited
database) to the NOAEL yields an oral RfD of 0.002 mq/kq/day.
Conversion factors: 4 hr/24 hr, S day/' day, 0.223 mq/m3 rat
inhalation rate, 0.35 kg ra~ody_w~qht,
0.5 absorption factor (i... 590 ~'Nm :x 4
hr/24 hr x 5 day/' day x 0.223 m /day x
1/0.35 kq x 0.5 - 22.4 mq/kq/day.
Althouqh, this study did not find definitive evidence of liver
damage, other studies have shown that the liver is a tarqet orqan.
Katahira (1982) cites that other studies have reported liver damage
in cats and rats followinq inhalation, intravenous, or
intramedullary injection (Lehmann and Flury, 1943;.Okhumra, 1958;
JOchmann, 1961).
,.. ....",,1)'; 1-'-"
. f" I'
Liver effects (centrilobular CYtomeqaly) were observed in mice
exposed to 5000 ppm THF 6 hr/day, 5 day/week for 13 ~eeks. Liver
effects were not observed in rats in this study; however,
acanthosis and supportive inflammation of the forestomach was
observed in rats exposed to 5000 ppm (Grumbien, 1988)
critical Studies:
Katahira, T. 1982. [Experimental studies on the toxicity of
tetrahydrofuran]. Osaka Shiritsu Daugaku Igaku Zasshi 31;221-239.
(J~panese)
Grumbein, S. 1988. 13-Week subchronic toxicity test by inhalation
of tetrahydrofuran in Fisher 344 rats and B6C3F1 mice. Patholoqy
Workinq Group Chairperson's Report~ Submitted to National
Toxicol~ Program, Re..arch Trianqle Park, NC.
Plea...not. ~~ the number derived is an interim number and'
ECAO is ...Jd.ng further review of this assessment. We will forward
any additional".'information to you a8 800n as it i. available.
Should yoa-d..1r. any additional information, do not hesitate to
call m. .~.7TB 684-7300 .
cc:
C. DeRosa (ECAO-Cin)
s. Lavin.on (Region I)
B. Mean. (OS-230)
. T. O'Bryan (OS-230)
S. Sokol (Balson Environmental
-------
State of New Hampshire
DEPARTMENT OF ENVIRONME?\."TAI.. SERVICES,
\\~E MANAGEM,,:NT DIVISION
e H~en tmYt:, Cos1(.C)rd. NH o.1.101-66OQ
6U3-271.2900
TTYITD1> 225-41~4
ROBEJr'J' W. VARNEY
CQMNISSIOIfP
PinUP J. 0'8~. PH'I
UlucroR
september 9, 1991
M1CHAEL A. SilLS. Ph.D.. P.E.
CllIU El4
-------
UPBIIDJ:% .
-------
- -
7
15:24
-------
ldI5IiI
O.oundwaler
Oround.aler
, ,O.ound.aler
O.ound.,ale.
Surface Waler
Surface Waler
Reqlllnmeni
Sial" . Nil ItnilCd Sialulel
0I.48S
Drinkina Wiler Si8ndard8
SII18 - ENV-WI410.QS
Oround.ller ProIeclion
Stancluda
SllIe - I!NV-W.-410.05(e)
Siale - Adnain. Code PI" '
WS 315-319 Primary uad
Scc:ondary Sianda....
Pederal . CW A - Ambient
Waler QuaUly Crileria
(A WQC) . Proteclion of
Fn:sh.ller Aquatic LiCe,
Iluman Henllh, fish
ConlUinpiion
51 lie - RS}.485A:8 NH Admin.
Code ENV-WI Pan 432
Surf8Ce Wal.c. QuIUIJ
Sluacluds
ClIEMICAL-SPECIFIC
ARAR.. CRITERIA. ADVJSORms AND OI)lDANCI!
~
Relevanl
and
Approprial.
To be
COIUIidered
To be
COfI8idcr.d
Relevanl
and
Approprille
Relevanl
and
Approprille
Applicable
Re~al Synqpsl.
Sell Conh procedurel ror proCeclion or drinkina .
.aler supplica by ealabUshing and adoptinl :
(under RSA S41-A) drinkinl .,aler I\Ile. and primUJ
drink.inl waler slancluda. SllIUIe allO aUowl
eccondary drinkinl .aler rule. 10 be adopted
which are RCCClIU'f 10 plOlecllhe pubUc welrare.
Muimum Conlanunant Levell (Ma..) which are
e'lablishcd under lhil IllIule shaD be no lell
.Irinlenllhan the moll recenl Nalional Primary
Drinkina W..er Siandarda whicb are in effecl. .
Allowable limlll for conlaminanll
in pourodWllcr ani bued upon Ne. Hunpahire
Divilion or PubUc Healrb Scmc:ea (health-baled
8Iandarda) uad Pederal Ma.., MCWI and
other relevual .anclud.. OroundWllcr
nondepacbtion requiremenlllnc:orporlle the lurface
.lIe. qualilY ..andarda at BNV-WI 432.
Stipulation Ihll poundwat.cr .haD nol contain
any .ubll8flce ia . conc:eDlnliorr which the
W.ler Suppl, and PoDution Conlrol Conamillion
delerminel it harmCul 10 humui heallh 0. the
environmenl. RcplatiOft ..lie. th.. Primary
(hClhh-bucd) Muimum Conlaminanl Levell (MCLa)
will be uacd 1o replale pound.ller contaminanl"
Nfl Ma.. Clilbl.iah levell or cOftlaminanl1
allowable in . .alcr IUppli", 111cy are
aeneralJy equivalcnt 1o SDW A MCLa.
A WQC are developed under the Cean Wiler Acl
(CW A) u pidclinCl Crona which 8111.. develop
wiler qualilJ .aradarda. A mORl 8Iriasent A WQC
for aquatic life may be round relevant and
appropriale rllhcr lhan an Me., when proCection
oC aqullic wsw8IDIl. beinS conaidcred at a
lile.
Surf8Ce w.ler clanificalion 8Iancluda for
Clu. B water8, rand poIcntiaU7 aa.. A WIle",
arc applicable 10 the aile. Ne. Hampshire
Surface Waler QullilJ atancIud8 are IIKnliaUy
the aune u federal unbienl water .,alil1 crileriL
C:
Aclion 10 be
Taken 10 Ahlin Re\piremmt
O~wat.cr .. and be)'ODd Ibo painl of
compI.ioncc will a!laJn SI8tO MCI..I al the
completion ol tbe remedy, Tbcse levc:ls will
be obtained by Ibc C8phUe IDd lrcahDeni of
ICIICb8Ie ClDlll8lifIJ: fnxa Ibo 18fldfi1l IDd
cnnl8mi08Ied groui1dwalcr Ia Ibo aaulhem
plume. In Ibe C8S1CrD plume. poundwat.cr will
reacb MCLI through 081"" lacnU8lioa wllbln
5 10 7 )'C8I8.
Stale grouDdwafer pmfeCdon I88Dd8'dI will be
llllined .. IDd beyond tbo painl of aompIlaac:e
II tbo c:ompIedon ollbe remedy. In 8ddI11oa.
anyllatmenl system wbk:I1 discharges InfO
aurflCiO wat.crs IDd any aaivilles ooaductcd In
lhe wetlands will be mnsiSlenl with Ibo
malDIeDaooe 01' Improvemenl ol groundw8Ier
quaUIJ al IDd beyond tbo poiat of CiOIDpl18DCIO.
Slate JIOUDdwat.cr pmfeCdon II80dardI will be
anaIncd .. 8Dd beyond tbo painl of caDpllaac:e
II the compIedGD ollbe remedy. In Iddilioa,
any Ire8lmeDlIJllem wbIcb disc:barges InfO
SUrflCiO walell and anJ activities conducted In
lhe wedands will be c:onsIsIenl wilh the
malDleaanc:c 01' Improvemenl ol groundwaler
qualilJ al and beyond the point of CXIIDpiianc:c.
AI lhe oompIealoo of tbo remedy stale 'MCU
will be mel al and be)'ODCllbc poinl of
compliance.
Any trealed wafer dJacbaraed InlO Ibe CodIem
River or the wellands IUIroUnding tbe slle
muse IDtCl A WQCs.
Disdwges InfO the Cocheco River and
wetlands from Ibe Ire8lmenl .ystems will meel
the fD08I llringenl afl.cria associated willi the
dassificaliOOl ollhese WIler bodiea. In
Iddldoo, all remedial "Mia will be
mnallleni wilh potecd.. the aau A walen
-------
, ,
ClEMICAL-smCIFIC .
ARAb. CRlI'mUA. ...nVW1RIRS AND GumANCB
. Aclion 10 be
Mdi.I Re"Jlremem S1IbII Requiremenl SynOpti. Taken 10 Anain Req,uiremenl
Groundwaler Federal - SDW A- Malmum Relevanl Sianda;.b; (abbrevlaled u MCLI - Groundwater aI and beyond the poInl of
Conlaminant Lenll (MCI..a) and Maximum Conlammanl Level.). whic:h compliance will altaln MCu 81 the c::ompIetlon
(40 CFR 141.11-141.16) Appropri... have been adopted a. enforceable. of lhe remedy. These levels will be obtained
'Iandudl for pubUc: drinking waler . by lbe capture end bellmenl of leachale
I)'stem.. emanellng from Ibe landfill end contamineled
groundwater In lhe southern plume. Inlbe
eastern plume, groundwater will reach MCLs
Ihrough natural attenuation within 5 10 7 yeers.
NOIe lhalthe SDWA MCL for usenlc In lhe
groundwaler bas been delermlned 10 be
relCMInl bUI DOl approprillte and therefore Is
DOl en ARAR. Instead, the RCRA
cona:nlrlltlon limits found al 40 CFR 264.94
will c:onIrOI.
Groundwaler Federal - RCRA Mulmum Relnant Stand""'; (MCLI.M.-!mum Conc:enlrllionl Groundwater 81 and beyond the poInl of
Concenlration Umlla and Umil.), for 14-1oaic compoundJ. Ma.. compliance will altaln MCLs al Ihe mmpletlon
40 CPR Pad 264.94 Appropri... lIave been adopted u put of RCRA of the remedy. These levels will be obtained
poundwller protection lIanduda. The.. by lhe capture and trealmenl of leachate
poundwller protecllon Ilandud. are el1llnaling from the landfill and conlam/nated
equal 10 MCLI ellabllahed under the groundwater In lhe southern plume. In the
National Primuy DrinId:r. Water Standuu, eastern plume, groundwater will reach MCLs
based on 1962 Public He Ib Servlc:c Ihroui!' natural attenuation within 5 10 7 yeers.
Replalion. under Ihe Safe Drinkinl Waler In addition, prior to or during remedial design
Ac:1 (SDW A). EPA and lbe 1118le will determine whether'
background levels of arsenic In lhe
groundwater exceed 50 ppm. If so, the
cleenUj1 standard will be set at background
levels.
Groundwller Federal - SDW A Mnimum To be MCLG..Non-enfon:eable heallh Soal. for At lbe completion of the remedy groundwater
Cunlamin""1 Leyel Goal. Con.ldered public wlter I,..em.. Maximum Conlamin- . al and beyond the painl of compliance will
(40CFR 141.50-141.51) ani Level Goal. (MCLG.) are set at leYell alliin non-zero MCLOs for lbase 1UbIIanc:cs
Ihal would reault in no known or antlciplled whim have no MCL. 1'hese level. will be
Idverse health erfecl. wilh an adequlle oblllnt:d by lhe capture end trealmenl of
mugin of .afel)'. leachate emanating from Ibe landfill and
conlaminaled groundwater In the southern
plume. In the eastern plume, groundwater will
reacb lhese non.zero Mans through natural
-------
"
pmMICAL-Spp.C1FJr. ARARa. CRJ'IERIA. ADVISORIES AND GUIDANCE
t.p!D1A.: OROUNDW ATER
Safe Drinkinl Water Act
Mulmam Coa&amiDut
lAvela (Ma...KuIU
51 .Ie NH Admia. Code WS 302
~nl40 CPR 141
Safe Drinkinl Water Aet
Muimum ConUlllinani
Levc" 00'" (MCLOa (uall)
fedcnl40 CPR ~41
Re.ource C_rntion
and Recove" Act (RCRA)
Maximum Contaminant Leyol8
&!kr.I40 CPR 264.94 (UI..U
DPHS . Ucallh
Ua ':d . OW Standarda
~.!.I .W.H IOoO.5( e }(ulil)
~
Poteo~~~: OIcmic.al. of COMem
V ___II. e Orunlc COl1\flOunda
AccloDe
Beaz.cne
Chloroclhanc
Dichloroclhy\cne
I,I-Dichloroclhylcne
I,2.Dichiorocthanc
Edlylbc~
Methylene Ctloridc
Melbyl Elbyl ~toDC
Melbyllaobutyl KcIollC
Tetnchlorocthylcne
Toluene
Trichloroethylene
1,I,I.Trichioroclbanc
T elrabyclrofunn
Vinyl OIloriclc
J'cid .t BaaclNeulral Eatnctablc O....anica
Anlbnccne
Beozo(a)anlbraecnc
Beozo(l)fluorlftlbraecnc
BelWl(a)py-
Bia (2-clbylbcayl) pblhal8le
ChlJlCnc
Di(ethyllcay\)phlballtc
DiclbylphtballlC
FluonDlbcnc
FluOlCne
Pbcll8Dlhrenc
Pyrcne
lIh1I1a
Antimony
AraeDic
Be"Uium
Cadmium
Qromi8m
Copper'
Cy8Didc
Lead
Merc..,
Nickel
Selenium
Silver
Thallium
Zinc
700
.5
0-
7
7
O.
700
.5
680
.5
\10
3.50
.68
1
-'
7
.5
.5
.5
.5
200
2
d.c)
l,iOOOW
o
200
o
1.54
O~2(1) 0 .003
.50,000
4(') 0 ".
1,800,000
.54
'IOI5(e) ole)
~ 50
1 ,PC)
10 10 .50( UiO)(d)
50 50 50
1,300(1) 1,300(1) -
;::I.) »e~otl» 200
..50
2 2 2
100 100 10
10 50 50
'lJ~e) 0",
. Pr~ MCLO or MCL (1988)(.53 Fa 31.516).
b Lowcat ()bacrved Effeci Level (LOEL).
c Propoacd MCLOa.50 Fa 46936 (NoYembcr 13. 198~). .
d Value ia for Chromium bolb in Irink'" (ID) IIIICI bcJ(l".lcnt (VI) form. Vllue in plfCnlbcac' it for total combined Chromium m and Chromium VL
e Alternative Met. optiona pt'opoacd" Fa 30310 (July 1.5, 1990).
-------
.
ldIsIiJ
Sediment.
Air
Air
Air
Re~ptenl
Pederal . NOAA Technic"
Memorandum NOS ONA ;2
Pederal- CM . N..lonal
Ambient Air Quant,
Siandud. (NAAQS)
(40CFR~.I. 50.12)
Siale . NIl Admin. Code .
I!NV-A:300
Ambient Air Quality
Standanb '
Slate - NIl Admin. Code
ENV-A I300Todc
Air Pollutant.
CIlEMICAI_SPRCIPIC:
ARARs. CRlI'I!RI... ADVISORIES AND GUD>ANCH
aamu
To be
Conlidered
Relevant.
and
Appropriate
Re'evan.'
and
Appropriate
Applicable
Requbement $,...,.i.
Reference do.,. for variou.'conlaminant. in
. sedimenl. and their potential biolosical
effects on biotl exposed to the contaminant..
NAAQS de line level. of primary and 8eCondary
levels for 8ix common air conlaminant.
(sulCur dioxide, particulale maller, cubon
, ftlonoxide, ozone, nitrolen dioxide and lead).
E.llblishe. primary and 8econdary ambient air
level. for eiaN air contaminant.:
. Particulate mailer
. SulCur dioxide
. Carbon monoxide
. Nitropn dioxide
. Ozone
. H)'drocarbon.
. Fluorides
. Lead
Seven of the primary and secondary standard.
CItabli.hed under thi..tate lIandard are
adopted from the Pederal NAAQS.
Establish ambient air limil. for 74 chemical..
These ambient air limit. (AAL.) are level.
at. or below, which ambient air concentration.
of I respective air conlaminanl will not advenel)'
arfect human health.
Aclion to be
Taken to Attain RIq,!ItremllU
All sediments In the drainage swate which
contain IIISCnic: in excess of SO ppm will be
removed from the swate and oonsotldated
under the landfill cap. Measures will be lal
10 prevent contamJnated sediment Crom
"'asbin~ into Ihe Cocheco River during
excavillon. .
The. Best Avail~le Technology will be \ISe(
10 Inuit the elDlssion ~ hazardous airborne
substances during recontourin& excavllion
groundwater treatment 8IId an1 ga ooIlecJOI
and 'reatment. Those chemical-Specific:
II8ndards set out In these regulatIons will be
met by this tec:bnoIogy.
The Best Available Technology will be
employed to ensure thaI air emissions
pncrated by remedial activides comply with
the standards lei out In this reguladon.
Release. of conlaminants to the air
from an)' source on .ill will not exceed
the respeclive AAL.
-------
CHEMICAL-SPECIPIC
~
Natiooal Ambient Air
~~)~~-
40000 (I-bour averap)I3' (I bour avense)
10000 (I-bour averale)9 (I bour averase)
Carboq Monoxide (CO)
Lead (P1!)
I.' (] IIIOnllu)
100 (IMval},'O.o, (IMval)
23' (I-bour),(J.12 (I bovr)
ISO (U-bour)/ NA
SO (lMual)/ NA
Nilrolen Dioxide (NOz) .
-------
pIHMICAL-SPECIFIC
f.RAIla CRI1'ERIA. ADVISORIES AND OUIDAN ~
tfg~'t: SURFACE WATER
CLEANWA'TER CWA\ - WATER DUALITY CRITERIA
For Protection or Anualic Lire
Q1sm.iW
Potential Cheatls:ata
or Concern
Volatile Or,anic Cl>fIIVOunda
Acetooo t
Benzene I
ChloroetbaM
DichloroolbJlclll
1.I.Dic:bl_daJ-
1.2-Dic:bI_1baIII
Elbylbe-
Melbyleoo CIloride
Methyl Ethyl Ke'-
Methyllaob.tyl ~tone
T etnchloroetbylene
Toluene
Trichloroetby\e1l8
1,1.I.Trichloroethane
Telrahydrofuru
Vinyl Chloride
Acid" BuelNe.t"1 E1tractablc Or,anica
Anthracene
Beuo( a)antbraccne
Beuo(a)nuoraathncelll8
Beuo(a)pyrenc
Bi.I{2-ctbylbcxyl) pbdaalatc
Qryacne
Di{etbylhexyl}phlhalate
DielbJlphtbalate
FluorantbcDII
Pluoreoo
Pbenandtrcne
Pyrcne
f!kWt
Antimooy
AncDic:
BcryUiIlJ1l
Cadmium
Chromium
Copper
CyUUde
Lead
Mercury
Nickel
Selenium
Silv"r
Thal,ium
Zinc
a
b
c
d
e
f
II
For Prolection or Human Heallb
Waier and P'l8h
Inlcslion lu"'\
P'18'o~:~tlon
Frcahwat.er Acutel
C}Jronlc. lu""
0.66
0.033
3100
0.94
1400
40
'.300/Jb)
11.600/Jb)
11.8ooI20,ooo-(b)
32,000/Jb)
1.85
243
3.250
0.80
14000
2.7
18000
2
8.85
424.000
80.7
1,030,000
5,280~(b)
17,sOo/Jb)
45.000121.900
2
3~
42
3.98O,Jb)
.
ISO
0.0022
0.0068
17~
8SO/48{b)(c)(e)
0.64/10.32hiW1J>
22/5"
11/.4 iff)
2.4,Q.0 12
363/40(1)
0.25(f),o.12(f)(b)
3O,27
-------
MWt
Wellancb/
Floociplainl/
Riven!
Re8ervoin
Groundwaler
Groundwaler
~
..
LOCA 110N-SPECIFIC ABABa
Recplremenl
PedenJ . 16 USC 661
ea. ae~., Aah ...
Wildlife
. Coordination Act
~
Applicable
Pederal . Gaoundwaler
Pcoteclion Strate"
To be
Con.idcred
Federal. Oaoundwater
CI...ific8llon Ouideline8
To be
Conaidcred
Requlremenl Synogsi.
Require. action. to be taken to avoid .dvene
ef~cc:!., minimize potential hum 10 rub, or
wildlife and 10 pic8erve nalural and beneficial
Ute. of the land. .
Action h) be
Taken 10 Attain !tequiRmcnl
DisdIargca ~ the halJDentlyslem(s) will
be mnduc:ted In SIK b . manner u 10 minimize
Idvcne Impacu on fish 8nd wildlife. Federal
.nd IIIle .gencies listed In Ihis SlalUle should
be ~lled during remedial design If any
Idverse Impacts are anliclpoled.
EP A'. aroundwaler protection lInIelY
I.. idenlifiecl in Groundwaler Proleclion
~". EPA Office of Groundwaler
Proleclion, Aupt, 19841, include.
Ihe foUowinl com.--.enll:
8I.'e.
. AlSellinllhc problem. Ih.1 may exi'l
from unaddre..ed lOUR:e. of conlamina.
tion-in particular,Inkinl8l0np
tanb, IUdlCe impoundmenl', and
landfall,:
Groundwater at and beyond the poInl of
compliance will be restored 10 ilS beneficial
use by tbc remedy through. oomblnalion or
capping. leachale CXJIleclion IDd trealment,
nalunl attenuation In the easlem plume and
the cdleaion and lnatment of (X)Dtaminaled
groundw8ter In the southern plume.
. blUing guideline. for EPA deci.ioo.
arfcclina aroundwaaer pcotcclion and
cleanup: ancl8lRnglhenini EPA'. .
oraanizalioo for aroundwarer manage-
men. al lhe heacilluarten and resional
levels, anclatn:ngtheninl EPA'.
coopenlion with Pederal and Slate
agenc:ieL
Clu,ifie, pounclwater by il' potential
beneficial ulCllUCh a. apecial poundwaler
(Clu, I) which arc around waren Ihat are
-highly vulnerable 10 conlamination
becaUIC of .he hyclrological chanc:lelillic:.
of Ihe are... in which il occ:un, and
characlerized by either of the foUowinl
fac.ors:
These guidelines will be consulted In
evaluating the suazas of the remedy and lhe
speed with which groundwaler is cleaned up.
. The ground...er i. irreplace.ble: no
reuonahle allemalive IOUJCe or drinking
w.ler i. nailable 10 .ub.lanlial popula-
.ic)ft..
. The groundWaier Is ecalopcall)' .i.aI: the
aquiler provide. the base now ror a part-
icularly sen,itive ecological ,)','em Ih.,. .
-------
tOCA nON-SPECIFIC ARARI
~ RCcPremenl ~y~qplil AClion 10 be
~"Uement ~ Tatcn to Attain Requiremenl
Wedlncb/ Feclenl . Cle.. Water Act Applicable Rcquirementl under thele codel prohibit The subsllnd1le wetland dredge and fill
Floodplain., (CW A) Section 404: 40 CPR !he dilChar. of drcdacd or rdl malcrial into requirements of the CWA will be met in all
R!verl/ . Put 230-33 CPR Put. water bodie. or wetlancb without complyina with activilira In and around the wetlands. No iii
Re8Crvoir. 320-330 the proc:cdulelldcnlified under !he pcrmiltina malerlal from the I'eCX)fJlOuring of the Landfi
lequirement. for thil code.' from the construction of !he Inlerceptor
lrenchlexttaalon well system, or from Ihe
construction of the leacbate trealmCftt planl
will be placed In the wetlands surrounding Ii
site. In addition, construction and malnlenanl
of the off.site groundwater treatment
system/extraction wells will be cmduc:ted 10
have !he most limited Impact on the wetland
All material dug from the wetlands will be
tested to determine whether It contains RCR.
wastes; If so, that material will be disposed .
In aaxxdance with RCM requirements
Induding the land ban regulations. That cle:
fill which is not redeposited In Ihe exmvalio
will not be deposited In the wetlands.
Wetlands will be restored to their natural SID
8t !he completion of the remedy, 10 !he extel
technically practicable. Neither the procedura
or permitting requirements of !his statule nee
to be met.
W ctlancb/ Feclenl !hcc:ullv. Order. Applicable Federal agencies are required to preserve and Measures to mitigate damage 10 the wetlands
Floodplain., 11988 A 11990 enhance !he natural and beneficial values of will be employed at all times during the
Riven! Floodplain Manlscment wctlands and Ooodplains. construction and operation of the remedy.
Relervoin and Protcction of Wedlftcb A~ter the construction of the management of
Federal. .0 CFR Part 6 migration elemenl of Ihe remedy, measures
Appendix A wIll be underl8un to restore !he wellands.
Wedln.isl Federal - General Facilitl Relevant New treatment. lIorlse or di8posll of
Floodplain., Slan.tucb .0 CPR 264.1 (I) and hazanioul wlste prohibited with 200 fcct Any groundwatcrllcachale trealment facility
River" . Sehmlc Standu.b Appropriate of I fAult which hu hid I displaccmcnt will be localed in aa:ordance wilh Ihis
RelCrvoir. in Holocene time. re(J"irement.
WetJlntb/ Fedenl . General FacUi~ Relevant Flcility whele RCRA hu.ardous ....Sle will Any groundwaterlleachate treatmenl facility, iJ
Ploodplain" Stanclarcb 40CFR 264.1 (b) and be lleatcd, lIored or di8pOSed of thai lie.
River" APPropriate within I 100 year Ooodplain mUlt be . located In a floodplain, will be designed and
Reservoirs dc.igned, conllJuc:tcd. opcmcd and maintained constructed In acaxdance with these
to plevent lhe wuhout of an)' huarclou. wute regulations.
-------
Requirement
FEDERAL. RellA 40 CPR Secli.)us
264.90-264.101.
(Subpart F) Releucs from Solid
Wastc Maoagcmco\ UoilS.
Idcntifies procedures 10 be
fonowed 10 ensure thai
arouodwater siaoduds are mel.
FEDERAL.RCRA40CPRSe~oDS
264.110 - 264.120.
(Subpan G)
Closure aDd POSI Closure
Requircments for closure/pOsI
closure of . landfill.
Groundwaler mooiloriaa aod
reporting requiremeolS
for a pcriod of 30 ycars .
hom the date of closure.
SWIll
RelevlDl .
aDd
Appropriate
RelevlDt
aocI
Appropriale
~C110N-SPBCIFIC ARARs
l\eqJJiremenl SynopsiJ
"Ocoeral facility rcquiremealS for
,roundwater monitoria, al atreCied
facUities and geocral R:quUcmeDlS
for comelive acUoo ,roJ.rams if
rcquiJed 81 regulated facilities.
."
Sets general scandards lor doslllliandfilis.
Requirca OWDC~ora of Iaodfilla 10
dcvcIq» dosure and poIt-do5ure plans. la
8ddilioa. die reguillions sea for1b pasa.c:Josurc
rcquIrelDCllll such as pouadwalcr moailOrina
for . period of 30 1C8D aflcr dosure.
.
Action to be
Talc.en 10 AII~\I. ~
'A CXXDJftbcDSlw ~,JUDdwata noaIludn.
IJIICIDo dcllpecilO Jctcd 8i1li !JIC8RlnI
poundW8!cr CDOIIIniDldoo 11 I 1d beyond Ibe
poUd of compIi8IIct.. will meet Iho subslandvc
IIIndardl ollhis reguladoo.
Implementation of this alternative
would comply with the requirements
of this allernative in the foUow-
in, maune..:
. Dalp oflbl cap wUl minimize Ihe aced for
fUlUlO lllliatenanCiO.
. ~.in, &be LaodfiU would
muwruzo 10 the exleol
necessary 10 proteci bumao
bealth and envlronmenl from
pbysical exposure to the
wasles oQ-sile and continued
fuguitive air emissions from
lbe Landnu. Also.
construction of \be cap would
mioimize fulUre oo-site
maintenance.
. Collectioo and lre;:.unenl of \be
c
-------
LOCA 110N-SPBCIFIC. ARAR.
Action to be
MdiJ Requirement S1IbII Requirement S,nqpli. Taken to Anun Requirement
Wellands' St.le - RSA 482-A AppUc.ble Sets general standards and criteria 'Cor filling, Any remedial Ictivldes affecting tbe wetlands
Floodplains! NH Admin. Code dredging and construction In or near wctlands. will meet the subsllntive requirements of tbis
Rivers! BNV. Wt JOe) Sllte Statute Ind Its related regulations.
Reservoir. New Hampshire Criteria
and Condition. for P"tU
and Drcdsinlln Wetl_d.
Wetlands! Stile. ENV-W. Part Relevant Controls actlvltlca wblcb Invlave dredging In An, dredging or filling activities affecting the
Floodplain., .. U. RSA "":A-11 and or around surlace water bodies. Belilmy Reservoir or tho CochcCo River,
Rivers! NH Rule. Relative to Appropriate Indudlnathe dredging 01 the sediments In the
Reservoir. Prevention of Pollution lwale, must meet the substantive requirements
from Dredpa. FUlinl. of tbls regulation.
Mlnina. Tnnsponlna.
Con.truction
Groundwater State. WeUhcad Tobc Sets general criteria for wellhead protection Stile Plan wiU be con.idered
Protection P,oarun Con.idered area delineation and Idcntlfiauion of to procectlhc Calderwood weU.
coollm1nalioa sources to be exduded from
protCClion areas.
-------
ReQuirem~n,
fEDERAL. RCRA 40 CPR Pan 264'.1(J
. 264.77 CSubpU\ I!)
Mwfest System. Rcconlkeepia,
~ ReporuGI
FEDERAL. RCRA .40 CPR Pan 264.10-
264,18 (Subp'an 8)
Gener.LI Facility Standards
FEDERAL - RCRA 40 CFR
Pan 264.30-31 (Subpan q
Preparedoess and Prevenlioo
FEDERAL. RCRA 40 CPR Pan 264.50.
264.S6 (Subpan D)
Coolingeocy Plm and Emc:rgeocy
Procedures
~'
RclcvlDl
IDd .'
ApproprillO
ReIeYul
8Dd
AJIpropdale
Relevanl
IDd
Appropriate
Relevanl
and.
Appropriate
ACI10N-SPECIFIC ARARs
Reqpiremen~ Synopsis
ReauJadoas apply to OWDera aDd
opcratOI1 01 boIb oo-site aod
off-site lacililies. RcquiRmcOl
ideoufies procedures to be foUoweel
io fiUial ouI. filia, aDd submit-
tios bazardous waste manif~u for
aU abJpmeau 01 bawdous WlStC
scot from aDd R"iveel by 8 fac:illty.
'Ibis subpart applica 10 all OWfleq
and opcratol1 otbuardous WlSte
facWlies. 1be subpU1 idealifies
procedures wbleb mUSI be foUoweel
for tbc operadoa aod maiateoan"
of. bazardous WlSle 1'80 fadlily.
Gcaeral lieU coveRd UDder Ibis
lubpart ue:
. Security Rquiremcatl for TSD
1.ci1ilies.
. GeaerailacWly iDspecuoo
rcquirelDeau.
. PclSoooe1 tniaioC rcquircnaeDU.
. Proccdun:s 10 pRveal mixiD, of
iDcompadblc WISIes.
. SiliaS rcquiRmcau for 8 TSD fIc1lity.
ldealifies Rqu1rcmcau wbleb mUSI
be met durio, ciesla... c:oasb1lcCioa,
IDd opcradoa of 1'80 fadlidea
10 miaimize possibWty of wea,
explosions or ur&p!aaaed relcases
01 WlSle.
ldeotifics &be requiremCDtl wbleb
must be addres&ed iD . coo&iA,eocy
, plan. I!Icb TSO laciliry must bavo
. cootiageoc:y pllD wbieb iclcadOCl
aU procedun:s 10 be loUowcd fa tbe
cvcDt 01 fiR, explosioo or a plaDDCd
release from . lacilily.
<.:
Aaioo 10 be
Taken 10 Allain ~eqJIiRm!:UJ
"
AU baardous IDIIcriaIs gencnled b;' &be
treabDCIJt SJSICIDS or 'bot SPOU' UD( ,m:red by
rCCXlllIOurina. IIIUII be eveJuatcd, rDlHiCes&ed,
pacbpd, labdcd 8nd rCtOrdcd 10 8'1COfdanc:c
willi dac:sc rcguladOOl prior 10 sbipn.eol off.
site. "
001, dao pordoaa oIlbia subput 8ddrcssI0g
1eaIrIIJ, IDSpOCIioo, pmsooacl balain.. &ad
prealudcIIII for bIDdiaJ iaaxapadblc WIStCa
are IdcvIaI &ad appropdMo 10 ibis remed,.
All slle opcmioaa, iadudiog dJc coastruaioa
.ad opeIIIioa oIlbc lrealmcDi facilities will
comply with tho lUbsIaaIivc requJremcalS of
Ibcsc pordOOI of 1Iti. subpart.
All site cpi:radoas. laduclog dJc aJnSlnJetioa
&ad apendoa of tho IIaIIDCDt fldllti~ wiD
be underIakca 001, Ifter Ibc IUbstaadve
provIIioas of tho prqIIftdacss and prcvcaaloo
regutlllons Ire In pl8CO.
A coodaJCllC1 plan will be dcvdopcd and
Implcmelllcd for tbo opcnIdoa oflbc treatment
facilldes. for an, rCCXJalOWing ectivltics, and
ffX all ocher rcmcdJai aaivl&ies. All oo-silc
. activities will compI, with all emergency plans
-------
.-.-..---
AC'I10N.SPECfFlC ARAR!
ReqIJiremell1
FEDERAL.RCRA40CFRSecdom
264.190.198
(Subpart J) .
Requilemeocs lor dae dcsil'"
loslallaaon aad operatioD of
any tanks or IIOt syslems
which are used 10 siore or .
ueal bazardous liquids or
sludles.
&aIuI
Req,tiremenl Synopsis
RepalCa laDies ~ lank Iystems which are. 10
be used 10 lem~nriJy &lore '.
bazardous liqwdl or II pan 0(.
lrellmeot syslem (or baZanlous
Uquidl or Ilud.es mUSI bC cleslpcd,
IDSlaUed IDd operated In ICCOrdaac:e
witb Ibe RCRA Siandards.
ActiOD 10 be
Taken 10 Allain Reqpbemenl
ReilevlDl
aad
Appropriale
T8Db or IIDIt Iystems I8ed 10 tcmporIrily
lien bIzardoua malertals IhaC be"" been
JCI1CI'IICd by silO balmeDl lystCIIII or
UIICOVcred u 'bot apoca' durin, fOCOOIOUdna.
will meet llllUbIIInlive requirements oflhese
reaulalioaa.
FEDERAL.RCRA40CFRSe~oDS Relev8D1 Oeaeral RquiremeDlS for surfac:e II surface 'fIIP""~nts arc used to
lempnriIyllonl 'llot 1pOI' materials.
264.220 .264.230 aad Impouodmeats. RequiremeDts ioc;lude treatment sludaes. or lrealmeDl fillers. then
(Subpart K) Appropriate dcSif'» -slaadanls. operatiooal. Ibae ImJlOUQClnlenla will comply wlib 811
Design, operation aad closure reqwremeals, mODilorioS aad ~rd substanllve provisions oflbae reguiadOOi,
01 surface impoundmenlS. keepioa requircmeoas IDd closure Jbosc surface illlpOUlldment regulalloas
requiremeDlS.. rcladnllo doIwe IDd poII4osure canI are
also relcwlll and appopriale 10 the cap design
aDd lcachalo IreaImcDt ponIoda ollbla remedy.
FEDERAL.RCRA40CPRSe~oDS RolevlD. GeoeI1l deslp aod opentioo re. II waste pilea are used 10 lemporarily SIOrc
264.250. 264.259 aad qulremeDtl for:ruy slorap of '.0I1pOI' materials. IreaImcaI sludges. or
trealmenl 81- Ibca Ibese piles will Q)QJpIy
(SUbpU1 L) . Appropriale tiazardous IOU or .Iud.es. willi 811 IUbllanlive provisions ollbese
Design aod operadoD Loc:adoos mUJ( have ID Impenneable rcgulaaiona.
procedures for wastc piles Iioer aod mllerials siored in piles
whicb are used 10 mUI be free of 1IIDdJo, Uqwd.
lemporariJy store bazardous
soils or sludges.
FEDERAL. RCRA 40 CAt Pan 26'1 Relev... Esaablisbca requirements applicable 10 All bazanIoua. materials geaerared by Ibe
lre8tmenllJllClDS or 'bOC SPOCS' unc:oYered by
(Subpart E) .... JCDCnIloo of baz.ardous wasrcs. recooIOurlna. must be'It:SICd, manifested,
srandards Applicable 10 Gcnnarora of Appropda18 plCbaed, labeled and r~ In IICCIDrdanco
Ilazardous Wasac wtlb Ibese teguladOlll prior 10 shipmen. olf.
sile.
FEDI!RAL. RCRA 40 CFR Pan 26J.IO- Relcv8Dt Idcod6es manilcsdDI&;roc:cdun:s OlC.aile ShipmCDts oC bazanlous
263.22 (Subpans A and 8) and 10 be CoUowcd lor all s 'pmCDlS waste or mllcri", wiU be
Slandards Applicable 10 Tramponers of Appropriate o( hazardous waslC. ~ropedy manifcSted aad logled.
nospor1Crs wiD comply with
-------
Reqpiremenl
FEDERAL. CW A 40 CFR
. Pan i2i; i24, 125
Naliooal PoUulanl
Discbargc Elimination Systcm
FEDERAL. CW A 40 CPR Part 403
EP A PRueaunena Siandards
SWUa
ReJcvaaa
8DcI
Appropiaae
RclcYIDI
IDd
Appropdale
ACI10N.spenPiC ARAb
RecaJ1ircmcQJ Syaopsls
NPDES Is Ibe aadoaal program for IasuJna.
maoilOrina. and wordn. pcrmill for dlrocl
dlsdilraes 1Il1o WI- clabo Ualled SIIIacs.
Ocaenl pJdeUael 10 be foUowcd
to calablfsbla. pRUCalmCDI
cfOuCDI dbcbarso Iim1I8 for
poUUIIDIS which wW be d1IcbarJcd
10 a publicly owoed _almcDI wolts.
I:'
.'
Ac:doa 10 be
THea 10 Again Requlrer
-------
gequiremenl
FEDERAL: RCRA 40 CFR Pan 268
Land Disposal Resuiclions .
FEDERAL. RCRA . 40 CPR 264.170 . 178
. (Subpart I) Use .nd Managemenl oC Containers
Ff DERAl.. . RCRA . 40 ( FR 264.1030 .
1036 .... 26U050 . 1064 'Sub""". ..... and
011) . r-- .""
SI...ndards for Air Emission:; for Procc.s..i V<
and Equipc:nlCPl Leaks enlS
FEDERAL CM . NauoDai
AmbicDI Ail Qualiay Siandards
40 CFR Pan SO
FeD :. . CM.... NESHAP
40 C~.. ..I, &b, Ii
SWJIJ
RelevlDl
aDd.
Appropriale
RclCVIIII
and
ApproprialC
Relevant
and
Appropriate
AppUcable
RelevlDl
aDd
Appropriate
-
AC'nON.SPECIFIC ARARI
Recpllremenl Synqpsls
Acdoa 10 be
Taken 10 -'naill Reqpiremenl
Idcadfiel bazudOUI waste Iypes aod
spcci6c SPA baz.ardoul wlSle c:odeI .
wb1c:b must mcelspecified allDCluds
prior 10 p1Kcmeo& or dist: of
Ibe wuac io ,laud uoia. BID
also specifics t:catmelll processes
10 be used 10 mcet aoals.
TbIa requl.remea& II rc1evlDllDd
IpplOpda&e 0011 10 Ibe ex&cDl
&bat Uod BID bazardous malerials
ue discovered OD-siac aod moved
ouwde Ibe area of coolamioalioa.
ADy .boa spor. uncovered duriol
recoo&ouriDS of Ibe laodfiU would
bave to be scllllO ID off.sile
IlCRA TSD Pacility.
If &be waste rails walbiD one of
Ibe rcgullled waste codes UDder tbc
Land BID, &beD &leabaem of &be
w8S1C 10 . point wbe.e Ibo wasle
may be disposed of in ID off.site
RCRA laod disposal UBiI, would be
ocalIUY.
ADy bazardouIaIud&CI 01 wasICI
ICGCraac4 duriD& tbc lI'CallDCOi
of (;O""..I...,,,d jouodwaIU wiD
be aatcd 10 dclenDiDc thaI,,1
lCquilelDCQlJ cstabIisbed uudcr
. tbc Iud baa IClu1aboD III
complied wiab prior 10 1I11off.
aile dispoPl 10 .IlCKA appIO-
Jaod diipoIa1 uaiL
"
Idcatiles requlrcmcnlS for the use and
1D8DIgcmea& of conlaiocn boIdiDS hazardous
substances.
Ant atalners boIdinSllquids wbldJ .re
UIICOVCICCI bJ lCICOIIIouriDg wiD IDCCI Ihc
requlrcmenII of Ibis rcsuladon. 10 addition
101 COOIainers used 10 IlOl'0 Irc8ImcDl aludgcs.
'bot spoI' WUle, or IrCllmcot fillers will mccI
the SIaodards of Ibis regulalion,
1bcsc two IUbparia SCI saaodards ror air
cmissiOBl I'tom trcabDCDI sJSl~
The design and aaainlCII8IICC of .11 c:omponenlS
of the IrcaIDICIII tr-:1CmS will mmply with the
II8Ddards ICI OUt In tbc$o rcguladonA
Maximum primuy and scc:oodUY 24-
bour CooceDtndOOS for pardcuJato
miller.
tdiligaUve meawes 10 Refucc
leDeration of dust or puticulale
malter will be employed duriog aU
lite ICIivi!ies.
Sell NatiooaI r
Cblorldo
111 Standards for Vinyl
ADr oo-s1&e &reIUDeo& proc:esscs
auc:b as air IUippen mUll mecl
8bo IClevllll IIIDdard.
-------
1'"
Requiremenl
SWIu
STATe. He.P CII. 190'
New Hampshire
Hazardous Waste Rules
RelCVIIII
I0Il
AppqIriatc
STATe. He.P CII. 190'.04
Maoifesiinc Requircmenu
AppUcaba.
STATE. He.P CII. 190'.0'
Pactaaiol ADd Labelling
RequiremcDu
AppUcable
STATE. Hc.P Cb. I90S.06
StilPd:uds for Gcner.alors
RelevlDI
IDd
Appropriate
ST ATE. He.P at. I90S;08
SI:and;ards for Owners and
Operalors or Haz;arcJous
Waste Facilides .:
RelevlDI
IDd
Appropriaae
A~ON.SP~CIFIC ARAb
Requiremenf Synqpsis
Oeocral JeCiuiremcots fol' In:atmeol,
..orale aod cI1sposal of bazo.rdoua
W&S1e aad dosure of buanIous
WISIe facUities., . '
Oeocral requiremcDII fol' maalCes&1n8
aod documeoaio, all off-aile
.bipmeou 01 buardOU8 mated....
Ideod6es requiremeDII fol' .
pacUaioI aod IabeWa. of 111
hazardoua maaerials 10 be shipped
off-aile. . - .
0e0craI de6aidoDS IDd requircmeOu
for ~:-a0ll olbazudoul wUlcl.
Ou' proccdwa 10 clcccrmlDe
wbetbcr a pellOD II "eaerator.
DcfiDCI ~uiremcou lor oblaiDio,
.,eoenaor .ID Dumber 8Dd record.
kecpiDJ proc:cdaala wbleb mUSI be
loUowcd.
Ocaeral requiremCGIS 101' OWDCII
or opcrlloa 01 bazudoua Wasil .
.ito OIlreallneO& (aeWdea.
. kequiremCDII iDdude:
. Security measurcalo miaimizo
acc:w 10 &be (acUity or aile.
. Traiaial requlremcou for
employ", .1 &be 'b.
. Dcaip lCaDdarcb for bazardous
WasllllabDeo& facWdca.
..
c .
AcdOD 10 be
Tahn 10 An,in Reqpq. ms:.a1
Site .cdvidea wUI.occc lilt:; Ib-
IlaDtivo .Iaaduda .01 out in
Ibcse repJadoas.
My off..ile abipmrd otbaz;.rdous
WISIe will be mlaifesacd iD
accordaoce wicb Ibcso requiRmcou.
ADy bazudous WISIe :'lpcd oU.
aile wW be pacbaed
IabcUcd iD ICCOrdaoce with Ibese
rcp181ioaa. .
'Jbae SIIIId8rds .. mCYaDI to all 'boIlpOt'
W8SICS UIICIOVCJCd durlaa recontourina and all
. sludges and filcers JCGCr81ed by tbo treatment
flCilidcs. The subllaative requiremenlS .of Ibis
reJUlaciOll wiD bo followed In bandlinlo .
ldenlifyia.. lrIDSpOrdaa and disposina ollhcse
wlSlCS.
All ICIDCdiaI II:dvldea wiD comply wilb Ibe
IUbslaadve povisiCD 01 8IaIC bazardous waste
reJUlIlioaL U 8DJ 8IIIc 5IaadanIa under Ibis
reJUlalioa Its more llringcal tb8a RCRA
IIaadIrds, .!beD Ibo marc sariaJCDIIIate
IIaad8rd wiD CIIIIcroI. Sioco IbIa reauJadoa
addressca lid IaaIqaa!CS by relcraa many
oIlbo RatA bazudous waste reJUl8lions. see
Ibe 8CIions 10 be Iaba for specific RCRA
-------
AcnON.SP~CIFlC ARAR$
AaiOQ to be
Req...iremenl awu Req,.lremcot ~yuopsls Taken 10 An:tin ReqJlIn:menl
FEDERAL. DOT 4~ CFR Pan 107 AppUc:ab1o Ilequlnmcau for bIad11o..r..Iabc1Uo.. Huudoua WUICIpoen&ed fIom
49 CFR Pans 171-11!» mul1fudol aDd IllDlpo I Ibe oo-sile TSD facility or flom
Depanmcoc olTransponauoo bazardous wlSto. ~a:.iIBOII. CDCOunaeled duriollbo
Reguladoo for Transpon of ICcoatouriol wUI be
Hazardous Malerials shipped ol(-sile. These ol(-sito
shipmcots wiU comply with
baodliog, labeUia" pacbgio..
and InDSpon n:quircmeots covered
by "1hiJ ICgulauoo.
FEDERAL. erA Guidance Manual To be ProYida tecbokal pidaoce on Ibo Discbarles 10 Ibe local POTW wID
on the Developmenl and Coasidered dcvelopmeaa ofloedlimiu. EPA', meelthe appUcablo limits imed
Implemeolalion o( Local 0e0eraI PretrcallDeo& RcluladoDl OD discbules 10 the sewcr sy lem.
Dischargc Limilalions Under Ibc require the esllbUsbmeDl o( loed
Pretn:aunem Program limits (or POTW, with CedenUy
(December. 1987) approved pRlRalJDeDl propama.
FEDERAL. Pcnnit Applic;aoll Tobo GuidellDes for detcnoiaiD,the ; Tbo IUbslaDlivl n:quiremcall idead-
Guidancc Manual for thc Coasidercd aec:cssuy requin:mcots lad slaaduds Oed in IbiI pidaace,lS aeceuary
"General Facilily Siandards 01 whieb . proposed ReM facility mull 10 obtain a pennil. wUI be
40 CFR 264 (SW.968, Ocaober (983) meet prior 10 the (acility obtain- addn:sscd by Ibis altenwive bUI
101 aa openUo, permiL a {»CIIDi1 aced pOI be obtaiacd
poor 10 CODSlNcUOD and
opendOQ of Ibis facility.
FEDERAL. Guidance Manual for To be Provides iatormatioa aec:essllry for Guidaacc wUI be used 10 evaluatc
POTW Pretrcaunenl Prognun Considered local POTW.IO develop approved wbether site-pocnacd WlSte water
Dcyclopmenl (Oct. 1983) pn:-beaImePI propam. Tbc maaual is compatible with the local POTW.
dcliDcllCa wbat da&a aad iafonnadOQ DiscIwges 10 Dover POTW wUI
must be submilted 10 I!P A in order meet appUcable pre-lreallDeot
10 obtain n:lulalory approval 01 requirements.
-------
Reqllirem~nl
STATE. He.P Cb. I90S.08(d)(6)
I.b .
Moniloring 01 HUiU'dous WUle
Trealmenl Filc~liliCi
ST A TI! . Hc.P Cb. 1905.08(0
(2)(1)
Additional Tccbnical Siaodards
. . Trcaamcol Siaodards
STATE.. Hc.P Cb. 1905.08
(i)(1Xc) Slonac Sianduds
SWuJ
R.elevlDl
and
Appropriaac
R.clcvlDl
and
AppropriaIC
Applicable
AC'tI0N.SPI!CIJIIC ARAb
Recpdremeol Syoqpsls
Requircmeau for IDstauIliOD &ad
operalioa of ODe or more or &he
10UowiD, mODilwl .yltcmI:
. OrouadWiler momcoriD, DCIWOrt.
. Air eaUsaloo mODiloriDa aecwork.
. Ulcblte moDiloria, DelWoR.
Oeoenl 8eqWrcmeau for IClccdoD
of IlUDDeIllIDCIbodI. TIUllDCDI
. mcIbod mUll ~pUab ODe or more
.of die foUowiD, objcc:dva:
. ReDder Ibe wUIO aoo-bazardous:
. Reader Ibe Wille nee fOl'
baadIia. aad InDSpOrI;
. Make &be WUIe IIDCDlble for
recovcry or reuse;
. Reader Ibe WIlle more ameaable
10 10o'-lenD IIOnle or:
. Reduce die volwnc of die b8zardous
wute.
e.IlbUabes rcquiremCDilIO cosure
&bat baDdIiD,lDd lIonp ".Iniml~~.
dlD,or 10 bum&D beIItb 8Dd Ibc
CDYUOIUDCDI. .
c
Acdoo 10 be
Taken 10 Allain ReCUlheme'u
"
. Periodic mooilorio,
01 pouadwllci and sudace Wilt r
wiU be lCCIui~ iD ord:r 10
dctenniDc cbID,CI iD silc coodilioas
and Ibe misr~lioo ofabe COOIlm:oanl
. plume. Air moniloriog (or
wortcat bealtb and .alelY wlO be
toodUClCd durioglbcse periodic
mooiloriP, rouads.
Tbcse IIIIe ...... walle IIahDcDI
IIIDdIrdI will peril Ibe acIccdoD ollbe
IrcaImCaIlCdUIoIogy eo be dcaermlual during
rcmedi81 dcsip; Ib8t 8eCbnoIogy will aJIDPIy
willa CIllO or more ollllClo S8aIId8rdt.
My olHile lIOn. of bazanIoua
wlSle w10 be IelDporIfl iD DIIWe
8Dd w10 comply willi III fcderll
8Dd awe IIIDdards. WUIC 001
ercaIcCI oo-aile will be lbippcd
10 ID off-aile RCRA-approved TSD
-------
Requiremenl
Siandards for Ownen and
Operalon of Hazanlous
WastC Facilitics (CoRt'd)
STATE. "e.P Ch. i90S.08(d)(S)
Tr:1nsrer of Ownenhip or
Reiinquishmem or Propeny
Rigbu
swu
Relevaol
aod
Appropriale
.
AC"nON.SPI!CIFIC ARAb
ReqpIremeni Synopsis
. Proc:edwalo be 10Uowcd lor coo.
ductiDlaaalyab 01 wastc 10 be
baodIed or uca,ed II &be .ice.
AcdOD 10 be
TueD 10 Allain ReClJlUemeni
"
. Proeedwa lor wlSlc baodlia,.
1I0nle. aod iaspec;doa.
. Oeaenl dosurc requircmCDII.
. Eoviroomeow aod bcallb .taodards
10 be mel lor ladlily wolba.
. Cooda'e:tao 10 Iddreu
posa1bl0 . COlI or rc1cua
01 COIII-oni"_,,.. CrOlA &be lice.
. Orouadwller moailoriDlleCluiremcolS
10 be lollowed durin, active pORioo
aod dOJUl'O period 0 facililY or
lice.
. Ncceaary aeapoasc &CIioDllo be
Iakca Ia Ibo evCDI 01 a .pilL
. PubUc DOtlfk8lloa pIao.
. Tcdllllc:aI I88IIduda for W8SIO IJCaIDICIII
.f8dUdcs.
. RequIrcmeDIs for aurfacc ImpouMlMlla.
. RoquUcmcota for W8SIO piica.
The ICqu1rcmcOIl ... Peclcnl rcauladooa
40 CFR Parta 264 aad 265 are iocorpor.
ated by refcrcoc:o. .
Require. approval of Slate prior 10
tnDIfer 01 my owoeahip or
opcntioo permil for. bUardoua
waslc lacility. Owocr or opcntor
musl also eosurc thai aU IutuJe .
propctty owocn arc aware ollolDlcr
uses of .lIc aad aoy usoc:illed
problems. .
NUDBS 8bouId be cOlISulled prior 10 Ibo
b8DSCcr of OWDCnbIp of Ibo aile. III Iddidon.
all funue OWDCD must be made aware of lho
WIISIC8 wbk:h remain.. tbe sile and InY
rcsIricdons occasary 10 preserve the Inlegrily
-------
Requirement
SWua
AppUcable
ST A TI! . NH Admio. Code
S~.C.600
NH Dcpartmcot or SafelY
Rules Cor Traospon or.
Hazardoul Matcrials
ST ATe. NH Admin. Code
ENV . W. 410.05
Oroundwalcr ProIcc:Iion
1BC
STATE. ItSA 48S.A:11 and,
. NH Admio. Code ENV.WI
Pans 4)0-431 Surfacc Water
Classificauoo
AppUcablo
STATE. RSA 495.11.:17 aud
NH Admm. Code ENV.W$ 415
TelTaW Allcralion
AppUcable
ACT10N.SPI!CIFIC ARAb
Requirement Synqpsis
IdeodJiea proc:cduael for p~y
IdeotUyioc. baDd1io, aDd abippiD,
huudous matClials. idcadfiea
ootificaUoa &ad mWfcsPS
proccdUJCI wbicb mull be foUowcd.
ProbibitS cliscbarsc of bazudou.
WUIe to pound wiler. or IP,
disc:buS' to pouodwatcr tbat would
result in . viola&ioo or lUfface
walcr quality iD adjaccDl surface
wiled. Also, pouodwaler caaaoI
bo altered 10 U 10 mate II
uaswlablc for driotio&.
Probib111 tbo disposal of WUI... 10
IP, IDIDIIOr IbaI would lower Ihc
qualily of lWface wilei' below Ihe
miobDUID aequIRmcaU of 1II.wfaco
water c:lauUic:adoo.
Establisbel criacria for aDy activily
IbaI sipificaoaJy ailed Ihc lerraia.
.'
\'
Ac:Cioo to bo
Taken to Anain Req,.iremeol
M"I oo-aile bazudouI wUte
wbieb IDUSI be shipped off.sile
wiU be pacbScd,llbeUed and
lhip~ in accordance wilb IbiJ
RquucmcDi.
Slate gromIwala protccdoa SIIndarda will be
attained II aDd beyoDd Ibc pobd of anpIlanc:e
allbc compIcIioa oflbc 1CfDOdJ. Ia addilioa,
all' ballDCIII 'JIIaD wbicb dIscbargcs 1010
awfacc watas aad 801 ac:tividca aJDductod ID
Ibc wcdaods will be consistco. willa Ibc
lDIIiatcoance CII' IIIIpIOVCIDCDI of groundWIIer
quail., at and beyf;IDd Ibc poilll of oompIlaaco.
AlllUncdial ac:tividcs afrcaloS lbe
8fOUIIdwaIcr and surfac:c walcr will be
COIIducIcd 10 U 10 proICICIlbc CISS A walen
ofdJo Bellamy RcaenoIr.
Dllcbargcaloto Iho Cocbec:o River aDd
wetlands flam Ibo IraImcIII SJIIC:mI will mcca
dJo most llrioJCDI aileda associated willi Ibo
dassi6cadons of Ibese WIlIer 'bodies. Ia
addidoa. all remedial ac:tividcs will be
consistCDI willa pIOIecdns tho Cass A walen
of tho Bellamy RcIcnoir.
Criteria ideDlified iD lbi.
reauJalioawWboaddRssecl
durio, recoaIouriD. aod c:appiD.
olllie LaadfiU aad dwioS IP"I
oo-lite coasuuc:doo :tlJdlor
rcmediatioa acdviuu
Midaadvo lDeaswu wiD be em.
ployed 10 mioimbo uapacu 10
Ibo wedaads. Oac:o aU CODSIIuC-
tioa activities bayO bt'U completed
aU Impacted we~ wiD be
ratoRd 10 &heir oriJi.aal .late
01' 80 an:a of equal diJOcasioas
-------
Reqpiremenl
ST A TI! . ItSA 485.A:5 WS PUt 904
SI8Ddanla for Plebeaaneal of
Wale. DiKbarpd 10 Publically
Owaed Tre811H118 WOIks (POTW)
ST A TI! . NH Admin. Code Oalpler
ENV.A 800 TelliD. aocI MoDiloriD,
Proc:edwes
ST ATE . NH Admia. Code Oaapler
ENV-A 900 Owaer or Opel'llor
Obli,aliOOI
SIIIuI
.--.-
AppU~able
Applicable
Applicable
..
AC'I10N.SPF.nFlC ARAb
I '
I
I
I
I
I
Reqpiremelll Synopsis
Adioa 10 be
T*- 10 Anain ReqpiremeDl
Sell genenI pretreahDent IIand8'ds for
di8cblrp 10 . fOTW.
Anl cidlr.. 10 Ibe POIW from lralment
Cacililiea wiD ~1 witb these aenmJ
pretreatmenllt8Dd8rdI . well . 8DJIoc8I
fOTW petrallDeDllI8ndudI.
Iclealifiea procedwa which mUll be
followed (or Ibc 1eSIio. of air
emissiOOl from Italioauy sources.
If Ibe CIIHiIe TSD facility emits
air C'Y'f...in...... appcopriaIe
IeIIios wiD be c:oaduClid 10
deaennioc Ibc levels of tbese
COOIamill...,
0wae1S or operators of sources which
c1iscbarp air poUUIIDIS ia measure.
able levels mUSI relaiD ICCORIa of
Ibc operalion of tile source feed
Iloct iDpuIlO Ibc IOUrce and .n
available emissioD daIa. Section
902 of tile repillion ideoIifies
iosIPeeI (temporary failure of air
pollution equipmeol) wbco Ibc owner
or opel'llor 0110 air poUutaol
discbarJC IOUR:C may be .nowee! 10
temporuily aceed Ibe air disc:buJe
limill esubIisbcd by tile Stale Air
Board. Section 903. of Ibe n:,ulation
require81ha11be owner or operator of
a source which bu bad a complilDCC
Icbedule eslablisbed for lbeir source
(scbedule sel by Slare Air Board to
brio, air disc:barges from source ia
line wi'" permil requiremeots). mUSI
comply wi... Ibe sc:bedule.
ProYided IhIt ell.. 'Indicates !hat poIlutanlS
may be readily C8IaJl8Icd or estimated. reaxds
of air discbar.. from tbe YIrious oo-sile
soun:a will be coIlecIed and mainlained In
accordance with this regulation. Air pollution
control device process upsets will be remrdcd
In ~nce with Ibe appropriate
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UPBlJDJ:Z ..
-------
ftequiremenl
STArn.
NH Admia. Code ENV.Ws 403
Waslewater Di~char&c Permit.
STATE. NH Admin. Code ENV.A
Pan 1002 Fuailivc Dust Control
ST ATE. NH Admin. Code ENV.A
Pan 1204 CODltol 01 VOC
EmissioDS
SWuJ
RelevlDI
aod
Appropriate
Applicable
Rdevanl
8Dd
ApprqIrillO
AcnON-SPP.CIFIC ARARs
ReqJdrement Synqpsls
Acdoa 10 be
Taten 10 AltaiD Requin:ment
Esaabllshcs cffIUCDI mooItodn,lystcm for oil
Industrial wastewater discharges 10 aurfa
wllers and aclS gcneraIltanduds lor
mailll8lnln, water qlllllllJ.
Wbilo DO permllS will be required under Ibeso
reguillioas, dJsdJarge. of water from tho
beatmenl IJIICIDS will meet Ibc general
IUbstantIve II8DdanIs of this reguladoo. Ita
addidoa, III disc:bargea will be moaJlareclln
ac:cordancx: willa Ibis rcgulatioo.
R.equires precaudoos 10 prevenl.
ablte aod COQarol luptive dusl
duria'lpec:ificd acalvities.
indudiD. excavation. coosaruction
aod bulk bauUoS.
Millpdvi IDCIIUreI wiD be IlkeG 10 control
Iugidve dull tdeucd durin, reconlOWin, and
other remedial acdvillca.
Specifics VOC emission coalrol
medaods aod establisbes llaail,doDS
00 VOC em1uioos lor vadOUI
iadusbics.
Any air emilsioos from abc carrd
LaodfilJ or abc 1'8D laciliay .1
be coolroUcd in accocdaDc:e .ilb
cuneot rcqu1remeats. No
emilsiODS of VOC'I above
c:umo'8III011aDdard8 wW
-------
treatment of this contaminant plume. The alternative method for
treating this groundwater evaluated in the Feasibility study, the
construction of an interceptor trench, would have a greater
detrimental impact on the wetlands.
7. There are no alternative sites for establishing an active
management of migration of the southern plume as the plume is
directly under these wetlands.
u
8. The design, construction and operation of these remedial
activities will meet state wetland protection requirements.
Activities in the Floodplain
9. If testing of the swalesediments where the swale meets the
Cocheco River indicate that arsenic levels are above 50 ppm, then
limited manual excavation will be undertaken to remove
contaminated sediments. It is expected that this procedure will.
be conducted manually - without the assistance of heavy equipment
- and that it will take no more than a few days.
10. This limited excavation will have minimal or no short term
adverse impact on the floodplain area and it will have no long
term adverse impacts.
11. The remedial activities in this area will be guided by the
principles set forth in 40 CFR Part 6, Appendix A and Executive
Order 11988, as well as state law protecting floodplains.
Mitigative measures will be taken during the excavation of
sediments in this area to protect the floodplain and its natural
and beneficial uses as well as to prevent contaminants from
washing into the Cocheco River.
12. No practicable alternative exists for meeting the
remediation goals. As documented in the ROD Decision Summary,
EPA has determined the clean-up of arsenic in the swale sediments
is necessary to protect the environment. As documented in the
Administrative Record and in the ROD Decision Summary, arsenic
levels in sediments above 50 ppm pose a threat to the biota in
the area.
13. Other clean-up/capping alternatives evaluated in the
Feasibility study are either ineffective in meeting remediation
goals or will have a greater adverse impact on the floodplains
while a180 providing less protection to the environment in the
long term. .
14. Since the sediments in questions are deposited in a
floodplain area, the action cannot take place outside of the
floodplain.
15. The remedial activities in the floodplain will comply with
-------
STATEMENT OF FINDINGS
CONCERNING REMEDIAL ACTIVITIES
IN WETLANDS AND FLOODPLAIN
1. The remedy chosen for this Site includes excavation and
construction activities in the wetlands to the south of the Site
and may include limited excavation of sediments in the floodplain
at the point where the drainage swale meets the Cocheco River.
Activities in the Wetlands
2. The installation of a groundwater extraction and treatment
system for the management and cleanup of the Site's southern
contaminant plume will require the placement of several
extraction wells as well as the construction of a water transport
system to convey the contaminated water to an on-site treatment
facility. These activities will require that truck access
through the wetlands be secured so that the wells can be drilled
and the .piping can be placed. In addition, these activities will
require drilling and placement of wells in the wetlands and the
excavation of trenches in the wetlands in which the transport
pipes will be placed.
3. The remedial design of this extraction and treatment system
will be guided by the principles set forth in 40 CFR Part 6,
Appendix A and Executive Order 11990, as well as state wetlands
law. The design will minimize the disturbance of the wetlands
and its natural and beneficial uses. Mitigative measures will be
taken during the construction and operation of this system so as
to minimize adverse impacts on the wetlands.
4. A two phase wetland restoration plan will be undertaken, the
first phase commencing at the completion of construction and the
second phase commencing at the completion of the groundwater
treatment. This plan will restore the wetland topography and
vegetation to the extent practicable, or, if necessary, establish
new wetlands of similar size iri a nearby area.
5. The construction of this groundwater extraction system in
the wetlands is the only practicable means for treating the
contaminated groundwater in the southern plume. As documented in
the ROD Decision Summary, groundwater modelling has indicated
that extraction and treatment of this plume are necessary to
attain ARARs at and beyond the point of. compliance in a
reasonable time, as well as to manage the contaminants in the
. short term so that they are prevented from continuing to migrate
towards the Class A waters of the Bellamy Reservoir.
6. Alternative methods for contaminant cleanup in the southern
plume would have a greater impact on the wetlands or would be
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united states
Environmental Protection Agency
Region I
,~
RESPONSIVENESS SUMMARY
,-
. DOVER MUHICIPAL LANDFILL SITE
DOVER, HEW HAMPSHIRE
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Responsiveness Summary
Dover MuniciDal Landfill site
DOVER MUNICIPAL LANDFILL RESPONSIVENESS SUMMARY
PREFACE
The U.S. Environmental Protection Agency (EPA) held a 60-day
comment period from March 26, 1991 to May 24, 1991 to
provide an opportunity for the public to comment on the
Remedial Investigation (RI), the Field Element Study (FES),
the Feasibility study (FS), the Proposed Plan and other
documents developed for the Dover Landfill Superfund site
(the Site) in Dover, New Hampshire. The FS examined and
evaluated various options, called remedial alternatives, to
address contamination at the site. EPA made a preliminary
recommendation of its. Preferred Alternative for site
remediation in the Proposed Plan issued on March 15, 1991,
before the start of the public comment period. All
documents on which the preferred remedy was based were
placed in the Administrative Record for review. The.
Administrative Record is a collection of all the documents
considered by EPA to choose the remedy for the Site. It was
made available at the EPA Records Center at 90 Canal street
in Boston, Massachusetts and at the Dover Public Library, 72
Locust Street, Dover, New Hampshire.
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 the
comments in this document before selecting a final remedial
alternative to address contamination at the Site.
This Responsiveness.summary is organized into the following
sections:
II.
overview of Remedial.Alternative. Considered in.the
. ~e.sibility study and proposed Plan, includinq the
preferred Alternative - This section briefly outlines
the remedial alternatives evaluated in the FS and the
Proposed Plan, including EPA's Preferred Alternative.
site History and Backqround on community Involvement
and Concerns - This section provides a brief site
history and a general overview of community interests
and concerns regarding the site.
I.
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TABLE OF CONTENTS
Section
paqe
Preface.
..................
. . . .
. . . 1
"
I
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED FOR THE DOVER
IAN'DFILL . . . . . . . . . . . . . . . . . . . . . . . . . 2
II
. BACKGROUND ON COMMUNITY INVOLVEMENT ANp CONCERNS. . . . . 3
Si te History. . . . . . . . . . . . . . . . . . . . . . . 3
History of Community Involvement. .' . . . . . . . . 5
III
SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
. . 8
Part I - Citizen Comments . . . . .. . . . . . . . . 6
Part II - Potentially Responsible Party Comments 20
IV REMAINING CONCERNS . . . . . . . . . . . . . . . . 39
Attachment.
A
FORMAL COMMUNITY RELATIONS ACTIVITIES
CONDUCTED TO DATE AT THE DOVER LANDFILL SUPERFUND SITE.
40
B
TRANSCRIPT OF THE APRIL 16, 1991
INFORMAL PUBLIC HEARING. . . .
............
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Responsiveness Summary
Dover Municinal Landfill Site
~/
considered to ad~ress the contaminants of concern and the
media in which they pose a threat. The FS also describes
the criteria EPA used to narrow the range of alternatives to
4 potential source control (SC) remedial alternatives and 4
potential management of migration (MM) remedial
alternatives.
The cleanup plan selected. by EPA to address sit~ .
contamination includes consolidation of the drainage ditch
and drainage swale sediments and recontouring the Landfill
followed by capping with a multi-layer cap and extraction
and treatment of the contaminated groundwater and leachate.
During remedial design, EPA will determine whether the
treated contaminated groundwater will be discharged to the
Cocheco River or Dover Publicly owned Treatment Works
(POTW). The selected remedy also restores contaminated
groundwater at and beyond the point of compliance to cleanup
levels through natural attenuation, in the eastern plume,
and by active extraction and treatment of the contaminated
groundwater in the southern plume. A monitoring program
will be implemented during pre-design to further define the
lateral extent and depth of contamination in the
groundwater. In addition, the cleanup plan will rely on
institutional controls to prevent any use of groundwater
until contaminant concentrations have decreased to safe
levels. A long-term monitoring program will also be
implemented during pre-design and will continue until EPA
determines that the remedy is considered protective. The
estimated net present worth of the remedy is $24.2 million.
All of the remedial alternatives considered for
implementation at this Site can be found in the ROD Decision
Summary, the Proposed Plan and the Feasibility Study.
:[1:. BACltGaomm 011 COIDIUIIITY IIIVOLVBMEIIT un CONCERNS
sit. Hi.tory
The Dover Municipal Landfill is located on a 55-acre parcel
of land on Tolend Road in Dover, New Hampshire, near the
Madbury and Barrington Town lines. The Bellamy Reservoir,
which supplies drinking water for the towns of portsmouth,
Newcastle, Newington, Durham,. Madbury, Greenland and Rye, is
located 2000 feet south of the Site1 and the Calderwood
Well, which supplies drinking water for the City of Dover,
is located approximately 2000 feet northeast of the
Landfill. The Cocheco River is located approximately 500
. feet east of the Landfill.
3
j
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Responsiveness Summary
Dover MuniciDal Landfill Site
III. Summary of Comments Received During the Public Comment
r~riod and BPA Response. - This section summarizes and
provides EPA's responses to the oral and written
comments received from the public during the public
comment period. In Part I, the comments received from
citizens are presented. Part II summarizes comments
received from Potentially Responsible Parties (PRPs).
Remaining Concerns - This section sUmmarizes comments
raised during the public comment period that cannot be
fully addressed at this stage of the Superfund process
but which continue to be of concern during the design
and implementation of EPA's selected remedy for the.
Site. EPA responds to these comments and will address.
these concerns during the Remedial Design and Remedial
Action (RDjRA) phase of the cleanup process.
IV.
In addition, two attachments are included in this
Responsiveness Summary. Attachment A provides a list of the
community participation activities that EPA and the New
Hampshire Department of Environmental Services (NHDES) have
conducted to date at the Site. Attachment B contains a copy
of the transcript from the informal public hearing held on
April 16, 1991 in Dover, New Hampshire. The comments
submitted by the citizens and the PRPs are available in the
Administrative Record.
I.
OVERVIEW OP REMEDIAL ALTERNATIVES CONSIDERED IN THE
PEASIBILITY STUDY AND PROPOSED PLAN
Using information gathered during the Remedial
Investigation, the Field Elements Study and the Risk
Assessments (RI Risk Assessment and FES Supplemental Risk
Assessment), EPA identified several cleanup objectives for
the Site.
The primary cleanup objective is to reduce the risks to
public health and the environment posed by exposure to the
source of contamination onsite and to groundwater
contamination that has already or may in the future migrate
off-site. Cleanup levels for groundwater and sediments are
set at levels that EPA considers to be protective of public
health and the environment.
After identifying the cleanup objectives, EPA developed and
evaluated potential cleanup alternatives, called remedial
alternatives. The FS describes the remedial alternatives
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Responsiveness summary
Dover MuniciDal Landfill site
increased carcinogenic and noncarcinogenic risks to human
health if contaminated groundwater is consumed.
Bi.~orr of comaUDi~y %Dvo1v"8D~
EPA has conducted public meetings and has released fact
sheets and press releases to keep the public informed of
site activities since 1984. In general, community concern
about the Dover Landfill has been relatively low. However,
community interest and concern increased following the
release of EPA's preferred cleanup plan and the issuance of
notice of potential liability for Site cleanup to the City
'of Dover and the Town of Maclbury.
The first public meeting concerning the Dover Municipal
Landfill was held on August 9, 1983. EPA and NHDES jointly
discussed the findings and recommendations of the Remedial
Action Master Plan (RAMP). In December 1984, EPA released
a community relations plan which included a summary of the
Site's history and contamination and described field
activities expected to be conducted at the Site. Also in
December of 1984, NHDES held a public meeting to inform the
citizens about the upcoming activities of the RI/FS. After
the completion of the RI/FS (March 1989), EPA and NHDES held
another,public meeting to discuss the results of sampling at
the Site.
In March 1991, EPA and NHDES made the Administrative Record
of the Site available for public review, released the
Proposed Plan to the public and published a public notice
and brief analysis of the Proposed Plan in Foster's Daily
Democrat. The Proposed Plan was placed in the information
repository at the Dover Public Library.
On March 25, 1991, EPA and NHDES held a meeting to discuss
the FS results, the cleanup alternatives, and the Proposed
Plan. Approximately 50 community members, including local
officials and the news media attended the meeting.
Questions asked or comments 'made at the meeting were related
to the following issues: remedial costs, availability of
Federal and State aid for the City of Dover, rate of plume
migration, landfill cap characteristics, and PRP liability.
Pub1io a8.c~ioD ~o .PA'. Pr8f8rr84 A1~8rDa~iv8
The concerns voiced by citizens, local officials, and PRPs
at the April 16, 1991 public hearing and in the comments
received by EPA relate primarily to the cost of the
Preferred Alternative. community members expressed fear
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Responsiveness Summary
Dover MuniciDa1 Landfill Site
~
The Landfill was in use from 1960 to 1979. Wastes were
disp~sed at the Landfill from both industrial and municipal
sources. Flammable waste was reportedly dispersed across
the .Landfi11 surface and, at times, burned. A trench and
cover method was used durinq most of the Landfill operation
to dispose of the wastes. In September 1977, the New
Hampshire Department of Environmental Services (NHDES)
(formerly the Water Supply and Pollution Control Commission,
or WSPCC) ordered landfill operators to stop acceptinq
chemical waste for disposal. In 1980, the Town of Dover
beqan cappinq procedures to close the Landfill and, in 1982,
the City of Dover and NHDES closed the facility and re-
excavated the firebreak ditch. around the Landfill to
intercept leachate.
In 1977, the Cities of Dover and Portsmouth, alonq with the
NHDES beqan studyinq the Landfill because of its proximity
to public and private water supplies. Study results .
indicated that qround water and surface water in the area of
the Landfill contained elevated concentrations of orqanic
and inorqanic contaminants. Private drinkinq water wells in
the vicinity of the Landfill were found to be contaminated
with volatile orqanic compounds (VOCs). After further
testinq, state officials determined that the source of
qround water contamination was the Dover Municipal Landfill.
In 1981, an alternate water supply was provided for
residents with affected wells. Residences alonq both Glen
Hill and Tolend Roads have also tied onto this water supply
line.
In 1983, the Site was evaluated by the EPA for possible
inclusion on the National Priorities List (NPL). Because of
the concentrations of contaminants present in sediments,
surface water, and qround water, and because of the
contaminants' proximity to drinkinq water sources, the
Landfill was' ranked and placed on the NPL. In 1984, the
NHDES, under a cooperative aqreement with EPA, initiated a
Remedial Investigation (RI) of the Landfill. In 1988, a
group of Potentially Responsible Parties (PRPs) siqned an
Administrative Order by Consent with the EPA to perform a
Field Elements Study (FES), addressinq data qaps of the RI,
and a Feasibility Study (FS).
The RI and the PES confirmed the presence of VOCs and metals
in qroundwater and sediments, and VOCs in the drainaqe ditch
surface water. A risk assessment conducted to evaluate
potential risks to public health the environment revealed
-------
Responsiveness summary
Dover Municioal Landfill site
.
for the implementation of the Preferred
Alternative exceeds the city's $13 million
borrowing limit (City Manager, state Treasurer).
The total cost in capital for the Preferred
Alternative would be $3000 per Dover household
(City Manager).
.
other financial demands on taxpayers currently
include the cost for the water and wastewater
treatment plant, education, fire and police
protection, solid waste disposal, street repair,
and public health services.
cities/towns are being forced to seek less costly
means to achieve goals in a bad economy; it was
requested that EPA do the same (Dover School
Department Representative).
.
.
Businesses do not have enough money to spend on
cleanup. EPA should consider the fiscal impact on
the community as well as the environmental impact.
The cost of cleanup will have a devastatinq effect
on the ability to compete and gain industries in
Dover (Chamber'of Commerce, Economic Commission,
and Dover Industrial Development Authority
representatives).
Area taxpayers and businesses will also be
affected by the costs to remediate the nearby
coakley and Somersworth Landfills. The total
amount of money to clean up all sites was
estimated at $70 million (Town of Madbury's
Attorney).
.
The harm to be caused by the taxes necessary to
fund the Preferred Alternative outweighs the harm
potentially caused by the effects of the
contaminated drinking water (one resid,nt and
former City Council member).
BPA ...Don..:'In selecting the remedy for the Dover Site,
several aspects of the costs associated with this remedy
were evaluated in detail including, among others, the cost-
effectiveness of the remedy when compared with other
alternatives and the total short and long term costs of each
alternative, including the remedy, compared with the level
of protection offered by each alternative. As a result of
.
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Responsiveness Summary
Dover MuniciDal Landfill Site
that because the City of Dover and the Town of Madbury had
\o.-.~- .: ~"~~~r' o;eneral notice of potential liability, that
there would be a substantial increase in taxes. Many of
. these community members argued that an increase in taxes of
the magnitude necessary to pay for the Preferred Alternative
would drive businesses and residents away from the City of
Dover and the Town of Madbury. Most citizens, officials,
and PRPs who commented on the.EPA's Proposed Plan said that
a less costly solution - such as monitoring and
institutional controls - would be sufficient to protect
human health from the threats posed by the site.
other members of the public supported EPA's Proposed Plan,
including the Water Department of the City of Portsmouth,
which draws drinking water from the Bellamy Reservoir.
III. SUMMARY OP PUBLIC COMMENTS AND AGBNCY RESPONSBS
This Responsiveness Summary addresses comments received by
EPA during the public comment period (March 26 to May 24,
1991). Twenty-one individuals (including representatives
from the cities of Dover and Portsmouth and Town of Madbury,
members of the Dover PRP Steering Committee, and area
residents) addressed EPA's Preferred Alternative during the
public hearing. Eight sets of written comments were
received by EPA during the public comment period (including
comments from area residents, the Dover City Manager, a
Dover city Councilman, the Mayor of the City of Dover, the
City of Portsmouth Public Works Department, the Town of
Madbury, and the Dover PRP Group). A citizen's petition was
also received.
Part I - Citi..n8, and Local Officials Comments
Comment 1: The majority of the comments received addressed
the inability of the City of Dover to pay its share of the
proposed $26 million cleanup cost. Twenty-two individuals
commented that the Preferred Alternative would be too.
costly. Each comment emphasized the fact that local
residents and industries are already experiencing economic
difficulties and that the cost .of EPA's Preferred .
Alternative is more than the City's taxpayers could possibly
afford. The following specific issues related to the cost
of remediation were raised by various individuals:
.
The City of Dover has been allocated over 60
percent of the clean-up costs by the PRP Steering
Committee and it's $16 million share of the cost
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Responsiveness summary
Dover MuniciDa1 Landfill site
that cannot be avoided if the EPA is to comply with its
statutory and regulatory mandate - account for a very large
portion of the total .costs.
While the cost-effectiveness of the remedy has been
thoroughly analyzed in the remedy selection process as set
out above, neither the Superfund statute nor applicable
regulations allow the economic climate of southern New
Hampshire or the financial well-being of those who will
ultimately bear the burden of the remedial costs to be a
factor in the selection process. CERCLA's statutory mandate
as well as the strictures of the NCP require that cleanup
standards be established through an analysis of the risk to
- human health and the environment and the applicable or
relevant and appropriate environmental laws. Cleanup levels
are set without regard for who will be named as a
potentially Responsible Party and who will ultimately bear
the costs of remedial action. EPA cannot establish
different cleanup levels, comply with fewer ARARs or select
a less protective remedy at a site as a result of who will
be liable for the cleanup costs.
In this instance, the City of Dover and the Town of Madbury
were issued general notice of potential liability because,
on-EPA's analysis they qualify under CERCLA Section 107 as
generator, transporter, and/or owners/operators with respect
to the site.. EPA has issued 37 notices of potential
liability to Potentially Responsible Parties (PRPs). These
PRPs include local industries, municipalities and
individuals. The liability for the total costs for the
implementation of the selected remedy is joint and several -
that is, all parties are liable for the total costs of the
remedy.
As liability for the cleanup is joint and several, the share
of the costs to be borne by the taxpayers of Dover and
Madbury will depend on any agreement these towns reach with
the other PRPs at the site. The City of Dover has been an
active participant in the PRP steering Committee which
calculated the internal PRP allocation of costs to date.
Comment 2: six individuals questioned why the Preferred
Alternative was selected if the groundwater contaminant
plume already appears to be receding and conditions appear
to be improving as a result of the installation of the cover
material and drainage trench when the Landfill was closed.
Specific related issues raised include the following, listed
~ as comments a,through d.
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Responsiveness Summary
Dover MuniciDal Landfill Site
. these evaluations EPA has determined that the selected
~~~~~y is cost-effective and that it complies with all
statutory and regulatory mandates which address cost-
effectiveness.
It should be noted that while the cost of each remedial
alternative evaluated by EPA was an important factor in
determining a remedy for this Site, cost is neither the only
nor the most important criterion in EPA's analysis. In
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), the National
Contingency Plan (NCP) and related EPA Guidance, cost was
one of a number of factors used to evaluate potential
remedial actions at several stages in the remedy selection
process. First, a large number of technology process
options which could be implemented at the Site were
evaluated for their effectiveness, implementability, and
cost. Secondly, a range of alternatives which combined the
various technology process options to address all media and
contaminants of concern were evaluated on the same three
criteria, including estimated cost. Thirdly, a deta~led
analysis of several select alternatives was undertaken; this
analysis was performed using the nine criteria set out in
the NCP, one of which is cost. (These nine criteria appear
in Section IX of the ROD Decision Summary and at 40 CFR
300.430(e) (9)(iii).) Lastly, the selected remedy - which in
this 'case combined portions of several source control and
management of migration alternatives and which cut more than
$1.6 million from the proposed remedy - was evaluated on the
same nine criteria, including cost.
As to the weight accorded cost-effectiveness in this multi-
staged evaluation, the NCP and related EPA Guidance define
cost as one of five primary balancing criteria to be
considered only after the first two threshold criteria have
been satisfied. Those threshold criteria include overall
protection of the human health and the environment and
compliance with all federal and state laws which are
applicable or relevant and appropriate (ARARs) to this Site.
In essence, any alternative which does not meet these
threshold criteria cannot be selected as the remedy.
In this case the threshold requirem~nt that the remedy meet
all ARARs is particularly significant because ARARs
establish the basic design criteria for major portions of
the remedy, such as the multi-layer cap. For example, the
mUlti-layer cap accounts for approximately 70 percent of the
total costs of the remedy. Thus the threshold costs - those
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Responsiveness summary
Dover MuniciDal Landfill site
leachate and surface water runoff to the Cocheco River. At
certain times of the year, the drainage ditch is dryl it is
believed that during that time, contaminated groundwater
. flows under the trench and migrates into the groundwater
around the Landfill.
;
,.
I
That the landfill was closed in the early 1980s in
accordance with state standards, as asserted by one
commenter, is not dispositive of the selection of a remedy
at this site. CERCLA charges EPA with cleaning up Superfurid
sites so that they address the current and future threat to
human health and the environment and meet all applicable or
relevant and appropriate environmental laws. There is no
'grandfathering' of past ineffective remedial measures. In.
addition, EPA takes no position with respect to whether
these past remedial measures were consistent with applicable
state laws. .
comment a: The Mayor and the Attorney for the City of Dover
expressed concern that the disturbance of the existing
Landfill cover would probably do more damage to the
environment and cause greater risk to human health than
would occur if it were left untouched.
EPA ReSDonse: While it is possible that there may be some
short-term, adverse impacts to the environment as a result
of the recontouring of the Landfill, in the long-term the
proper closure of this Landfill will provide far greater
protection to human and health and the environment than the
current Landfill cover and drainage trench.
The recontouring activities include consolid~tion of the
existing Landfill perimeter soils and debris from the toe of
the Landfill side slopes, as well as the drainage ditch
sediments, on top of the Landfill prior to capping. The
recontouring of the Landfill is to provide adequate slopes
to allow proper drainage and to minimize the amount of
imported clean fill required to achieve the necessary slopes
(a significant reduction in cost is obtained by limiting the
amount of clean fill necessary).
Before recontouring can begin, a preliminary assessment will
be performed consisting of surface geophysics and test pit
explorations to ensure that excavation is limited to areas
containing predominately soils, debris and municipal waste.
However, it is possible even with these precautionary
measures that the excavation in the Landfill could expose
some hazardous substances in various forms such as barrels,
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Responsiveness Summary
Dover MuniciDal Landfill Site
BPA ..sDons.: Based on the extensive scientific study of
the Site, EPA has concluded that the contaminant plume is
not receding and that the original cover material and
firebreak trench have been, and continue to be, ineffective
at protecting the human health and the environment. Site
studies have shown that total VOC concentrations in some
wells have decreased, however these same studies have
indicated that in other wells, total volatile organic
compounds (VOC) concentrations have increased. Chemical
concentration fluctuations are typically observed in
contaminated groundwaters at hazardous waste sites. Figure
5-2 of the FES compares the HMM ND (non~detect) plume (FES)
and the GZA ND Plume (RI). It is apparent from those
interpretations that the lateral extent of the plume has not
significantly changed from the Remedial Investigation to the
Field Element study. While contaminant concentration data
for certain compounds in off-site wells, such as .
trichloroethylene and 1,2-Dichloroethane indicate a decrease
in concentrations, other compounds such as vinyl chloride
and methylene chloride indicate an increase in
concentrations. Further, vinyl chloride, which 'was only
found at.trace levels in the RI, was detected in three wells
during the FES at up to 31 times the Safe Drinking Water Act
Maximum Contaminant Level (SDWA MCL).
As to the effectiveness of the closure activities in the
early 1980s, the cover material placed on the Landfill
consisted of sandy loam which provided only limited
protection from dermal contact with contaminants and little
or no hydraulic barrier which would prevent precipitation
from infiltrating through the Landfill as this material is
porous in nature. At present, much of this cover has eroded
away, exposing some Landfill wastes. Only sparse vegetative
growth covers the majority of the Landfill. Therefore, the
cover currently does not preclude rainwater from.
infiltrating the Landfill resulting in the migration of
contaminants into the groundwater, south and east of the
Landfill.
In addition, the Landtill was constructed using standard
fill and cover techniques, without any definitive drainage
system or leachate collection systems. As a fire preventive
measure, the Landfill was sur~ounded by a "firebreak"
trench. The drainage trench was constructed by re-
excavating to a shallow depth and berming the excavated
materials to one side. The trench currently intersects the
groundwater table during seasonal high groundwater level
- conditions and collects and-conducts contaminated. Landfill
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Responsiveness summary
Dover Municioal Landfill-Site
The comment that contaminant levels have decreased has been
addressed in more detail in a EPA's response to comment
number 2. In essence, while total VOC concentrations in
certain well locations and some individual contaminant
concentrations have decreased others have increased. The
extent of the plume configuration does not appear to be
receding. In addition, there is no indication that the
risks associated with the site has lessened.
comment 4: One resident did not understand the need for
remediation since no one has seen any dead animals or birds
and since there are plenty of shrubs and trees growing
around the site. He believes that the land will refurbish
itself.
ZPA ReSDonse: The lack of dead animals and the presence of
trees' and shrubs does not indicate the lack of contamination
at the site. The Site presents both current and future -
risks to humans, flora and fauna through contaminated
groundwater, surface water, soils and sediments. GrGundwater
contamination, although not visible to the human eye, is a
substantial threat at the site. The contaminated
groundwater and the threat it presents will continue if the
source of this contamination is not controlled.
Additionally, contaminated sediments in the drainage swale
present a threat to aquatic inhabitants of the Cocheco River
and to a lesser extent, a threat to humans. The same is
true of the perimeter drainage ditch which is a visible
source of surface water contamination. Many wild animals,
such as deer and raccoon, drink from this water, and are
therefore exposed to the contaminants present in the water.
Frogs in this drainage ditch are exposed to the contaminants
in the sediments and surface water. Humans may also be
exposed to these contaminant pathways. -
As to- the comment that this Site will 'refurbish' itself
without remedial action, all sampling and modelling indicate
that it would take decades for natural processes to make
this site safe and to return the natural resources of this
area to their beneficial uses. As set out in the
Feasibility Study, taking no action at this site is to allow
the _contaminants to remain and spread for generations.
Comment 3r Representatives of the City of Dover and Town of
Madbury, and other concerned citizens and officials
recommend that a less costly alternative be considered. -
Specifically, these individuals recommendedthat-EPA.
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Responsiveness Summary
Dover Munici~al Landfill Site
sludges, etc., and some releases could occur. Therefore,
:::--:'. ..::! ::-<::r..lire that extreme care be exercised during
excavation in the Landfill and that contingency measures
such as dust and odor suppressant foam be developed and
implemented as necessary. Any.hot spots or full drums
encountered will be tested and removed, treated and disposed
of in an off-site RCRA TSD facility.
In addition, continuous air monitoring will be conducted to
detect unacceptable exposure levels to.workers and area
residents from inhalation of fugitive dust, organic vapors,
and emissions generated during Site work.
. .
..-.
Commen~ b: Two Dover City Council members questioned the
appropriateness of using data collected seven years ago as
the basis for the choice of the Preferred Alternative.
These council members believed that contaminant levels have
decreased. They suggested that actions be taken only if the
public health is definitely threatened. .
EPA Response: The statement that the remedy is being
selected on data which is seven years old is inaccurate.
Data collection at this Site commenced in the early 1980s
and has continued up until this year. The last round of
sampling - performed by NHDES - occurred in the spring of
1991, shortly before the issuance of the Proposed Plan. All
of this data has been analyzed to determine whether remedial
action is necessary and whether the remedy will be
protective of human health and the environment.
Remedial action is taken at a Superfund site on the basis of
unacceptable risk as well as the failure of the site to
comply with all ARARs. The risk calculation in this case is
based on that data collected in 1989 and 1990 by HMM in the
Field Elements Study, as well as some portions of the data
collected by Wehran Engineers in 1985 and 1986. Some of
this data was confirmed as recently as several months ago.
As discussed in the ROD and supported in the Administrative
Record, all of this data indicated that there remain
unacceptable risks to human health trom this Site.
All of the data collected, including that collected in 1991,
indicates that, among other things, off-site groundwater
contains levels of contaminants above limits set by the Safe
Drinking Water Act.MCLs which are an ARAR for this site.
This exceedence of ARARs, confirmed by data taken just a few
months ago, is another reason for the selected remedial
action. .
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Responsiveness Summary
Dover MuniciDa1 Landfill site
between the Landfill and the reservoir thereby reducing the
groundwater velocity. This action does nothing to
ameliorate the problem of the continued movement of
contamination from the Landfill.
In addition, such an action, implemented without addressing
the source of contamination, suffers from many of the same
problems as long-term reliance on institutional controls
that are listed above. In particular, it fails. to prevent
the formation of contaminated Landfill leachate and the
future migration of the contaminants away from the Landfill.
It also does not clean up the contaminated groundwater
between the Landfill and the reservoir. In sum, such an
action would be in contravention of CERCLA and inconsistent
with the NCP in that it not only fails to satisfy the
threshold criteria necessary for the selection of a remedial
action but also meets few of the objectives for remediating
this site.
EPA has analyzed in detail the deferral of the management of
migration portion of this remedy. As set out in the ROD, an
. active management of migration remedy has been chosen for
the southern plume so as to clean-up the groundwater in a
shorter time frame than that for natural attenuation and to
manage the plume so it does not reach the Class A waters of
the Bellamy Reservoir. In addition, deferring the management
of migration portion of this remedy so that it may be re-
evaluated after the cap has been placed, allows groundwater
risks to remain for an extended period and fails to
institute any short term protection for the Bellamy
reservoir.
EPA agrees that there should be a separation of flows
between the upgradient diversion portion of the trench and
the downgradient interceptor trench. This was not made
clear in the Proposed Plan. The function of the upgradient
trench, included in the selected remedy, is to divert clean
groundwater from any contact with the waste materials,
thereby reducing the volume of contaminated groundwater
requiring treatment. The clean groundwater will be diverted
to the Cocheco River or as necessary, recharged back to the
wetlands to prevent dewatering of the surrounding wetlands.
Comment 4. A resident suggested that grading the Landfill,
diverting surface water away .from the Landfill, and
vegetating the Landfill surface should be sufficient in
controlling and naturally abating the contamination.
15
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Responsiveness Summary
Dover MuniciDal Landfill Site
consider the following actions before finalization of the
~~p.~~r.red Alternative:
.
implementation of a limited action proposal such as
Alternative SC-2:
damming and mounding of water in the Bellamy Reservoir
to reverse further flow toward the reservoir and
creating the equivalent of a hydraulic control in that
area:
.
.
defer implementation of the Management of Migration
alternative: and
delete any requirements to install an upgradient
interceptor trench, or at least separate its flow from
the downgradient trench.
These individuals note that the above options would be less
costly. They also believe that since institutional controls
have been implemented, a public water supply has been
provided and the contaminant plume appears to be receding,
these options would be sufficient in protection of public
health and the environment. '
.
BPA R.spon..: While EPA agrees that implementing a limited
action remedy such as that proposed in these comments would
be less costly in the' short-term than implementing the
selected remedy, a similar limited action plan was reviewed
in detail in the remedy selection process and rejected. The
analysis of such a limited action can be found in the
Feasibility Study and summaries of the analysis can be found
in the Proposed Plan and in the ROD Decision Summary. In .
essence, such a plan would be inconsistent with the intent
of CERCLA and with the NCP insofar as it fails to comply
with ARARs, it fails to provide adequate protection to human
health and the environment, it fails to provide a long-term .
solution, and it fails to reduce toxicity, mobility or
volume throuqh treatment. In particular, the heavy reliance
on institutional controls for a long-term solution is
inconsistent with the NCP where active remedial measures are
practical. In addition, the failure. to return the off-site
groundwaters to their beneficial uses in a reasonable time
is also inconsistent with the NCP.
EPA does not agree that raising the water level of the
Bellamy Reservoir will reverse further flow toward the
reservoir, although it may decrease the hydraulic gradient
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Responsiveness Summary
Dover MuniciDal Landfill Site
EPA ReSDonse: The selected remedy as described in the ROD
includes grading the Landfill, directing surface water away
from the Landfill and establishing vegetation on the
. Landfill surface. As noted in the responses. above and in
the extensive analysis of this site contained in the
Administrative Record, these actions alone are not
sufficient for the protection of human health and the
environment and do not meet the ARARs for the site.' In
essence, this proposal is little different than the no-
action remedy evaluated in the Feasibility study and
rejected in the remedy selection process; it fails to meet
not only the threshold criteria (protectiveness and
satisfying ARARs) but also fails to provide long-term
protection and to employ treatment as part of the solution
to the contaminant threat.
Comment 5: A Dover resident questioned why the Dover
Landfill was singled out for cleanup when thousands of other
sites are more contaminated.
EPA Response: The basis for this Site's proposal and then
placement on the National Priorities List (NPL) can be found
in the Hazardous Ranking Package and those studies on which
these documents are based; all of these materials are
contained .in the Administrative Record. In essence, this
site was placed on the NPL after the discovery that
contaminants from the Landfill had polluted residential
wells adjacent to the Site, that contaminants were flowing
from the site directly into the Cocheco River and that two
municipal drinking water sources, the Calderwood Well and
the Bellamy Reservoir, were in close proximity to the site.
The Dover Municipal Landfill was proposed for the NPL on
December 30, 1982, was ranked and listed on the NPL on .
September 8, 1983. The activities leading to its placement
on the NPL include studies of the Landfill and its impact on
the. surrounding area performed by the NHDES and the Cities
of Dover and Portsmouth. These studies were conducted as a
result of the concern that Landfill contaminants were in
close proximity to the Calderwood Well and the Bellamy
Reservoir. These studies indicated that although the
Bellamy Reservoir and the Calderwood Well had not yet been
contaminated by the Landfill, residential wells and the
Cocheco River were being polluted. Residential wells near
the Landfill. were found to be contaminated with VOCs in
1981. The Cocheco River was being contaminated by leachate,
generated by the Landfill, and discharging via a local
stream (swale) to the river.
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Responsiveness Summary
Dover MuniciDal Landfill Site
In 1982, the City of Dover informed the EPA of its concerns
about the Site. EPA performed a preliminary assessment and
site investigation of the Site, which then led to the
development of a Hazardous Ranking Package and the ultimate
proposal for and placement of the Site on the NPL.
For a comparison with other sites considered for the NPL,
the public should consult EPA's Superfund Inventory called
CERCLIS, which contains the preliminary assessments and site
investigation reports of other "sites,"' which after
evaluation, either did not require the generation of
Hazardous Ranking Package, or if a Hazardous Ranking
was required, the "scoring" for that particular site
meet the criteria for proposal on the NPL.
CommeD~ 7: A City of'Dover Councilman felt that during the
public meeting EPA downplayed the danger to public health
and safety posed by the Site. He questioned why remediation
is necessary if the risks are not great. '
a
Package
did not
EPA ResDons.: EPA disagrees that the risks to public health
and the environment have been "downplayed" by EPA. The
immediate threat to public health from the Dover Municipal
Landfill Site was removed from the Site when residents were
supplied with a public water line in 1982. The baseline
risk assessment (performed initially during the RI and
supplemented in the FES) estimated current and potential
exposures and risks to public health from several exposure
pathways, using current data and assuming no remediation
will take place in the future (no-action). EPA has
identified the estimated risks for the Site, from the
various exposure pathways, and these risks indicate that the
primary threat of exposure is from future use (i.e.,
drinking) the contaminated groundwater around the Site. The
risk assessment do not set clean-up levels for remediation,
but is intended to be used as,a basis for the evaluation of
various alternatives proposed for the cleanup of the Site.
Comm.D~ 8: A City of Dover Councilman stated that a clay
barrier many feet thick prevents water from reaching the '
bedrock from where the city wells draw their water. He
concluded that this factor along with the fact the Bellamy
Reservoir has not been affected calls for modifications to
the Preferred' Alternative. '
EPA ResDoDse: EPA assumes that the "bedrock from where the
City wells ,draw their water" is referring to the lower
hydrogeologic unit comprised of sandy gravels and dense
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Responsiveness Summary
Dover MuniciDal Landfill site
till, rather than the actual bedrock unit. EPA agrees that
tIle :mar~ne clay unit, which underlies the site and separates
the upper and lower hydrogeologic units, inhibits the
contaminated groundwaters in the upper hydrogeologic unit
frc: reaching the groundwaters in the .lower hydrogeologic
unit. Data has also indicated, to date, that the Bellamy
Reservoir has not yet been contaminated by the groundwater
migrating from the Landfill. Each of these factors has been
taken into consideration in the selection of the remedy for
this Site.
However, as discussed in detail in the Feasibility Study and
in the ROD, these factors do not change the fact that the
groundwater in the upper aquifer has contaminant levels
exceeding those considered safe for drinking and thus the
Site ARARs are not met. In addition, in accordance with the
NCP. and related EPA Guidance the remedy at this Site is
based in part on the future risk related to the groundwater
contamination in the upper aquifer. Again the faqts cited
in this comment do not address this risk.
In essence, this comment takes the position that if there is
no threat to the current municipal drinking water sources,
then the remedy should be less protective. The NCP and
related EPA Guidance take the contrary view; all risks
related to a Site, including risks associated with future
private consumption of contaminated groundwater, must be
addressed in the remedial action. A remedy which does not
address the contaminants in the upper aquifer fails to
satisfy even the threshold criteria required by the NCP.
Comment 9= The City of Portsmouth Public Works Department
submitted a comment in support of EPA's Preferred
Alternative because the "cleanup plan is taking the
necessary steps to correct the problem and protect the
Bellamy Reservoir". It was stated that since over thirty-
thousand residents are served by the Bellamy Reservoir, this
water supply should be protected. The City of Portsmouth
also noted that the "reservoir would be difficult, if not
impossible, to replace at a cost much higher than it would
be to clean up the landfill that threatens it".
EPA a.SDons.: Each element of the 'selected remedy will be
consistent with protecting the Class A waters of the Bellamy
Reservoir. The remedy 'requires active groundwater treatment
in the southern plume as well as the management of the plume
so that it does not reach the reservoir. This active'
treatment of the southern plume will only be foregone if new
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Responsiveness Summary
Dover Municioa1 Landfill Site
evidence reveals that the plume poses no threat to the
Bellamy Reservoir.
CommeD~ 10: Two area residents commented that they hope EPA
will not relax necessary requirements based solely on the
cost or financial impact to the PRPs. "These residents are
concerned about what effect no action or limited actions
will have on their property value. They do not feel that
placing a fence and warning signs around the Landfill
protects either the public or the environment from possible
hazards. Hunters, bikers, and four-wheel vehicles still use
the Site and deer feed and drink. from the land around the
Landfill. These residents do not believe that they should
be penalized for the PRPs unwillingness or inability to
correct mistakes made in the past.
EPA ResooDse: The selected remedy employs a combination of
waste containment, capture and treatment, and natural
attenuation that satisfies all statutory and regulatory
requirements. The remedy is also consistent with this
comment, in that it takes active measures to protect human
health and the environment: neither no-action nor limited
action were chosen for this Site.
CommeDt 11: A petition signed by Dover and Madbury citizens
urges EPA to adopt a "reasonable and economically feasible"
plan for the cleanup of the Dover Landfill. The petition
recommends continued monitoring and installation of a new
cap only if conditions worsen. It is also recommended that
additional actions should be placed in only as necessary to
correct worsening conditions.
EPA ResDoDse: The cost-effectiveness of the remedy is
addressed in the response to Comment 1 as well as in the
ROD. The limited action proposed - monitoring and staged
implementation of remedial actions only if Site conditions
worsen - is inconsistent with the NCP in that it fails to
satisfy not only the threshold requirements for remedial
action but does not meet the si~e-specific remedial
objectives set out in the Feasibility Study and summarized
in the ROD. In addition, the response to Comment 3 is
equally relevant to this comment.
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Responsiveness Summary
Dover MuniciDal Landfill Site
p.~~+, !t Summary of potentially aesponsible Party Comments
Balsam Environmental Consultants, Inc. (Balsam) submitted
written comments on behalf of the Dov~r Landfill PRP Group.
Balsam commented that certain elements of the Proposed Plan
are overly protective of human health or are
"environmentally or technically impracticable." The Balsam
comments are summarized below.
Comment 1: Balsam recommends that EPA select a "sequential
and phased" remedy for the site instead of implementing all
of the components of the Proposed Plan simultaneously.
Balsam proposes the following four sequential phases.
Phase X: Construction of a properly designed cap over
the Landfill, installation of a ground water and
surface water monitoring system, and implementation of
access and institutional controls.
Phase XX: Construction of an interceptor trench
upgradient of the Landfill with discharge of collected
clean ground water to the Cocheco River through an
NPDES-permitted outfall.
Phase XXX: Installation of an interceptor trench
downgradient of the Landfill, with treatment of
collected ground water.
Phas8 XV: Installation and operation of an offsite
ground water extraction and treatment system.
Balsam proposes that if results of ground water monitoring
reveal that site cleanup objectives have not been achieved
after the completion of each phase, additional phases would
be implemented sequentially. Balsam contends that such an
approach wou~d be consistent with the National Contingency
Plan 40 CFR 430(a) (ii) (A) and satisfies the nine criteria
for evaluation outlined in 40 CFR 300.430(e)(a)(iii).
Furthermore, Balsam contends that a phased remedial program
is appropriate for the Dover Landfill site because
"significant" risks to human health and the environment are
not currently posed by the Site and future risks are not
"significant" because of institutional controls; therefore,
Balsam takes the position that the additional time that may
be associated with completion of its proposed remedial
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Responsiveness Summary
Dover MuniciDal Landfill site
program should not result in increased adverse impact to .
human health.
Balsam also states that it would be premature to implement
onsite hydraulic controls and active ground water'
remediation without a more complete understanding of the
current hydrogeologic conditions at the site. Balsam
recommends that implementation of the hydraulic control and
management of migration elements of the Preferred
Alternative be deferred until better evaluation of the post-
cover system installation ground water flow regime is
developed, and associated changes in ground water flow and
plume migration direction have been monitored in the field.
EPA Res~oDse: EPA has reviewed the Balsam proposal in
detail and determined that it fails to meet not only the
threshold criteria for the selection of remedial action,
protection of the human health and the environment and
compliance with ARARs, but fails to compare favorably with
the selected remedy when evaluated against the five primary
balancing criteria. The following response summarizes a
number of important faults EPA has found with the Balsam
proposal. In addition, one particularly important
shortcoming of this proposal is addressed in detail.
In sum, the proposal fails to meet the threshold criteria
for selecting a remedial action because: the proposal fails
to satisfy many ARARS including groundwater clean-up levels
established by Safe Drinking Water Act and the Resource
Conservation and Recovery Act (RCRA), the federal and state
hazardous waste laws requiring complete containment of
hazardous wastes, and the federal and state laws protecting
surface waters; the proposal fails to prevent the generation
of contaminated leachate from the Landfill and the migration
of this leachate into the surrounding groundwater and .
surface water, in contravention to ARARs and cleanup
objectives; the proposal fails to provide sufficient.
protection to the Bellamy Reservoir in the short-term and
long-term; the proposal does not provide for groundwater
cleanup in a reasonable time frame; the proposal does not
adequately address the long-term risks posed by the
contaminant plumes; the proposal fails to address
contaminated sediments in the drainage swa1e; and, by its
nature, the proposal is not a permanent solution. In
addition, reviewing this proposal in light of the five
primary balancing criteria, among other problems with this
proposal are the following: the proposal employs treatment
as a last measure, contrary to the NCP's bias towards
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Responsiveness Summary
Dover MuniciDal Landfill Site
treatment of hazardous wastes; the phased approached may 'not
be cost-effective if early remedial measures do not meet
cleanup levels; a phased approach will generate
substantially more administrative problems, ,and ~ransaction
costs will increase as well; risks may increase
substantially if leachate is allowed to continue to migrate
from the Site; the proposal conflicts with the NCP's mandate
that institutional controls are to be used for long-term
solution only where other means are not practical for
cleaning up the contamination; and the 'phased approach may
significantly delay the ultimate cleanup of this Site.
Of particular concern is the failure of the Balsam proposal
to include a leachate collection and treatment system at the
outset of the remedy. As described below, this proposal
would allow continued contaminant migration from the Site,
threatening human health and the environment and failing to
meet many of the ARARs, in the 'hope that a limited rem~dial
action will eventually meet cleanup objectives.' Such a
'wait-and-see' approach to remedy implementation provides
little assurance of either short term or long term
protection from the Site.
At the Dover site, substantial amounts of waste material
currently lie beneath the water table and remain saturated
during all or major portions of the year. The leachate from
these saturated wastes coupled with the leachate produced by
rainwater infiltrating through wastes above the groundwater
table is the source of the contaminated groundwater
downgradient of the Dover Landfill. While the cap alone
will minimize or prohibit the amount of rainwater
infiltrating through the waste, it will not abate the
continued migration of contamination from the Landfill
associated with normal groundwater flow.
The installation,of an effective capping system is expected
to somewhat alter the current hydraulic conditions within
the Landfill and thereby influence local groundwater flow
and direction characteristics; it will not decrease the
amount of hazardous substances that are currently in the
contaminant plumes and beneath the Landfill proper. Leachate
that has been generated within the waste mass can also be
expected to continue to move outward until such time as the
waste mass is effectively de-watered (recharge being denied
by installation of ' the cap). portions of the waste mass may
continue to remain beneath the water table unless the now
relaxed groundwater mound falls permanently below the bottom
of the wastes. Thus~ the remedy's interceptor system will
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Responsiveness Summary
Dover MuniciDal Landfill Site
provide for collection of leachate until such time as the
benefits of capping the landfill become fully effective or
in the event that wastes remain beneath the water table
collection will continue until leachate concentrations fall
to and remain within acceptable limits.
MOdeling conducted during the FS estimated cleanup levels
will be attained within 5 to 7 years in the eastern plume
and within 10 to 24 years in the southern plume provided
source control measures are implemented including cap and
the leachate/groundwater collection system around the
Landfill. Without the leachate/groundwater collection
system, contamination from within the Landfill or already in
the aquifer will continue to migrate offsite thus increasing
estimated times to attain cleanup levels in the eastern and
southern plumes. Given these circumstances, ARARs would not
be met in either plume at or beyond the compliance boundary
within a reasonable time frame as required by the NCP and
certainly not within the time frame which could be attained
using active measures to control the migration of
leachate/groundwater from the Landfill. A phased" approach
to instituting source control measures thus builds into the
cleanup of the Site long periods during which contaminants
may migrate off the site and increase the threat to human
health and further harm the environment.
Based on the above conclusions it is EPA's opinion that
employing a "wait and see" method of remedy implementation
does nothing to diminish, and could magnify, potential risks
to human health and the environment.
EPA agrees that additional data must be gathered during pre-
design and design to allow for the proper design and
construction of the groundwater/leachate collection system.
EPA also agrees that the groundwater/leachate flow patterns
may change somewhat after. the installation of the cap.
However, EPA has not concluded that the resultant change
will be significant. Further, EPA has concluded that the
groundwater/leachate collection system can be appropriately
designed in conjunction with the cap design. EPA
acknowledges that, after implementation of both systems,
some fine tuning of the collection system may be required to
optimize its effectiveness. However, this is not considered
unusual and can be provided for in. the design.
Finally, the time to design and install, the cap, to then
wait until the groundwater flow regime under and around the
landfill to stabilize, and to then design and construct the
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Responsiveness Summary
Dover MuniciDal Landfill site
groundwater/leachate collection treatment system would take
'" ,"",~",,~~~...t;.3.J. number of years, possibly in excess of ten.
Only after this lengthy period would the groundwater
remediation process begin. In the meantime contaminants
would continue to migrate from the Landfill in the
groundwater and surface water. EPA does not consider this
approach to be consistent with the NCP in that the
groundwater will not be returned to its beneficial use in a
rc~zon~ble time frame, and the contaminated leachate
entering the local surface waters would violate ARARs.
Comment 2: Balsam comments that the remediation of the
southern plum~ through groundwater extraction and treatment.
does not appear justified. Balsam bases this opinion on the
following factors: 1) EPA has concluded that the Bellamy'
Reservoir will not be significantly affected by contaminated
ground water: 2) installation of an engineered cap over the
site will both significantly improve ground water quality
and modify the existing hydrogeologic regime, both of which
will serve to mitigate the ,southern plume: 3) ground water
in the area will not be utilized due to institutional
controls implemented by the City of Dover: and 4) closer
examination of the risk assessment, which indicates that the
majority of the potential future risk associated with the
southern plume is attributed to arsenic, reveals that risks
may be overestimated.
EPA ReSDonse: The possibility that the Class A waters of
the Bellamy may be contaminated by the southern contaminant
plume is one of several reasons for including the active
treatment of this plume as part of the Proposed Plan and the
overall remedy for this Site. EPA has determined that, to
date, the plume has not had an adverse impact on the waters
of the Bellamy: this does not mean that future contamination
will not occur. As noted below, groundwater sampling and.
modelling has indicated that contaminants in the southern
plume are moving towards the reservoir. In addition,
natural attenuation will take from 10 to 24 years to improve
groundwater quality to cleanup levels after the source
control measures are put into Dlace. without active plume
management'these contaminants may reach the Bellamy during
this lengthy period. More importantly, as discussed in the
ROD, active plume extraction and treatment is justified even
if the contaminants posed no threat to the Bellamy: the fact
that groundwater contaminants exceed MCLs in an area that
could be used for drinking water is sufficient justification
for employing active treatment and management of this plume.
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Responsiveness Summary
Dover Municipal Landfill Site
As to the second basis for Balsam's opinion, EPA
acknowledges that an effective cap over the Landfill may
alter the ground water flow characteristics in the area of
the southerly plume. However, there is little support for
the position that a cap alone will cause a significant
improvement in ground water quality in' the downgradient
plume. Even if an effective cap is installed on the
Landfill, it is likely that groundwater will still flow in a
southerly, downgradient direction. As indicated from Table
3-2 in the FES report entitled Elevation Information for HMM
Installed Monitorina Wells, groundwater elevation in the
upper unconfined aquifer ranges from one to five feet below
surface grade. Therefore, it is assumed that some of the
disposed waste deposited in the Landfill exists in the
saturated zone. Accordingly, as indicated in a groundwater
contour map of the Landfill area (Figure 3-6 in the FES),
grounQ water could flow in a southerly, downgradient
direction underneath the Landfill, through the existing
industrial and municipal waste. This scenario would likely
cause a continued migration and expansion of the VOC plume
in a southern direction towards the Bellamy Reservoir. The
cap will reduce the vertical flow of water through the waste
but not the horizontal flow through the waste in the
saturated zone.
In addition to allowing leachate 'to continue to flow beyond
the Landfill boundaries, the cap would have little or no
impact on the contaminants that have already migrated within
at least 900 feet of the reservoir. While the flow may be
somewhat retarded by a cap, those contaminants will continue
to pollute the groundwater at and beyond the point of
compliance and will continue to flow towards the reservoir.
It should also be noted that the calculation of the natural
attenuation time frames for the eastern and southern plumes,
by HMM, assumed that an active source control alternative
had b$en installed and that further miqration of
contaminated groundwater and leachate had been eliminated.
The natural attenuation time frames were estimated to be 5
to 7 years for the eastern plume and 10 to 24 years in the
southern plume. These estimated time frames will increase
if leachate and contaminated qroundwaters are allowed to
continue to miqrate from the Landfill.
As noted in response to prior comments and in the ROD,
institutional controls, if they are implemented, will
provide protection from contaminated groundwater in the
,short-term. However, the NCP requires that such controls be
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Responsiveness Summary
Dover MuniciDal Landfill Site
used as a long-term measure only when other alternatives.are
n=t ~ractical. In sum, the proposal that institutional
cQntrols be used for an indefinite period while Landfill
leachate continues to contaminate groundwat~r is
inconsistent with the NCP.
Balsam's position that the risk attributable to arsenic in
the groundwater is overestimated is addressed in detail in
EPA's responses to the Public Health Evaluation submitted by
Environmental Standards, Inc. for the Dover PRP Steering
Committee (comment c). In addition, the reasonable maximum
risk for vinyl chloride, found at 31 times the drinking
water standard in the southern plume, exceeds EPA's
acceptable risk range.
Comment 3: Balsam states that EPA has not established
criteria for the termination of the proposed groundwater
recovery and treatment systems. Specifically, Balsam states
that EPA does not discuss target cleanup levels (TCLs) or
specific points of compliance that would be used to
terminate recovery and treatment operations. Balsam
recommends that these criteria should include attainment of
TCLs in defined monitoring wells for a defined period of
time. Balsam further recommends that, in determining TCLs,
EPA should consider documented operational limitations of
the ground water recovery and treatment system. Balsam
notes that the use of Maximum contaminant Level Goals
(MCLGS) as a TCL is infeasible when the MCLG is zero, citing
the preamble to the NCP.
EPA ResooDse: EPA has set interim groundwater cleanup
levels in the ROD which must be met before cempletion, of the
remedial action at and beyond the point of compliance. In
acc~rdance with the NCP, the point of compliance is
established at the edge of the waste management area. When
the interim cleanup levels have been attained in all
monitoring wells at and beyond the point of compliance, ~
risk assessment will be performed on residual groundwater
contamination to determine whether the remedial action is
protective. Remedial actions shall continue until
protective concentrations of residual contamination have
been achieved or until the remedy is otherwise deemed
protective. These protective residual levels shall
constitute the final cleanup levels for the ROD ,and shall be
considered the ultimate performance standards for the
remedial action. The groundwater monitoring system will
then be utilized to collect information for three years to
ensure that the protective residual levels remain and the
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Responsiveness Summary
Dover MuniciDa1 Landfill site
remedy is protective. The details of the groundwater
monitoring program, such as number and location of
monitoring wells and parameters, will be determined during
remedial design.
EPA has also determined that until Site-specific data
indicates that groundwater cleanup levels will not be met,
it is inappropriate to include provisions which allow
treatment to be terminated prior to the attainment of these
levels. There is currently no Site-spe~ific information
that leads EPA to believe that the cleanup levels cannot be
attained through extraction and treatment.
As noted in the ROD, interim cleanup levels for
probable carcinogenic compounds (Class A and B)
set at the appropriate MCL given that the MCLGs
compounds are set at zero.
known and
have been
for these
Comment 4: Balsam proposes that the compliance boundary for
Site cleanup be established at the shore of the Bellamy
Reservoir and at the banks of the Cocheco River. Balsam
submits that the area bounded by the Landfill to the north,
and the Bellamy and Cocheco to the south and east, would be
established as a non-attainment zone. Balsam asserts that
such a non-attainment zone is consistent with current New
Hampshire groundwater policy which, it claims, is to be
incorporated into New Hampshire's groundwater regulations at
an undetermined point in the future. Balsam also commented
that such a proposal is justified because institutional
controls can be used to prevent the extraction of drinking
water from this area, a City water supply can be provided in
this area, and the source control measures will help
eliminate the contaminant plume. A similar comment was also
submitted by counsel for the City of Dover at the public
hearing.
EPA a.SDons.: EPA has considered the above comment and
determined that the establishment of a compliance boundary
at the shores of the Bellamy and the banks of the Cocheco
would be inconsistent with the NCP, insufficiently
protective of the human health and the environment, and
contrary to ARARs and the EPA's Groundwater Protection
Strategy. In addition, a review of the current New
Hampshire regulation which addresses this issue (Ws 410.13)
but which is not an ARAR, indicates that even if it were an
ARAR, the proposed compliance boundary would meet neither
the letter nor the spirit of that regulation. Finally, the
policy to which commenters refer is neither specified in
27
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Responsiveness Summary
Dover MuniciDal Landfill Site
their comment nor could be an ARAR as it is not an
enforceable promulgated state regulation.
In accordance with the NCP, groundwater remediation levels
will be attained at and beyond the edge of the waste
management area. In this case the waste management area
includes the Landfill and the perimeter drainage ditch. At
the completion of construction of the source control portion
of the remedy, the compliance boundary will be set at the
outer edge of the interceptor trench; contaminants at and
beyond that point must meet cleanup levels. While the NCP
allows for site-specific exceptions to this general pOlicy,
at the current time no site-specific factors indicate that
such an exception is appropriate.
In addition to being inconsistent with the NCP, the
establishment of a zone of non-compliance beyond the edge of
waste management area would be contrary with both federal.
and state ARARs controlling the protection of groundwater
and surface water. Such a proposal, if accepted, would
institutionalize the pollution of a potential drinking water
resource and could allow the Class A waters of the Bellamy
to be contaminated before any remedial action was taken. In
addition, if groundwater remains contaminated in this area,
an unacceptable risk to human health would also remain.
Finally, an examination of the current state regulation
controlling compliance boundaries, from which the comment
draws support but which is not an ARAR for this Site,
indicates that the boundary should be set at the closer of:
the property boundary, 500 feet from the waste material, or
a distance set in a.permit. In this case, a compliance
boundary at the edge of the Bellamy Reservoir and Cocheco
River would far exceed that set by this regulation because
the property lines for this site fall far short of those
surface water bodies. In addition, it appears contrary to
the l.tter and spirit of this state regulation for
contamination to remain in groundwater beneath privately
owned properties surrounding the site.
As to the unspecified pending changes to New Hampshire
regulations, in accordance with the NCP, ARARs are "frozen"
at the time that the ROD is issued. unless a later-identified
ARAR is necessary to ensure that the remedy is protective of
human health and the environment. The non-attainment area
policy to which Balsam refers will not attain ARAR status by
the time the ROD is issued, and, being less stringent than
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Responsiveness Summary
Dover MuniciDal Landfill Site
existing requirements, will not later be necessary to ensure
protectiveness; it is therefore not an ARAR for this Site.
Related issues raised in Balsam's comment, such as the use
of institutional controls, the nature of the-groundwater
flow, and the movement of the plume are addressed in other
EPA responses.
Comment 5: Balsam states that EPA's preferred RCRA cap
construction is overprotective. Balsam believes RCRA
requirements are not applicable to the Dover Landfill Site
cap because disposal activities ceased before the effective
date of RCRA. Balsam recommends that EPA consider a five-
layer capping system with a single hydraulic barrier,
consistent with NHDES requirements: a soil cover layer, a -
sand buffer layer, a low permeability layer, a layer of free
draining sand, and a layer of topsoil. Balsam notes that
EPA has selected caps of similar design at other solid waste
landfill Superfund sites in Region I.
EPA ResDonse: EPA and theNHDES have reviewed Balsam's
single barrier cap for use at this Site and rejected it.
The single barrier cap fails to satisfy ARARs and does not
provide adequate protection to human health and the
environment. In addition it does not compare- favorably with
the selected remedy when evaluated on the five balancing
criteria set out in the NCP and summarized in the ROD. EPA
has determined that the selection of the multi-layer cap is
consistent with the NCP and all relevant Guidance.
/ "\
The NHDES cap, as proposed by Balsam for use at this Site
and described above, was designed by the State of New
Hampshire for closure-of solid waste landfills in that
state; the design requirements are the minimum engineering
requirements for solid waste landfill caps. While this Site
received large quantities of municipal solid waste during
its operation, it also received substantial amounts of
industrial wastes which would be considered hazardous (and
regulated by RCRA) if disposed today. These wastes were not
RCRA wastes at the time of disposal onlv because the
reaulatorv and statutorY reauirements of RCRA were not in
Dlace at that time. These RCRA-type industrial wastes are
now the source of contamination migrating from the Landfill
into the surrounding groundwater.
Since siqnificant quantities of RCRA-type wastes have been
disposed in the Landfill and continue to pose a threat to
human health and the environment, federal and state
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Responsiveness Summary
Dover MuniciDa1 Landfill Site
"
~azardous waste regulations have been deemed relevant and-
-t';.'';' -t'..l,"-~;;, to the cleanup of this site. The state solid
waste laws are not ARARs for this site. The cap will be
designed to meet or exceed, among other standards, the
performance requirements set forth in the state and federal
ARARs including 40 CFR 264.111, 40 CFR 264.310 and the
guidance document Final Covers on Hazardous Waste Landfills
and Surface ImDoundments, July 1989 (EPA/ 530-SW-S9-047)
(Tecnnical Guidance). In addition, the use of a RCRA-type
cap is consistent with EPA Guidance concerning the selection
of remedies at municipal landfill sites: the Guidance manual
Conductina Remedial Investiaations/ Feasibi1itv Studies for
CERCLA MuniciDa1 Landfill site, February 1991, EPA/540/P-
91/000 (OSWER Directive 9355.3-11), recommends that a
composite-barrier cap (multi-layer) is to be used when a
landfill contains RCRA listed 'wastes, wastes sufficiently
similar to RCRA listed waste, or RCRA characteristic waste.
In addition to compliance with ARARs, the multi-layer cap
was selected for the Dover Landfill because infiltration is
a primary concern due to the high annual precipitation in
New Hampshire. The mUlti-layer cap provides an additional
"barrier" layer, which reduces the rate of infiltration more
than a single-barrier cap, such as the NHDES solid waste
closure cap. The mUlti-layer cap is the best available cap,
designed to provide maximum, long-term protection from
infiltration due to precipitation.
comment 6: Balsam submits that installation of a ground
water interceptor trench around the entire perimeter of the
Landfill, proposed by EPA, does not provide for segregation
of upgradient ground water, which is presumed clean, from
downgradient ground water. Balsam states that clean
upgradient ground water would be conveyed for on-site
treatment prior to discharge to the Cocheco River or the
Dover POTW. Balsam believes that upgradient ground water
should be conveyed directly to the CochecoRiver and
discharged. Balsam also states that the efficiency' and
effectiveness of the treatment process is greatly reduced
when impacted ground water becomes diluted.
~~~_~e8~q~S~-1 Although not clearly indicated in the FS, the
upgradient portion of the "interceptor trench" will collect
and divert clean groundwater around the Landfill. This
point is clarified in the ROD.
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Dover MuniciDal Landfill Site
CommeD~ 7: Balsam comments that the remediation of drainage
swale sediments to address risk associated with arsenic
present in the sediments is overprotective. Balsam states
, that the risks associated with direct contact and ingestion
of swale sediments are within EPA's acceptable risk range.
Balsam concludes that remediation of the drainage swale
sediments does not appear to be warranted.
EPA ReSDODse: While EPA agrees that cleanup of the
contaminated swale sediments is not necessary for the
protection of human health because the risks associated with
ingestion and dermal contact with these sediments falls
wi thin the accepted risk range', cleanup of the arsenic in
the swale is necessary for the protection of the
environment. EPA, in conjunction with NOAA, have determined
that a cleanup level for arsenic in the sediments should be,
set at 50 ppm for the protection of aquatic biota.
CommeD~ 8: One PRP commented that $2 million have already
been spent on trying to determine the best cleanup
alternative for the site and not one "shovel-full of dirt"
has been removed. The PRP felt money was being spent
"capriciously" and that less money should be spent on the
Preferred Alternative.
EPA ResDonse: The NCP and related EPA Guidance outline the
process which EPA must follow in conducting Remedial
Investigations and Feasibility studies. While such a
process may seem expensive and cumbersome, it is aimed at
ensuring that the best remedy is chosen at each site while
also creating national consistency in the proper selection
of remedies for, Superfund sites.
Following the issuance of the Record of Decision for the
remediation of this Site, the design of the remedy will be
undertaken. Once the design is completed, the construction
of the remedy will commence. It is estimated that the,
design and construction will take approximately four years
to complete.
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Dover MuniciDal Landfill Site
RISK ASSESSMENT
u
The Dover Landfill PRP Group submitted a report titled "An
Updated Public Health Evaluation of the Dover, New Hampshire
Municipal Landfill Superfund Site" dated May 18, 1991 and
prepared by Environmental Standards, Inc. (ESI Report).
The EPA has evaluated this report as it did other public
comments and considered it in selecting a remedy at this
Site. Since the report was not submitted in comment format
and did not specify particular areas ' of the HMM risk
assessment with which it disagreed, it is particularly
difficult for EPA to "respond" to the report. While this
Responsiveness Summary does not provide a forum for EPA's
detailed evaluation o~ the ESI Report, as noted below,
efforts have been made to address major differences in the
HMM risk assessment and the ESI, assessment, and to highlight
portions of the ESI Report with which EPA does not agree.
In sum, after a complete review of the ESI Report, EPA is
not persuaded that, as ESI concludes, the site poses no risk
outside EPA's acceptable risk range. In EPA's view, the ESI
Report does not comply with Regional risk assessment
standards, at times employs collections of data which are
not justifiable, considers factors which the Region
determines to be inappropriate, and makes assumptions
inconsistent with Regional policy.
General Comments & ReSDonses:
Comment a: ESI provided risk analysis for three separate
groundwater data sets:
1) RI data set, utilizing data from the most
highly contaminated well (Well B-2U) as a basis of
hypothetical long term exposure
2)' the 95th percent upper confidence interval of
the mean concentrations of the RI and FES data
sets combined, and
3) the average concentrations of the most recent
and validated data (FES data)
BPA ReSDonse: EPA'determined it was not appropriate to use
only the RI data set or the combined RI and FES data set
because these data sets do not represent the most current
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Responsiveness Summary
Dover MuniciDal Landfill site
chemical concentration levels (e.g, latest sampling results)
found at the Site. . EPA determined that the risk analyses
for data sets 1 and 2 were not relevant because the
estimated risks derived from those data sets. would not
reflect the risks associated with the current concentration
levels found at the Site. EPA agrees that the use of data
se~ 3, FES data, was appropriate to conduct the risk
assessment. For the above reason, many of the responses
which follow address ESI's risk assessment on data set 3.
EPA's risk assessment data set used average and maximum
concentrations from the data collected during the Field
Element Study by HMM Associates, except for two compounds:
1,2-dichloroethane which was not detected during the FES and
tetrahydrofuran, which was not analyzed for during the FES.
Data for these two compounds was taken from the RI. The
supplemental risk assessment in the FES presented the
average (most-probable) and maximum (worst-case) risks using
the FES data except for the two compounds as noted above.
Comment b: ESI submitted this report to provide a summary
of the methodologies and results of an independent risk
assessment of the Dover Landfill utilizing the most current
guidelines and data obtained during the RI and FES.
EPA ResDonse: Region 1 pOlicy, and the policy in effect when
the risk assessment for the Dover Municipal Landfill was
initiated was to calculate average and reasonable worst case
risk estimates based on average and maximum observed
concentrations. This approach was consistent with EPA
Regional Policy and National EPA Policy at the time the risk
assessment was initiated. Furthermore, it has remained
consistent with current Regional Policy despite changes to
the National Policy.
Reasouable Maximum Exposure
Recent EPA national risk guidance (RAGS) recommends
calculating one risk estimate using the 95% upper confidence
limit on the mean concentration corresponding to a
reasonable maximum exposure estimate. The authors of this
guidance have not yet provided sufficient information to
employ that portion of the guidance. related to the 95% upper
confidence limit in a nationally consistent manner.
Furthermore, the recent national guidance is simply that -
guidance. CUrrent Region I risk assessment policy is
consistent with the NCP which requires the evaluation of the
Reasonable Maximum Exposure. Region I, therefore, has
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Responsiveness Summary
Dover MuniciDa1 Landfill Site
chosen to follow its consistent policy of using average and
reasonable worst case risk assessments until such time as a
nationally consistent methodology is developed.
Furthermore, in the case of the Dover Risk Assessment, not
only were EPA's average and reasonable worst case' risk
estimate~ in excess of EPA's acceptable risk range, but a
95% upper confidence level of the mean co~centration as
computed by ESI (following the recent National EPA Policy)
also appears to exceed the acceptable risk range. The
average and maximum cumulative risks, from the HMM FES
Supplemental Risk Assessment (and thus EPA's risk
assessment), are 1.86 x 10-2 and 6.97 x 10-2, respect;.ive1y.
EXDosure Parameters
EPA's risk assessment prepared' by HMM was submitted on
February 11, 1991 and presented both average and maximum
risks. Exposure parameters used in this assessment were'
consistent with Region I .po1icy and National Superfund
Policy, applicable at that. time, and the Office of Drinking
Water which uses a 70 year exposure period to derive MCLs.
Some of EPA's parameters differ from those used by ESI. For
example, EPA assumed a 70-year vs. 30-year exposure duration
for groundwater ingestion, and assumed that 100% vs. 75% of
groundwater ingestion occurs at home. Furthermore, the use
of ESI parameters would not have resulted in significant
decreases in EPA's risk estimates.
EXDosure Pathways
ESI has also included two exposure pathways in the
quantitative risk assessment which EPA did not: inhalation
and dermal absorption during household use of groundwater.
currently Region I only evaluates these pathways
qualitatively because there is no consensus either in Region
or in Headquarters on how to quantitate the risks from these
exposure pathways. If EPA had evaluated these pathways
quantitatively, the total risks would have been even greater.
(by perhaps a factor of 2).
ESI's Missina ComDound
EPA Regional policy as well as the national guidance state
that risks for all classes of carcinogens should be added.
ES omitted the one class C compound from the cumulative
risk, 1,1-dichloroethy1ene. EPA calculated a risk range of
2.2 x 10-5 to 2.2 X 10-4 for this compound which factored
into EPA's cumulative risk estimate.
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Responsiveness Summary
Dover MuniciDal Landfill site
SDecific Comments & ResDonses:
CommeD~ c: ESI states that elevated arsenic levels were
found in groundwater samples at the Site, in wells which are
clearly upgradient of possible Site influence, and in other
wells where no VOCs or other markers oŁ landfill impacts
were evident. ESI also states that New Hampshire is known
to have high concentrations of arsenic-in pristine
groundwaters. ESI states "According to EPA's guidelines, it
may be appropriate to eliminate this element from the risk
assessment." In addition, ESI states that very few samples
were filtered and that by limiting water analysis to
unfiltered arsenic, "this aspect of the investigation was
rendered meaningless". ESI states that arsenic data does
not appear to correlate with the levels of contamination by
VOCs, therefore no conclusion .can be drawn with respect to
landfill influence on arsenic in the shallow aquifer at this
Site. .
EPA ReSDODse: EPA agrees that there may be elevated levels
of arsenic in the groundwater around the Site. .EPA does not
agree that arsenic should be eliminated from the baseline
risk assessment when background levels of arsenic in the
groundwater has not been readily identified at this Site.
Given the high concentrations of arsenic found at the Site,
EPA does not anticipate that once the background level is
determined, that it will significantly alter EPA's risk
assessment. EPA's approach to evaluating risks at a site,
is that all risks for the site, whether background, site
related, or both be included in the baseline risk
assessment.
Data indicate that for VOCs, the four most contaminated,
shallow aquifer wells during the RI: OW-lA, B-4U, OW-SU, and
B-2U-respectively, are also the four most contaminated wells
for arsenic according to FES data. EPA notes that although
well OW-LA was not sampled for arsenic during the FES, MW-
101, located approximately 20 feet north was sampled for
arsenic and high concentrations of arsenic were found. In
addition, well MW-101 had the highest total VOC
concentrations during the FEB.
The higher levels of arsenic found on-site (up to 1300 ppb)
suggest a potential influence of the Landfill Leachate
(i.e., VOC, organic acids, sulfides, iron, etc.) in the
groundwater on the mObility of naturally occurring arsenic.
In addition, arsenic may have been disposed of at the
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Responsiveness. Summary
Dover MuniciDal Landfill site
T,;uHi1:i.ll due to its presence in typical municipal wastewater
sludge and industrial wastes.
v
The national guidance (RAGS) states that while filtration of
yz:ol.:.l1'.iwater samples provides useful information for
understanding chemical transport within an aquifer, the use
of filtered samples for estimating exposure may
undere$timate chemical concentrations in water from an
unfiltered tap. Therefore, data from unfiltered samples
should be used to estimate exposure concentrations.
The ROD states that a background level for arsenic will be
determined by the EPA and the NHDES after the pre-design
sampling results have been evaluated. EPA will set the
cleanup level for arsenic in groundwater to the RCRA MCL of
50 ug/l or background, whichever is determined to be higher.
The cleanup level will be.set for total arsenic in
groundwater (unfiltered) because this is representative of
the residential use of groundwater for a drinking water
supply.
Comment d: ESI states that the baseline risk assessment is
based on the unrealistic assumption that contaminated off-
site groundwater will be consumed and utilized on a daily
basis. The reason stated is because at present: 1) private
residences that could be impacted by the Site are connected
to the municipal water supply; and 2) an ordinance
prohibiting the installation or use of a well for any
purpose within 1500 feet of the Landfill was added to the
City of Dover Code (116-7.1). ESI did, however, calculate
risks for the ingestion, inhalation and dermal adsorption of
off-site groundwaters.
EPA ReSDonse: The NCP states that the role of the baseline
risk assessment is to address the current and future risk
as~ociated with a site in the absence of any remedial action
or control, including institutional controls. EPA addressed
the use of institutional controls as a component of remedial
action in comment number 3.
Comment e: ESI presented an evaluation of potential
VQ~i1~Qi~ considered as part of the RI risk assessment and
supplemental risk assessment (FES) and their associate
risks, including the exPosure to contaminated swale
sediments. ESI concluded that contamination present in off-
site groundwater represented the only significant potential
concern at the Dover Landfill.
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Dover MuniciDal Landfill Site
EPA ReSDonse: EPA agrees that the primary risk is the
ingestion of the off-site contaminated groundwater. Based
on the risk assessment performed by HMM for the Supplemental
Risk Assessment, and as stated in the ROD, the risks from
other exposure pathways are within EPA's risk management
goal of 10-4 to 10-'. Because EPA did not consider these
additional pathways a primary threat, EPA did not critically
evaluate ESI's assumptions given that ESI's conclusion was
consistent with that of EPA.
Commen~ r: ESI lists the chemicals regarded as compounds
posing the only significant potential concern at this Site.
These compounds include: arsenic, benzene, methylene
chloride, tetrachloroethylene, trichloroethene and vinyl
chloride. .
EPAReSDonse: EPA agrees that these compounds present a
potential concern at the Site, 'however, this list is not
cQmplete. In addition to the compounds listed by ESI, .HMM
lists ten chemicals of concern. EPA has determined that
these ten compounds are also concern. In particular,
tetrahydrofuran, 1,1-dichloroethene and 1,2-dichloroethane
pose significant risks.
Commen~ a: ESI developed "provisional" RfDs values for
various chemical compounds, where EPA has not published oral
and/or inhalation RfD values in IRIS or HEAST for
noncarcinogenic toxicity endpoints.
EPA ReSDonse: ESI developed "provisional" RfDs for benzene,
tetrachloroethylene, trichloroethylene and vinyl chloride.
EPA did not attempt to quantitatively evaluate the
noncarcinogenic effects of these compounds because the
overriding concern is for the carcinogenic effects. The
Hazard Indices for these compounds, as derived by ESI, are
0.44, 0.0062, 0.0099, and. 0.29 respectively. EPA determined
that those. Hazard Indices for noncarcinogenic effects for
those particular compounds were insignificant when compared
to the Hazard Indices evalua~ed for arsenic (37) and
tetrahydrofuran (24) as presented in the FES Supplemental.
Risk Assessment.
Commen~ h: ESI quotes the conclusion of the EPA's Risk
Assessment Council review of the Risk Assessment Forum's
proposal for quantifying risks associated with oral exposure
to arsenic at Superfund sites. This quote states that the
"qualities, and. uncertainties could, in a specific risk
management situation, modify one's concern downward as much
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Responsiveness Summary
Dover Municical Landfill
Site
as an order of magnitude". ESI states that the risk
assessment(s) utilized the findings and all the
recommendations of the Science Advisory Board's review of
the arsenic issues develop provisional slope. factors for
quantifying increased risks resulting from ingestion of
inorganic arsenic. . .
EPA ReSDonse: ESI has factored in the so-called risk
management factor into the derivation of the cancer potency
factor for daily intakes of 2.86 x 10-3 or less. EPA does
not include this risk management factor in calculating the
risk assessment, but, rather uses it as a risk manaaement
factor in determining cleanup levels for a site. The use of
this risk management factor in estimating risks would result
in the risk estimate being decreased by a magnitude of order
(ten-fold). . .
comment i: ESI states "An BCL of 0.005 mg/l and an MCLG of
zero concentration in drinking water has been proposed" for
tetrachloroethylene. In addition, ESI lists an MCL for
toluene at 2000 ug/l and a Drinking Water Equivalent Level
(DWEL) for methylene chloride at 2000 ug/l. These values
were presented in Tables comparing chemical .concentration
levels found at the site and BCLs or other advisories.
EPA ReSDonse: The MCL for tetrachloroethylene at 5 ug/l and
the MCLG at zero has been finalized. The MCL for toluene
has been finalized at 1000 ug/l. EPA used the proposed MCL
(5 ug/l) and MCLG (zero) for methylene chloride to set
cleanup levels rather than the DWEL.
Comment i: ESI reports that ~e combined hazard indices for
the three data sets, used in their report, showed
consistency and ranged from 0.9 to 1.2. ESI states that a
value marginally exceeding unity does not indicate a.health
hazard. .
EPA ResDonse: Although ESI concludes that the.
noncarcinogenic effects of contaminants are not of concern,
EPA's assessment indicated a concern with noncarcinogenic
effects of arsenic and tetrahydrofuran: the maximum Hazard
Indices being 37 and 24. respe~tively.
Comment k: 'ESI developed and presented a "provisional" oral
RfD for chloroethane in appendix H of their report (pRfD of
33 mg/kg/day). The Hazard Index for chloroethane was
determined by ESI to be 0.00071 for noncarcinogenic effects.
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Responsiveness Summary
Dover Municinal Landfill Site
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EPA a..DODS.: EPA's Environmental Criteria and Assessment
Office recently provided the Regional Office with an interim
oral reference dose for Chloroethane of 0.4 mg/kg/day. This
oral RfD was derived through extrapolation of the inhalation
reference concentration verified by EPA in December 1990.
The principle toxicological study for the reference
concentration was a developmental inhalation study conducted
by Scortichini, et. al., ~986. The noncarcinogenic effects
of chloroethane, as presented by EPA in the ROD Decision
Summary, is a Hazard Index of 1.0.
zv.
REMAINING CONCERNS
Issues raised during the public comment period that will
continue to be of concern as the RD/RA phase of site
remediation gets underway are listed below. EPA will
continue to address these issues as more information becomes
available during the RD/RA.
1.
Area residents and local officials will wish to be kept
informed of the results of site monitoring. Potential
contamination of bedrock wells and the Bellamy
Reservoir will likely remain a conce~n.
Community members will want assurances that the most
cost effective measures are taken through the entire
remedial process~
Community interest in the Site may rise due to remedial
activity at neighboring Sites such as SomersworthSanitary
Landfill and the Coakley Landfill.
2.
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Responsiveness Summary
Dover MuniciDal Landfill site
ATTACHMENT A
LIST OF FORMAL COMMUNITY RELATIONS ACTIVITIES
CONDUCTED TO DATE AT THE DOVER LANDFILL SUPERFUND. SITE
u
9 August 1983
December 1984
13 December 1984
30 March 1989
15 March 1991
16 March 1991
16 March 1991
22 March 1991
25 March 1991
Meeting held by EPA and the NHDES at the Dover
City Hall to discuss the findings and
recommendations of the Remedial Action Master Plan
(RAMP) .
Community Relations Plan issued for the Dover
Landfill site.
Informational meeting held by NHDES at Dover
City Hall to describe plans for the RIfFS.
Informational meeting held by EPA and NHDES at
Dover City Hall to discuss results of the RI.
EPA Proposed Plan published.
Administrative Record made available for public
review at the EPA office in Boston and at the
Dover Public Library.
EPA press release issued regarding the Proposed
Plan, the public meeting and hearing, and the
opening of the comment period.
EPA published a public notice in the Foster's
Daily Democrat announcing the availability of the
Feasibility Study, Administrative Record; and
Proposed Plan; the public comment period; and the
scheduled meeting and hearing.
Informal meeting held by EPA at the Horne Street
Elementary School to discuss the results of the RI
and FES, and to present cleanup alternatives and
EPA's Proposed Plan. .
26 March 1991- Public comment period on EPA's Proposed Plan.
24 May 1991
16 April 1991
Informal hearing held by EPA on Proposed Plan.
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Responsiveness Summary
Dover Municinal Landfill site
28 June 1991
EPA Responsiveness Summary issued for Record of.
Decision on EPA's Preferred Alternative for the
Dover Landfill Site.
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Responsiveness summary
Dover Municical Landfill site
ATTACBHBNT B
TRANSCRIPT OP '1'JIB APRXL 1", 1"1
INFORMAL PUBLIC BEARING
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
Dover Municipal Landfill Superfund Site
Dover, New Hampshire
DOVER PUBLIC HEARING
April 16, 1991
7:55 p.m.
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Dan C.oughlin, ,
Moderator:
Chief N.H. Superfund
Nancy D. Lowney
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- Ii Cheryl Sprague 5.
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4 I John R. Peltonen 8
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5 i George Maglaras 14
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i David Wright
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7 I Richard Houghton 30
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8 Lee Perlman 40
9 I Thomas Cravens 41
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10 i Hamilton R. Krans, Jr. 42
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11 I Ot i s E. Perry 44
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12 David S. Penniman 46
13 Gerald A. D...~y 48
14 James Richards 49
15 ° Rosie Walker-Bois 51
16 Jim Caliendo 52
.17 Bi 11 Dube 55
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18 i Robert Gallo 56 I
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19 j.' Ga.ry Sear 57 !
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20 I Janet Wall 59
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il Tom Forbes 63
22 I James H. McAddams 65
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23 ' Howard Wi 11 i ams 67
24 Jeanne Shaheen 68
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(Meeting opened 7:55 p.m.)
DAN COUGHLIN:
My apologies for the
inconvenience of making you sit around for a half
hour or so. Our stenographer, as I told you,
called at the last minute and said they couldn't
make it.
I appr.eciate your indulgence.
My name is Dan Coughlin.
I'm Chief of
the New Hampshire Superfund section.
We're here
tonight to conduct a public hearing for the
Remedial Action Proposed Plan Feasibility Study
for the remediation of the Dover Municipal
Landfill Superfund site.
With me to~' Jht up front are Cheryl
Sprague, Remedial Project Manager for EPA, and
Carl Baxter representing the Department of
Environmental Services.
Before we start let me just give you a
quick format on how we'll conduct the meeting.
Cheryl will first give you a very quick discussion:
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on the Proposed Plan itself.
We've mailed out
numerous copies of those Proposed Plans.
If you
don't have one and would like one, we have some up .
over here by Doug, who is from our Human Relations:
office.
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After, we'll hear the comments in the
order in which you find them.
I think we have
about twelve of them. I would reserve the right ~o
ask to limit the comments to about ten minutes.
If you think it's going to run more than ten
minutes, please summarize your comments and give
us a text, full text afterwards, and we'll make
sure that text gets in the record.
All the comments tonight will be
transcribed.
Transcriptions will be available,
and also be responded to in the Responsiveness
Summary, which is part of the Agency's Record of
Decision which is our over-al. Jecision document
for remediation of the site.
would recommend that you do or
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encourage you to do i
The comment period ends May 24th, so if
you're going to submit written comments, and we
so, please make sure they're postmarked by May
24th when you send them into us.
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At the end of the comments I will close
the public hearing and we will be available to
answer questions up front here if anybody has
anything they would like to discuss with me.
And
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Again, I thank you for your putting up
with us in our not having any stenographer.
do the best we can.
We'll
Okay.
Any questions on the format?
I call on Cheryl. -
CHERYL SPRAGUE: Thank you.
My name is Cheryl Sprague.
1'm Remedi a 1
Project Manager for the Dover Landfill Superfund
site.
On March 25~h we held a public meeting.
at the Horne Street elementary school.
Mr.
Richard Pease, from the New Hampshire Department
of Envi ronmenta 1 Servi ces, descri bed t: -
activities during the remedial investigation.
this meeting Mr. Rick Cote, of H.M. and M.
At
Associates, the potential responsible party's
contractor, presented the alternatives that were
retained for detailed analysis and feasibility
study.
And I presented the EPA'sPreferred
Alternative.
Tonight I would like to briefly describe I
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the Preferred Alternative, and then we'll open the;
floor to solicit your comments.
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intersection of Glen Hill and Tolend Road in
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Dover.
It is a 55-acre landfill that operated
from 1960 to 1979, and accepted both municipal and
industrial waste.
The Feasibility Study developed
alternatives that pertained to either source
control or management of migration.
Source
control for thi~ site refers to the landfill, the
perimeter drainage's sediment, the drainage swale
sediment and the groundwater and leachate directly
under the landfill.
The management of migration refers to
the contaminated groundwater when 'it's migrater
away from the landfill.
We refer to this as the
eastern plume and the southern plume.
The EPA Preferred Alternative
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control includes recontouring the existing
landfill and placing a 55-acre multi-layer cap
over the landfill.
There will be construction of
a groundwater and leachate collection system,
which includes the installation of interceptor
trench/extraction wells or a combination of the
two around the perimeter of the landfill to
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There will be use of an on-site powdered
activated carbon treatment system or an equivalent
system to treat the groundwater and leachate with
discharge to the Cocheco River, or we will have
pretreatment with discharge to the Dover Publicly
Owned Treatment Works.
There will also be limited excavation of
the sediments in the drainage swa1e with
deposition back onto the landfill prior to
capping.
The multi-media cap consists of the
following layers.
There will be a vegetative
topsoil, a common fill layer, a drainage layer, a
flexible membrane, low permeability layer.
That
makes up the multi-media portion.
And a gas
ventilation layer covering the waste.
The preferred alternative on the
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Management of Migration includes the use of
institutional controls, where possible, to
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prohibit the use of groundwater, site use and s1te :
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access.
There will be an implementation of a
long~term groundwater monitoring program.
There
will also be the implementing of pre-design
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additional monitoring wells to further define the
lateral extent and depth of contamination.
We
will be conducting one or more pump tests to
determine the ability and rate that the
contaminated groundwater can 'be extracted from the
aquifer.
There will be the attainment of the
target cleanup levels in the eastern plume for
natural attenuation processes such as adsorption,
groundwater extraction wells i~ the southern
with an on-site treatment system, either a
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dispersion and degradation.
There will also be the instal'lation of
powdered activated carbon treatment system or an
equivalent system, wfth recharge back to the
wetlands and or discharge to the Cocheco River.
The cost for t,lItese preferred
to import large volumes of fill material
construct ~he 55-acre cap.
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needed to !
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alternatives is approximately 26 million dollars.
A large portion of these oosts is due to the need
That concludes the presentation.
I will
now turn it back to'Dan to open for any comments.
DAN COUGHLIN:
Okay.
Thank you, Cheryl.
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attorney representing the city of Dover.
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JOHN PELTONEN:
Good evening, ladies and
gentlemen.
For the record, my name is John
Peltonen and I'm an attorney and I'm legal counsel
to the city of Dover in this'matter.
And I .want to thank you for this
opportunity to speak on behalf of the City, and
remi~d you that in the order of sign-up this
evening my remarks will be followed by his Honor,
George Maglaras', mayor of the city of Dover, and
his remarks in turn will be followed by those of
Mr. David Wright, who is the city manager.
First and foremost, the City recognizes
that it has two principal obligations in this
matter.
One is to protect the public health and
the environment.
And in that regard the City has
undertaken several tasks to assure that public
health is assured and is safe.
The second obligation and of equal
importance is to protect the public fisc, that is,
the public treasury.
And the City has a great
concern with the expenditure of tens of millions
of dollars in view of the minimal if any risk
which confronts us, especially since we feel that
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risk otherwise can be controlled.
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We would urge on behalf of the City that
the Agency consider instituting a limited action
proposal alternative along the lines perhaps of
SC-2, holding in abeyance implementation of any
other remedy, because this would provide overtime
protection to human health si,nce there will be no
exposure pathways for ingestion of groundwater,
ingestion of soils, or inhalation of airborne
contaminants.
This site was covered with a vegetative
cover in 1979, pursuant to then existing
regulations. Institutional controls in effect and I
which can be put into effect can prevent the
disturbance of that cover and prevent access
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to prevent ingestion or inhalation.
The City already has provided public
water and has enacted a restrictive use ordinance
to prevent the use of the ground water in that
area.
In fact, from the moment that site was
permitted by the State as a dump site, as a
landfill, the use of that aquifer for drinking
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early '60s.
Institutional controls can be instituted
at the Bellamy to keep the water dammed and
mounded, reversing further flow in , that direction
and creating the equivalent of a hydraulic control
in that area.
And the compliance boundary can and
should be extended out to at least the five
hundred foot level beyond the waste pile,
, consistent with New Hampshire water supply
regulations, WS, part 410.
Evidence already suggests that the plume
;s retracting, probably as a result of the cover
materials already over the site and the drainage
ditch that was installed around the site in the
mid 1980s. Nothing more has been done on the site I
with regard to remediation since that time, and it I
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we can monitor that plume. We are of the oPinion!
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appears conditions are improving.
Before we spend 26 million dollars we
must give a limited alternative a chance, so that
that it presents no realistic threat to health
since the actions already taken, combined with a
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exposure pathways.
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In fact, we would urge you to
consider that construction of the remedy with its
necessary disturbance of the site will create much
greater risk to residents and to the workers than
wouid compliance with a limited action
alternative.
And this factor must be weighed in
the analysis.
Now, we understand the Agency's need to
avoid the time and expense of performing another.
RIFS and a ROD five years from now.
And what we
recommend is to include SC-7Awith modifications,
which I will discuss, but defer its
implementation, because we believe that limited
action with institutional controls over time will
prove to be all we need to protect human health
and the environment.
With regard to the proposed plan which
we urge you to hold in abeyance, clearly the
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Management of Migration component is not
necessary, at least not now.
The plume to the
Bellamy appears to be retracting.
Contaminants
from the landfill probably will not reach the
Bellamy reservoir and we should permit a time to
continue monitoring that area.
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be proven right, and at least implementation
should be deferred to permit that monitoring.
Consideration should be given to
deleting any requirement to install, an up-gradient
interceptor trench, or at least to separate its
flow from that in the down-gradient trench,
thereby reducing the volume of water to be treated
and decreasing the capital costs in the time of
treatment associated with a water treatment
facil i ty.
And the compliance boundary should be
set away from the edge of the waste pile to permit
a more realistic ability to reach desired goals.
We are concerned that the extent of the
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effort proposed is an unnecessary and
extraordinary expenditure of scarce assets when a
limited action alternative can provide adequate
protection over time.
Cost and community
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acceptance are two of your criteria.
Just as you
eliminated an 800 million dollar remedy, we
believe you can eliminate a 26 million dollar
remedy and still protect the public.
Please listen to the comments that you
will hear tonight, and please be flexible in the
development of the ROD to permit limited action
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alternatives and a very delayed and slow ~pproach
to the expenditure of this amount of money.
Now, it's easy, either in an academic ~r
judicial environment, for us to fall into the trap
of tearing each other's positions down.
And all
of us here, everybody here has an obligation to
avoid doing that.
Our task is to work together to
forge an agreement on the most reasonable and fair
response to this situation, and the city of Dover
has been working very closely with the Agency in
this regard and we will continue to do so.
But
it's important, however, for the Agency to I
understand ~.;at the imposition of an' obligation to
pay tens o' millions o' dollars in response to a I
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situation which presents minimal if any risk will
be destructive to the civic and industrial
community of Dover.
Thank you.
DAN COUGHLIN:
Mayor Maglaras.
GEORGE MAGLARAS:
Good evening, and
welcome to our fine City one more time.
The City's actions, to respond along
with the PRP's, has been a commendable one.
We as
a community over many years have been up-front and
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appropriate steps to ensure the public's' health
and safety as it relates to the landfill.
Specifically, I don't want to be
redundant, but the restrictive use of ground water
in the area, we've instal led. water lines in the
area for our residents.
We've instituted proper
zoning regulations to make everyone aware of the
existence of a landfill.
The installation of a
trench and the vegetative cover as well, and the
pursuit of other institutional controls~ and we
have fully cooperated with the State and Federal
officials as progress has surely been made and we
will continue to do
But as mayor of the city
of Dover, it is the city council's official
position that we stand in opposition to the EPA's
Preferred Alternative, and would announce our
preference for a limited action alternative which
may be modified through future negotiations.
Given the demographics and the
socioeconomic conditions of our community, to
apply our limited resources to fund a 25 million
dollar project of this type, given the minimal
threat the landfill imposes, is at best il1-
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I don't want you to mi~understand what
I'm saying, because we stand ready to accept our
responsibility and not bury our heads in the sanu;
however, gi ven all that we face as a communi ty and
as a State and as a nation, we should be able to
work together t~ bring about a common-sense
resolution to this issue, which will surely
enhance and promote our quality of life.
Thank
you.
DAN COUGHLIN:
David Wright, city
manager, city of Dover.
DAVID WRIGHT:
Thank you.
Wright.
For the record, my ..~1ne is David B.
I live at 203 Henrila Avenue, and since
February of last year I have been the town
administrator, city manager of this community.
I want to start off by talking about
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what this really means.
Everett Dirkson, one of
my favorite U.S. Senators said: You know, a
billion here, a billion there, it adds up to real
money.
That's just what we have here.
We've
got a million here, a million there, and it gets
1 os t.
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if you're far away and don't see how it affects
the community and what 25 million means in terms
of alternatives to this community.
I may want to
go work through some of those economics.
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The Tolend Road landfill, 5C-5, which is
Source Control Preferred Alternative of the EPA
and the Migration of Management option chosen by
the EPA at a total cost of 'almost 26 million
dollars, 25,954,000.
If you divide it into the
population of the two cities involved, Madbury ~nd
Dover, it is $2,975 per person on a capital
expenditure, not including interest, on a capital
expenditure.
To put that in perspect:. ., to equal
26 million dollars, you have to go back twelve
years for every single capital expenditure the
City has ever made.
million dollars.
Twelve years equals 26
The average household in this community
pays less than 2 thousand a year, $1997 in taxes;
yet the total cost in capital for this preferred
alternative is $3000 per household in this
community.
You can argue that, or say that that
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it's not to be paid in taxes.
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But frankly, who's
kidding who? This is coming out ~f this
community.
And if it's coming out of the
employers of this community it's going to come out
in the form of wages that they can't take.
The
1ay-offs they're going to make, expansions they're
going to put off, or even plants that they have to
close.
And more importantly, what the City's
share is going to be is going on the taxpayers of
, thi s communi ty.
That's who is going to pay the
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I want to talk about some of what the
impact is of the solution in terms of EPA"s, t~,,,;
City's share that's now currently proposed.
Now,
granted, we don't believe necessarily that we're
But we don't know I
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going to pay this total amount.
because we haven't got the design.
And
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traditionally, the conceptual amount of mo'ney that \,
we have on the table in this just-proposed remedy,
'when we get the design I believe that history
shows has been higher.
And so this is what
hopefully is not a realistic cost but probably
low.
And so maybe our share is high, but the cost
of total construction is way below.
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share based on the formula that has been
publicized that the City would pay the 63 percent,
that is $16,351,000 that the City' would pay
somehow, into a bond or out of the operating
budget.
And just to give yo~ some ideas of what
that is compared to, what that really is,
$16,275,000. is the whole City budget this year as
has been proposed by me, and the city council has
told me to cut it.
They haven't told me how much'
yet, but that's clearly what's"happening.
Which
is no where near, or not as much as your proposed
alternative and our share.
The school budget is $16,500,000.
Madbury's town budget is only $532,000.
Dover's
million dollars as opposed to 16,.
And you
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legal limit., how much we can bond, is only 13
why this figure is frankly ludicrous for the risk
to the public posed by this landfill.
Let's talk about what we're giving up.
What things we would give up to pay for this, and
how maybe they affect public health.
The City's share, I hope, and this ;s a
big hope, of the present sewer treatment plan as
is proposed is a $1,600,000.
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23 million dollar facility down the river that.'s
at least our share. So we could do ten of those
with the amount of money that you're going to
require to close this landfill to protect a
minimal risk.
A fire pumper, just on today's current
business, about $198,000.
We could buy 82 fire
trucks.
That's more than we'd ever buy in this
century and maybe two centuries.
And we're havi ng I
offers from -- we need two and we're having a
terrible struggle to get beyond one within the
operating budget and within the capital budget.
That's 82 pumpers.
We have an iron, manganese problem in
our water wells.
We have numerous wells in the
City, I think in the order of about seven or
eight.
We have one well with an iron, manganese
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plant in it so that people can get decent water
quality.
That cost us $900,000. This particular
expenditure, we could build eighteen of those and
cover all our wells and any wells in the future
with iron, manganese plants, this double
expenditure mandated by the EPA.
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sidewalks up.
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This is 163 years worth of.sidewalk
repair to this community. ' And the City has been -
- as a matter of fact was the test case.
They've
been held liable for anybody that falls down on
the sidewalks by the court system.
We have to pay
if somebody gets hurt, so we have to make .those
kinds of expenditures.
And to put. it in perspective, we need to
build a new public works garage.
The faci 1 i ty now I
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. is a terrible space that directly impacts the
Cocheco River, frankly.
It has more of an impact
on the Cocheco River than probably this particular
landfill does.
And that cost us 3 million
dollars.
That's five of those to build this
landfill to solve a minimal risk.
We need a new elementary school.
We've
been struggling year after year for" five or six
years.
And I think there's some people here from
the school board who will talk about this.
To '
build an elementary school, that costs about 3
million dollars.
There's 4.7 elementary schools
that we could pay for out of that amount of money.
We need a new interchange at Reed
Circle.
This is the State -- ours, of course, and
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the State's share.
The sum of money -- and the
State's money is involved in this, because they
know this is a dangerous circle and people are.
going to die if we don't do something on this
circle. ,And our share's a million dollars.
This landfill, we could build 16 of
those for the amount of money we're going to spend I
capping the landfill on the preferred alternative
selected by the EPA.
For $200 a foot, a running foot, we can
get a first-class water, sewer line, road and
drainage project going.
We could build 81,000
feet of road, almost 82,000 square feet, or 15
miles of new streets for this money.
Some of our streets are in very poor
shape and we need that money.
We can spend -- we
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are currently in active negotiation to build a new ~
industrial park in conjunction with private
'industry, where we would acquire the land and sell
it to people building in, this town, not the
developers but the builders. The total amount of
money we have available for that up to our maximum I
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bond unit at 1 million and 3, $1,135,000.
We
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which would pay for this cleanup over ~ndover
again, that we could build.
It cost us every time we buy a school'
bus $38,000.
We could buy 429 school buses.
That's more than probably the- whole State of New
Hampshire, certainly in this area, for this kind
of money.
And our school bus fleet is aging.
And
those are school children riding it daily.
I guess that's why the City feels that
frankly this amount of money is not only just a :
waste of money, it is a moral bankrupt position
.
and I'm saying that it's taking away from more
pressing public health needs and needs of the
City.
I want to talk a little bit about the
financial situation next.
In the last several
years the city of Dover, not unlike every other
city in the State, is experiencing a downturn in
the economy.
This top line represents tax
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collections.
You can see that they're going.
People are not able to pay their taxes now.
That's the clear bottom line.
Year after year
after year, the last three years, that has risen
to the level of about 6 million.
It has never
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been that level historically.
People cannot pay
their taxes, so we don't have the wherewithal,
and that drives up our costs.
We have to borrow
more.
We don't have the interest on our money.
But that's the taxes that we.now have.
Our sum balance, which' is, well, the way
the world looks is called surplus, perhaps, but
it's the money left over.
It's our reserve.
It's
how much money we have to ,cover any contingencies
on the basis of the government finance accounting,
taking in these accruals is in a negative
position.
Because of that Moody's has dropped the
City's bond rating for an A, for B double A 1,
which is the same level as Massachusetts, or one
step above; I'm sorry, the State of Massachusetts,
which is the lowest in the country.
And that's
the bond rating we have to show these bonds at.
That's the interest rate that's going to bt set
because of that bond rating to float this bond to '
take care of the EPA's Preferred Alternative.
There's some other anecdotal things that
I will share with you.
This is nothing I
prepared.
This came out of the Union Leader, the
newspaper we have in this State.
It's a Monday
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business thing of this week dated today, and it
talks about the level of foreclosures and the
level of bankruptcies in this State.
How they've
reached levels never seen before. I'd like to
have that entered.
And I checked with the Stratford County
Registry of Deeds today. And we've had 186
foreclosures in Stratford County, 72 in the city
of Dover.
That's an historical high that has
never been reached since we've had records, and
this is a very old county.
So the ability to pay
is not there, and everything we have to do we
COll't push on when we have to take it out of the
budget and it becomes an operating cost. That's
just assuming we can bond this, if we can bond
this.
I
Let's go with how it affects the
operating costs of the City.
If we were to take and float a 16
million dollar bond our debt service, principal
and interest, what we have to pay a bank at 7
percent interest --' hopefully which will stay firm i
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if our bond rating doesn't get any worse, because
the direction of our collections or fund balance
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hasn't improved any, it's gotten worse --, is 2
million dollars, almost~
$1,962,000.
What is that? That's my fire
department.
The entire thing.is more money than
we spend there.
That's more money than we spend in
insurance and fringe benefits for all the city
employees and to cover all the insurances for the
City.
That's more than we spend in trash
disposal.
And it's more than what the school
department:~~ends to operate and provide teachers
for the Horne Street School and all the staff and
all associated costs, gas, heat, books,
everything.
It is three times the amount for the
entire parks and recreation budget.
It is probably five times the size of
the entire planning and development of this City,
including building inspection and all those
departments.
The total existing City debt -- we pay
this now -- is 3 million dollars a year.
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almost double that.
The total police department is only 2.5
million.
This is the largest department I have-in
the whole City.
Our property tax values, one dollar
equals, is $501,000.
Hopefully.
That may go
down.
It's certainly not going to increase. This
may be the first year in de~ades where the City
has not had a growth in their tax evaluation. We
may have a negative growth.
We may have more
abatements than we will have tax increases, n~w
evaluations coming on line.
So that's hopefully
the best figure we',~ going to get.
This works
out to almost $4, just to pay for the debt.
rate right now which is just under $50.
Qn a
My whole budget increase which the
council is sending back to me to make a major
change is proposed as $4.40 to cover every
increase that we have after I've bare-boned it.
$0 there's no new programs.
We've offered, you
know, positions that we could.
I sti 11 have $4
tax increases, I have no revenues.
Your bonding
will double, almost double that amount.
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City, I think this is a telling table.
Th is is
how much money since 1959-- now, in 1959, I want
to tell you a secret, I was 9 years old, in
elementary school. Cheryl wasn't born.
I ' 11 tell
you that Dan was, sort of.
about 7.
But he was probably
In 1959 for this year we only spent a
little less than 15 million dollars for City
purposes in bonds.
The schools managed to do a
little less than 10 million dollars. We have the
water department, the sewer department and
all the I
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others.
None of them can equal the Tolend Road
land.';l, an EPA mandate, or the waste water
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treatment plant was an EPA mandate.
Now,
everybody says you're supposed to get State
funding for that, and this is supposed to be our
share, not including the -- you know, there's a 23 \
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million dollar treatment plant, 5 million dollars
of which is coming from you guys.
The rest is
coming from the State of. New Hampshire.
you haven't followed the budgets up here.
1 suppose I
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In
Boston you may not get that.
.that.
They have not funded i
The House budget was passed last week;
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did not include a dime to repay us for the bonds
for this item.
So this is going to go on our tax
rate, this mandate.
We're going to pay all that,
unless there's some change, and the State's in
worse shape than we are, fran.kly.
If you add up every single expenditure
paid for by bonds -- I think it's about 40 million
going back to 1959.
And I'll bet a good 6 million
of that or so is for EPA mandates for other things
doing with the sewer plant, sewer separation and
those kinds of things.
That's 40 million dollars;
that's everything we've ever bonded for all those
years.
If y()
.dd these two projects together,
the waste water treatment plant we were mandated
by the EPA to do, and the Tolend Road project at
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the level we're thinking about that it appears
, we're going to have to pay, that's 40 million
dollars. That equals every bond we've had since I I
was 9 years old. . I
I guess you can see why the City is I
concerned. I understand where you guys are coming I
from.
I understand it that you're concerned about i
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the taxpayers.
The EPA, the Superfund was
established by taxpayers ultimately through, they
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paid money for oil and other, those kinds of
surcharges.
And they set up the Superfund and the
EPA has been very cognizant of that and has acted'
very responsibly toward that to make sure the
taxpayers are not having that money wasted.
But
in this case, to paraphrase my other favorite
politic theorist, Pogo: We have met the taxpayers
and these are them.
These are your taxpayers that
are paying your salary and my salary, and they're
going to be paying for this closure one way or
another in the wages that they can't get or in
taxes.
And I think that deserveS the 'EPA's full
attention on this issu.
I think it deserves the
EPA to look hard at the question of mixed funding
for we have a lot of industries who have gone
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away.
Because if you don't pay for it these
taxpayers, your taxpayers will pay for it.
And
that's basically my remarks to this point and I
have copies of this to enter on the record.
DAN COUGHLIN:
Okay.' Thank you.
Richard Houghton, Chairman, Madbury
Board of Selectmen.'
RICHARD HOUGHTON:
My name is Richard
Houghton.
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Selectmen.
Together with my fellow Selectmen,
Joseph Moriarty anrl Bruce Hodson, both of whom are
with me tonight, 1 speak on behalf of the 1200
residents of the Town of Madbury who potentially
face an enormous liabi1ity exposure thre'ateni ng
the. economic well-being of our town.
For your perspective, my comments are
organized to address just who Madbury is, what
ties Madbury has to the Tolend landfill, and
finally, how Madbury hopes that the EPA's
practical and equitable use of discretion in I
overseeing the future remediation of the site can I
ba 1 ance envi ronmenta 1 and fi SC(l' '~-!.oncerns, nei ther I
'of which is any more important than the other to
our citizens' day-to-day life.
At the conclusion of my statement I wish
to submit my comments, supporting detail in
writing to be made a part of EPA's administrative
record.
When waste disposal operations were
initiated at the To.1er.ut.landfill between 1961 and
1962, the Town of Hadbury had an approximate
population of 556 people. The non-school portion
of our Town budget then slightly exceeded $15,000.
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Excerpts from our Town's Master Plan evidences our
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town's population growth, 704 people by 1970; 987
by 1980; and 1202 by 1988.
Master. Pl an excerpts.
show that only one out of every four Madbury
citizens has been a resident .in town for'more than
ten years.
The building of single-family homes over
the past three decades has.caused our rural
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agricultural town to become in part a bedroom
community, a suburb to Dover, Durham, the
University of New Hampshire, Portsmouth and the I
Seacoast generally. Very few people work in town. I
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Our households are made up primarily of
. 'ried
couples, many with children.
Any remediation costs to be paid by
Madbury citizens will have a significant fiscal
impact on every household.
The Town's
appropriations or budget for the calendar year
1991 anticipate expenditures, excluding school
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costs, of only $532,868.
cost of EPA's proposed remediation plan for the
This is one fiftieth the I
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To1end landfill site as announced by EPA in
midMarch.
Actual town expenditures for fiscal
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15 percent of our local real estate
taxes funds our schools, our town's budget.
An
average family household's tax bill may range fr.om
$3500 to $4000.
Last year's $40.75 tax rate per
$1000 of assessed valuation was allocated as
follows:
$31.13, or 76 percent of the total tax
rate funded the Oyster River School District, a
cooperative school district, including the towns
of Madbury, Durham and Lee.
9 cents, or 1 percent of the total tax
rate funded the Madbury water district.
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$3.35, or 8 percent of the total tax
rate funded Stratford County expenditures.
And finally $6.18 or 15 percent of the
total tax rate funded the 1990 town budget of
$437 , 131. .
A proposed remediation plan costing more
than 50 times the town's current annual budget
opens eyes in Madbury.
Whatever portion Madbury
must bear of a proposed 25 million dollar
remediation plan will ha~e a direct and costly
effect on the $6.18 portion of our current tax
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During the 1960s and '70s, when ,the
To1end landfill was in operation, Madbury's
population varied between only 500 and 800 people.
For so long as the To1end site was being used
there was never any general garbage collection in
town resulting i~ waste disposal 'at the Tolend
landfill.
The majority of town residents disposed
of household trash through personal incineration,
trash burial and private dumps.
Townspeople
contributed negligible waste to the site.
During the same time there were only and
still only three major industries in town.
The Taylor egg farm composted, burned
and buried most of its waste on it's own premises.
Some rotten 'eggs were brought to the To1end
landfill.
Madbury Metals did not even open until
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1975.
The Elliot Greenhouse is also in
Madbury, but both it and'its greenhouses
operations use private dumps on their own
property.
Since 1955 New Hampshire state law has
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facilities for either privately or pUblicly owned
land.
The language of the applicable state
statute, RSA 147:23 was then, just as it is now,.
per RSA 149 M 13, mandatory in its requirement
that a municipality provide for and assure access
to a pUblic disposal facility for garbage and
other solid waste.
The lack of a town dump in Madbury
appears to have been a problem resolved by a
permitting procedure by which a limited number of
Madbury residents could obtain permits to use the
Tolend Road landfill.
Our 1963 Town Report
confirms this arrangement for the limited number
of only 40 families.
Nothing can be confirmed about this
limiting permitted use except for the 1971 payment
of $97 to t~e city of Dover for dump permit fees.
By 1972 lease arrangements were made by
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prior selectmen, presumably in a continued effort
to fulfill state mandates and allow for continued
minimal use of the site by Madbury residents.
general survey of town residents conducted in
A
February of 1988 confirms nothing more than a
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the site my a minimal number of Madbury residents. ! -
Realizing the small town that we are and
the negligible use that we made of the dump, and
while one can well imagine the level of concern
Madbury residents have about thei r - need -and
ability to contribute toward the remediation of
the Tolend landfill site, municipal budgets have
everything to do with the allocation of scarce
financial resources among a wide variety of
community needs.
The Dover landfill cleanup
presents a poteritially greater cost than any other
municipal expenditure in the town's history.
Madbury is environmentally conscious.
-As one example, the town is currently reviewing a
major recodification of our zoning ordinance,
doing away with more typical dimensional
requirement schemes, and instead proposing zoning
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to encourage appropriate use of suitable soils and I
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the protection of aquifers.
However, the
potential joint and several liability to pay for
environment damage as a result of Federal and
State statutes and regulations imposed strictly
and retroactively is of great concern.
Whil e a
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appropriate to assure that any burden shared is
cost effective and one which is reasonably
necessary to eliminate practical health risk while
not financially crippling the town's ability to
address other needs.
The town of Madbury joins in supporting
the comments of the Dover city attorney.
The town of Madbury will join in the
submission of professional comments addressing
EPA's selected proposed plan.
The town of Madbury believes that the
selection of a cost effective remediation, as
required by federal statute and regulation,
requires EPA to compare the marginal benefit and
overly designed remedy will have to the
communities of Madbury and Dover to the more
direct benefits citizens of our municipalities
will obtain by directing scarce tax dollars to
other heeded muriicfpal services and household
budgets.
Any design and implementation of a
Management of Migration remedy must be deferred
until the benefits of Source Control can be
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It was literally with some amazement
that my fellow Selectmen and I listened to EPA's
current assessment of risk to both the Cocheco .
River and the Bellamy reservoir at EPA's public
hearing at the Dover Horne Street School' on
Monday, March 25th.
Much of the immediate and irreparable
harm perceived some years ago has significantly
subsided. Contaminant plumes have been controlled I
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considerably. No one in Madbury would spend large \
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and the previously perceived threat to both the
Cocheco and Bellamy reservoir has lessened
sums of money to design a school which only might
Particularly when:
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become necessary in the future.
future needs might actually differ from present
perceived needs, thus requiring reaesign of any
actually needed school.
If town residents are to support and
fund even a portion of a multi-million dollar
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remediation plan to the Dover Tolend landfill
site, residents will expect the same Yankee
to influence discretionary decisions of the EPA.
The technical comments to be submitted
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seriously and earnestly considered by the. EPA.
Every effort must be made to assure that cost-
effective decisions are made with regard to
choice, design and implementation of remedy.
Federal law mandates EPAto consider cost,
technology, reliability, administrative and other
concerns and their relevant effects on the public
health and welfare and the environment.
Madbury's obligations to educate its
young, extend essential fire and police protection
to all, care for its needy and to provide other
basic municipal services are equally important
provisions for the public health and welfare.
Excessive remedy design, implementation costs will
adversely affect the public health and welfare.
A
cost-effective remedy is justified, but its
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effects will be certain and significant to Madbury -I
residents and the essential municipal services
th~y demand, which together with Madbury's
remediation liability exposure can only be funded
by what has already become
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an overbea ri ng property I
tax burden.
for you.
Thank you.
I do have a submission
DAN COUGHLIN:
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Lee Perlman, Eastern Air Devices.
LEE PERLMAN:
My name is Lee Perlman.
I'm president of Eastern Air Devices.
We are a.
manufacturing company located in Dover.
We have a
150 employees, approximately.40 percent of them
are residents of Dover.
I'm an owner of this business and I'm a
taxpayer in Dover.
I want to say what I have to
say will be short, because much of what has
already been said I want to tell you I.
wholeheartedly endorse and agree with in detail in
terms of the selected remedy and its benefits.
An increment of 20 million,
approximately 20 million dollars is simply not
worth it.
As I see the problem, there isn't an
incentive on the part of the people who are
deciding how much money is to be spent simply
because they're spending other people's money.
There's a very, very small incremental benefit you
get for spending a very,-very large incremental
dollars that doesn't have to be spent because it
can be spent later,. if you follow the Dover
suggestion and the problems can be eliminated.
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The aquifer, the Bellamy can be protected and
decisions can be made on an ongoing basis.
One last point.
To show you how I feel
about the sensitivity for spending money, so far
well over 1 and a half million dollars -- 1 and a
half million dollars has been spent by the PRPs,
and probably, my guess, somewhere between a
quarter of a million. and another half million
dollars has been spent outside of the PRPs or not
counted in the PRP expenditure.
So somewhere
between 1 and 3 quarters and 2 million dollars
have been spent so far on this so-called problem
to remedy th:
~roblem and not a single shovel of
dirt has been moved.
I think that's a telling
DAN COUGHLIN:
Thank you.
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fact that we're spending money capriciously.
recommend that the presentation of the Dover
managers be received carefully and implemented.
Thank you.
Thomas Cravens, Portsmouth Water
Division.
THOMAS CRAVENS:
My name is Thomas
Cravens.
I'm the representative for the
Portsmouth Water Division.
And we certainly
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sympathize with the residents of Dover and Madbury
who have quite a cost and impact to their budget
for this cleanup.
And I think that we are probably seeing
something similar of this sort in our own landfill
that we have declared as a Superfund site, the
Coakley landfill.
However, in the water division
we have a responsibility to our water customers
that we do what we can to protect their drinking
. water and the sources of drinking water.
To that
end we are also working to develop well head'
protection programs to protect our well areas.
And we have written 0: letter to the EPA already
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stating that we support the EPA's proposed cleanup i
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program for this Dover Superfund site. Thank you. i
DAN COUGHLIN:
Hamilton R. Krans, Jr.
D. I .D.A.
Can you tell me what that is?
HAMILTON R. KRANS, JR.:
Yes, I will.
DAN COUGHLIN:
Thank you.
HAMILTON R. KRANS, JR.: My name is
Hamilton Krans.
I live on Hamilton Street in
Dover, and I represent the Dover Industrial
Development Authority, which is the D.I.D.A.
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other members have asked me to speak agai~st the
preferred' action by the EPA and for a more limited
and less expensive alternative.
Dover is in competition with a number of
communities throughout this State and throughout
the Country to attract industry into this City.
One of the ways that we are planning on
doing this and have done so in the past is to
create an industrial park.
As Mr. Wright has
indicated, our bonding capacity now is a little
over 1 million dollars.
I believe he indicated
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that the City's bonding capacity is 13 million
dollars.
What we are fearful
. 'as Mr. Wri ght
indicated, is that this preferred action will
usurp all of the bonding capacity that the City
has.
And consequently I think that one can see
the dire consequences of not being able to compete -
either locally 9r nationally for industries.
Consequently. I won' t bel abor the poi nt. I
but a number of people have testified here tonight I
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concerning the balancing of the good that the
preferred plan would do with the devastating
effect that it would have economically on Dover.
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Development Authority, I can assure you that this
will have a devastating effect on our ability to
compete, to gain industries into this city.
Thank
you.
DAN COUGHLIfi:
Otis Perry.
OTIS PERRY:
Thank you.
My name is Otis
Perry.
I live at 137 County Farm Crossroad in
I'm a member of the city council.
Dover.
I don't have any prepared remarks and I
wasn't sure about the format, so I'll speak off.
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resources issue and a moral issue about how the I
City and the government will distribute our taxes. \
As far as I can see from what I've read' i"
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in the proposed remediation and in the FS that was I
shown, the situation and from what 1 heard you
the cuff.
But I want to emphasize very strongly
my support for the idea that we're talking here
not about just cleaning up the Tole.nd RJ
landfill, we're talking about an allocation of
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say, Mr. Coughlin, at the original public hearing, I
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public meeting at Ho~e Street School, the
situation at the Tol~nd Road landfill is not that
serious.
It is not ~he overriding public health
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ago when we started this process.
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And it. seems to
me that a careful ,well-monitored program of
watching the situation out there, fully prepared
to step in and do whatever is necessary to protect
the public health, if and when the public health
is really threatened by the pollutants in the
ground out there, is a much more preferred
alternative to spending a lot.of money piling dirt
up on top of what is already there, with the hope
that by doing that nothing at all will .happen when
we know that something probably will anyway.
As I said originally, I think of this as
an economi c resource all ocati on issue and the ci.,. !
manager made a very eloquent statement about how
we have to think about spending, allocating our
resources and spending the money we have to
provide the services, public health services for
the people who live in this community and in our
neighboring communities, and I think that
spending this kind of money on this particular
proposal is a waste of that money and is probably
-- well, I won't say that.
waste of money.
I just think it's a
DAN COUGHLIN:
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David Penniman.
DAVID PENNIMAN:. I'm David Penniman, of
51 Evans Road in Madbury.
And I'm a member of the
Oyster River Cooperative School Board, which is
made up of the Towns of Madbury, Lee, and Durham.
As a school board member, certa~nly I'm
charged not only to ensure the quality education
of our children, but even more so in these times
to use scarce fiscal resources effectively.
Education of our children is naturally of prime
importance.
Failure to do so ransoms our future,
but more importantly their future.
We're already strapped for school funds. I
.as we had in our district, a major battle to
reduce spending this last budget cycle, and we
expect another such endeavor this next budget
cycle.
In the town of Madbury, which is the
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smallest of the three towns, 76 percent as already!
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attested to, makes up, of Madbury's tax revenue is I
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for the schools.
And with no industry in town,
being a residential community, you're talking
about people that own homes to produce the tax
base in the town of Madbury.
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as you have portrayed in this particular thing is
just going to kill people when it comes to trying
to keep their homes.
Unfortunately, further monetary
requirements for whatever reason again must be
raised by property taxes.
As you well know in
this State there aren't many other ways to get
more money.
Property taxes seems to be the only
way. Some people are trying other methods, but
it's going to be a long term, if any.
Residents
are already at their limit regarding property
taxes and are strapped just to support our
schools, to say nothing about just trying to
support the minimal town requirements we have in
Madbury.
Monetary requirements on the Town of the
magnitude are you proposing will break the
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barely able to hang onto their homes at this point i
taxpayer's backs.
Many are at the limit and are
just trying to support the taxes required today.
With what you are implying, many will probably
have to lose their homes.
There's no way they can:
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keep them and pay such a tax burden.
We ask a reasonable approach to the
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landfill situation.
I strongly support
environmental protection, but we mustn't go for
the silver spoon approach when a plastic spoon -
approach would do the job in this case.
very much.
Thank you,
DAN COUGHLIN:
Thank you.
Gerald Daley, Dover School Department.
GERALD DALEY:
My name is Gerald Daley.
I'm the superintendent of schools here in Dover.
, And I'm here this evening to ask that the EPA give
careful consideration to one of the les~ costly
but viable alternatives for solving the problem at
the Tolend landfill.
I certainly recognize the
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severity of the problem, but I want to be sure
that I also bring forth the severity of the
school's problems.
We're facing severe budget crunches at
this particular, time, due at least in part to the
ne~ sewage treatment plant which is going on line
very shortly.
I really fear that the impact of this
particular plan, the preferred plan, will have a
serious, very serious effect on our situation.
We i
need a new elementary school in Dover.
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have it because we can't afford it.
We don't have a kindergarten in Dover.
We can't afford it.
This month I sent out reduction force
notices, layoffs, to 26 professional staff people,
including our elementary 1ibrarfans and classroom
teachers on every level.
There's every
possibility that we can't afford them..
We also can't afford continuing costs, ,
continuing hits like the one that may come to us
if the preferred plan goes through.
respect that.
the citizenry.
I have a responsibility to educate
I'm willing to seek less costly
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The EPA has a responsibility to protect
the citizenry from environmental hazards, and I
means to discharge my responsibility and I ask
that the EPA do the same.
Thank you.
DAN COUGHLIN:
Thank you.
James Richards, director of public
works, Dover.
JAMES RICHARDS:
Good evening.
My name
is Jim Richards, 143 Long Hill Road, Dover.
I'm
the director of public works and I agree with all
that has been said before me.
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First, the landfill was closed in
conformance with the standards that existed in
1979.
Second, the pollution plume appears to
be lessening in size and intensity, and doesn't
warrant this type of expense~
Third, as you've seen indicated before
you tonight, the means of payment is more than the
populace can afford.
Lastly, I've built secure, sanitary
landfills that were generally lined, albeit on
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bottom, with clay or membrane.
The proposed
barriers, all of them, vinyl, clay and membrane
are excessive in their approach to protection. :
I believe that monitoring and monitoring i
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only should be required and hopefully a more
common sense design, rather than building a
pyramid of trash -- maybe even to extraction wells
or hydraulic barriers or just some more t.hought
given.
The existing layer, the capping that was
put on in '79 apparently is working fairly
decently.
That's all I have to say.
Thank you.
DAN COUGHLIN:
Thank you.
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Dover Chamber of Commerce.
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ROSIE WALKER-BOIS:
Thank you.
I'm the president of the Greater Dover
Chamber of Commerce, and I'm a resident of Dover
as well.
I represent close to 500 business people
in the commun i ty, most of whom 1i ve here.,
The words that I hear when I go out and
talk with business people in the community -- I'm
in the real estate business myself, and I have an
opportunity to be out and about and talking with
people on a daily basis.
And the words that I
hear them saying is:
Well, we're struggling
along.
We're here for the long haul, but it's
going to be very hard.
We're working very, very
hard for even fewer dollars.
And this is the point that I would like
you to really sincerely keep in mind.
Everybody
is really struggling to try to do their very best
to live and work in this community, to be able to
stay in this community.
And a greater tax burden
is going to make it increasingly difficult for
them.
I see the responsibility here as a two-
part responsibility.
It is your responsibility to
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come up with some kind of a plan to help us, give
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us some ideas of how we can take care of this
landfill, and that's one part of the
responsibility.
The other part of the responsibility is
the fiscal impact on the community.
And I ,
sincerely hope that you will take that part of
your responsibility as seriously as you take the
part of giving us the ideas in the plan put
forward to take care of the hazardous waste.
Thank you.
DAN COUGHLIN:
Thank you.
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Jim Caliendo, tax payer.
JIM CALIENDO:
Good evening.
I
My name is;
Jim Caliendo, and I am a taxpayer, and when I see
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something like this, why. I do get a little irate. I
You've heard from all of the illustrious I-
people here in the city of Dover except a
taxpayer.
questions.
And I'd like to ask a couple of
You said we could ask you some
questions, so I'd like to ask you some.
Number one, why, out of all the
multimillion places that are more contaminated
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Dover?
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DAN COUGHLIN:
I should explain before
we go on with the Questions, we will take
comments. We'll respond to the comments in the
Responsiveness Summary as part of the Record of
Decision.
This is not a Question and answer
session right now.
We'll take down all the
Questions and we can assure you'll be given an
answer in the Responsiteness Summary.
JIM CALIENDO:
Well, I thought I was the
last speaker so I thought I'd throw that in and
give you a chance anyway.
D~' .;OUGHLIN:
JIM CALIENDO:
Okay.
As a taxpayer, as you've
already noted, it would fall on our shoulders to
pay an additional 2 or 3 thousand dollars.
When I
moved to Dbver in 1965 I was paying $400 . year
for taxes.
Now I'm paying in excess of 4000.
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And I do fight city hall and I do fight
the school department and I do fight the public
works and I do fight the fire department and I do
fight the federal government.
And I've seen some places in this State
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54
landfill.
I am also a contractor and I am well
aware that given a given period of time the land
seems to refurbish itself in many cases.
And we
do have facts right here in this City that the
Dover landfill in the last 30 years has receded
from becoming any more hazardous than it was
originally thought to be.
And like a lot of farms that went to
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waste 200 years ago, you can walk in the woods
about the only thing you can see is some stone
fences.
Outside of that, the trees are there, the
pines are there, and
forth. .
We don't see any dead animals out there
around the Dover landfill, we don't see any dead
birds out there and we don't see anything out
there.
We've got shrubs, you've got trees,
everything else is growing out there.
And I just
can't see the government coming in here and asking I
us to spend 26 million dollars when there's really I
no need of it. And I'd like to have you take some I
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real consideration on that fact.
Thank you very
much.
DAN COUGHLIN:
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.Bi 11 Dube.
BILL DUBE:
My name is 8ill Dube.
I
live 242 Dove~ Point Road.
I'm chairman of the.
DOVeT Łconomic Commission.
I'~ 1;ke to make my comments to let you
know how this extensive cleanup will impact the
economy of this City.
I really support a limited action plan
that would ~educe the cost to the city of Dover.
The size of t~is obligation that the City would ~e
incu~ring is t~emendous.
We've heard the city
manager point out that it's as large as our school \
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budget, as la~ge ~s our total city budget.
As a
small businessman in the community, it's 15 to 20
years total salary for our whole dealership.
just -- j1t~ mind-boggling.
I
We need to look at the economic
development, the ability to pay for this if the
City is saddled with this obligation, the increase:
mentioned .before~by other people.
It's just
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in the tax rate, the number of foreclosures, as
to CTeate a problem that will stifle economic
develo-pment.
develo-pment.
There will be no economic
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this City because of the tax rate.
We're going to
stifle all of the growth of the community and I
think that we're going to wind up.either
bankrupting or tremendously crippling this
community that we will not be.able.to go. forward.
I really respect the EPA's abilities,
their knowledge, but please think of us and take a
limited approach that will serve all of us and not
just an extensive cleanup that will serve to
destroy the city rather than clean it.
Thank you.
very much.
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DAN COUGHLIN:
Thank you, sir.
anybody else that would like to comment?
ROBERT GALLO: My name is Robert Gallo,
and I'm counsel for the town of Madbury.
And I
just wanted to add the larger perspective to what
you've heard here.
Assume everything you've heard is true,
and then multiply that by three because of the
impact on the seacoast area of New Hampshire that
results from similar remedies being required at
Coakley in Northhampton and at Somersworth and
here in Dover.
And I think a fair assessment of
the amount of money that's being looked for is
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57
probably in the range of about 70 million dollars.
And you can't miss the fact that those
are not three absolutely isolated communities. .
People in Dover work in the Portsmouth-Northampton
area.
People from Portsmouth-Northampton area
come to Dover to work.
The same kind of exchange
has happened with Dover and 50mersworth.
these are interrelated communities.
I mean,
So once again, everything that you've
heard about what will happen to Dover and Madbury
is absolutely truR. although unfortunately it's
going to be multiplied by three by the general
propo~'.':S you've made for this area.
Thank you.
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DAN COUGHLIN:
Anybody else?
j ''-- /
Okay.
With that I'll close the hearing.
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Do I have somebody else that would like
to comment?
GARY SEAR:
councillor of Warp 3.
My name is Gary Sear.
1'm a
I'd just like to take a
second and respond to some of the comments made
tonight.
You know, when we think of Switzerland
we think of fine chocolate and fine watchmaking.
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58
met, which they do meet every year, but in 1967
there was a gentlemen who introduced an electronic
watch.
And in that time the council of
watchmakers, who were the people that were in the
know of fine watchmaking, decided that it would
never work.
That individual two years later sold
that patent to a Japanese firm and as you know it
today we have what we have, the electronic watch.
Okay?
Now, in 1967 the Swiss had 85 percent of
the watch market and today they have 20
percent of !
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the watch market.
Okay? Because they fai~ed to
1 i sten and to I
~ith the times.
In 1967 I was 14 years old and I had my
first cigarette. A few years after that cigarette I'
packs came out and said it could cause, it could
be hazardous to your health.
I think today -- I
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don't smoke anymore, but they do in fact say it is i
hazardous to your health. Times do change and we I
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have to be cognizant of that, but we all try to do :
the right thing.
We stopped drinking coffee, we
drink decaffeinated coffee until they tell us it's
no longer good for you, and then we go back to
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When I first went in the service they
told me salt tablets were great for you, so they
gave me all kinds of salt tablets. Now they say
I .
it's bad for your blood pressure.
We continue to be in a vicious cycle and
be led by government officials, ~nd I can
perfectly appreciate where you're standing right
now because we all are there from time to time.
But the bottom line is that we are faced with a
decision that has to be made over the next several
months which could effect the future of this City
and could destroy the City if it wasn't dealt with
properly.
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Nobody wants to do the wrong thi ng here, !,--./
and we all want to do the right thing.
I think
consciously we want to do that, but I think there
are alternatives and I think there have been some
presentations made tonight that show that we can
in fact do something that's positive but do it in '
a way that's not going to be a detriment to the
conununity.
And I would strongly urge you to take
those into consideration.
Thank you.
DAN COUGHLIN:
Yes, ma'am.
JANET WALL:
For the record, I'm State
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60
rep. Janet Wa 11 .
I live in the town of Madbury.
I was not going to speak this evening, but I think
I need to join the unanimous voice that you've
heard here tonight that the project you're
planning to implement is going to more than
cripple us, it's going to cripple the next
generation.
In our school district this year we
nearly had a taxpayers' revolt.
We desperately
needed school funds, and yet at the same time
people are crying out saying they simply cannot
afford the property taxes anymore.
Tonight you've heard fl- 'civic leaders
in the city of Dover and the town of Madbury.
,
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any I
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You've heard from businessmen. All of us are
saying the same thing: We simply can't afford
more. As a State rep. I can tell you that the
State of New Hampshire is hurting and hurting
~ .
badly.
That's not political rhetoric, that's
called hard reality.
There's not going to be any
money coming from the State to help the cities and i
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towns this year; we. don't have it.
And I think
you folks from Massachusetts need to realize what
we're feeling up here.
We're no better off than
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Massachusetts.
As a private citizen I need to tell you,
I live in a house that's been in my family sinc~
1740.
Our family has been around since Madbury
was part of the city of Dover, town of Dover at
that time, before it became a town of its own.
In
the years I was growing up in the town of Madbury
our family had land~
Our family had an
alternative means for disposing of our household
waste.
We had an incinerator and we had ways of .
burying and places to bury what we could bury.
the whole time that I have lived in the town of
In
Madbury I believe that our family has mad: :se or
. did make use of the landfill at the Tolend site
approximately two years.
Now, I fully believe in having
responsibility for cleaning up problems that we
have created over time, and I don't abhor the idea!
at all of picking up my share of the
responsibility.
But when I heard the figures
tonight for what I'm going to have to probably pay
as a taxpayer, I'm going to tell you that I am so
crippled at this point financially that 'I'm quite
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house.
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From a household that -- a family,
rather, that once had large portions of land and
more than once house, I live in the old family
homestead on one acre of land.
the vicinity of $4000 a year.
My taxes are in
I have two sons,
-
one of college age, one about,to go to college.
don't know how I'm going to do it.
I
I'm doing the best I can to be fiscally
responsible, and I realize that you know that the
rest of the city of Dover and the town of Madbury
are trying to do the same.
But when you're
dipping into the till for resources there comes a
point when there's nothing left to take.
We now
have gone to the well to draw out for the school
district, we've gone out to handle our major
. '
responsibilities for simply maintaining our
municipalities.
And we've gone to the well so
often and for so much, and we've been so careful,
actually, in how we've done it.
But at the same
time there's just nothing there to take anymore.
We're at a point now where people are leaving the
area because people just cannot afford to live
here anymore.
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consider an alternative plan.
, I'm sure that you will be very careful
in choosing exactly what is best for the cleanup
of that site, and. I have a tremendous amount of
respect for the EPA.
But I ~lso ask that you
consider what a burden it's going to put on us and
our children.
Thank you.
DAN COUGHLIN:
Yes, sir.
TOM FORBES:
Hi.
My name is Tom Forbes.
I'm also chairman of
I live at 254 Tolend Road.
the Dover Planning Board.
Three brave souls.
Welcome to Dover.
I guess I'm just naive, ,and I was just
sitting back there and I talked to a guy next to
me.
I said, "They don't really, they don't'
really propose to mandate this on us, do they?"
And no dfsrespect.
It's just beyond me.
That
kind of money is just beyond me.
You know~ being
on the planning board we work with the CIP and I
have to smile about it.
Because, you know, we sit
there and quibble about fire trucks, but we
quibble about smaller things than that.
Air
conditioners in the library, in the children's
reading room.
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around for two or three years.
64
We don't have the
capability of paying this.
It's just, you know,
preferred plan, that's good.
It's like going to the doctor, you know,
and havi ng an i nj ury to my back and the 'preferred
treatment would be surgery.
Well, I couldn't up
for that.
You know-, I can't feed my fami ly if I'm
laid up for six months.
So I'd say to the doctor:
Well, what else can we do? You know, maybe I can
change my exercising habits, maybe I can change my
diet? What can I do?
What can we do over there and'still not
compromise the water in the Bellamy reservoir or
in the Cocheco.
Again, I guess I'm just naive.
I
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It seems I
to me if you go out there and grade it, if you go
up-slope and divert the water, if you put some
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vegetation back on it, some trees, some grasses,
it seems to me nature mends very well.
And again, you' know, I don't profess to
be a scientist in environmental studies or
anything else.
Just common sense, there must be
things that can be done on an interim basis and
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concern is the protection of the water.
There
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ought to be things that can be started right now
and monitor the situations.
From' what I
understand it's already getting better.
If we do
some simple things out there. maybe we won't have
to go forward with a plan that h~s a price tag
that really is just beyond us.
Thank you.
It's beyond us.
DAN COUGHLIN:
Thank you.
Any last comments?
Yes, sir.
JAMES H. McADDAMS:
My name is James H.
community.
I am a forty-five year resident of this
Was for a lengthy period of time the
McAddams.
executive officer of the chamber of commerce
during a period of years when the community
experienced a large growth and development, and
since 1980 have been a member of the city council,
presently a mayor pro tern of the community.
My remarks are directed in the hope that
EPA might consider one of the ~everal alternatives I
'that have been suggested to the much more
elaborate and expensive program as laid out in
your report and recommendations.
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66
that consideration is worthy of thought.
For one
thing, I have been, as many others have, closely
aware of this particular landfill site since we -
first began to worry about it in the late '70s and
early '80s.
There are at least one or two
features -- and this information may have been
shared earlier.
I'm sorry, I was unable to be
here ~arlier this evening.
But there are at least
two or three features in this landfill that
. perhaps make it somewhat different than some of
the others.
And I think the most important thing
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that I want to emphasize is that from the very
beginning the citizens of this community and the
government of this community have been primarily
interested in the health and welfare in the
residents of this community and the areas nearby.
And consideration of one of the
alternative methods, and I referparticul~rly to
perhaps monitoring, even more extensive monitoring
while we have a chance to learn if any of the bad
effects of this landfill are permeating further
than they are at the present time can be studied.
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67
simply feel that on the basis of the community's
record and being interested in public safety and
its continued interest in wanting that to be the
first and most important thing -- I know that
there's been lots of testimony about the' economic
situation and the terrible impact it might have
upon this community.
So if there's any way
possible, I would want to be one of those who
worked in every way that we possibly could to
support and guarantee public health and safety ~ut
do it in the way that might let us determine what
the problem may be in the future.
Thank you.
DAN COUGHLIN:
Thank you.
Yes, sir.
HOWARD WILLIAMS:
My name is Howard
Wi 11 i ams .
I live at 18 Lisabeth Circle.
I am
also a member of the Dover City Council, and I
couldn't let an opportunity go by, Dan, without
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sharing my views again with you on my feelings on
the landfill.
I certainly support the cleanup the
landfill and protecting the environment at every
opportunity.
I don't want to do anything that
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68
supply of Portsmouth.
I'm certainly concerned
about that, like every member of the Dover City
Council is.
However, as you can see from the
presentation from the city manager of Dover, we
have trained him well in the value of a dollar.
This city council is very fi~cal responsible and
we're working very hard to'control our tax rate.
I would hope that you would look at the
opt ions, an'd don't look at them in terms of the
risk that was present seven or eight or nine'or
ten years ago.
Look at it in terms of the risk
. t~ that's present today. And is this elaborate type I
of a cleanup really merited based on the risk that I
we have present to us today and what looks like
the risk that we could be facing in the future. \
And I certainly want to assure you, and
I'm sure that you would not do otherwise, that you I
would look at this and present to the taxpayer of
Dover a cleanup proposal that ;s both safe and
economically justifiable.
Thanks very much.
DAN COUGHLIN: Thank you.
Anybody else?
JEANNE SHAHEEN:
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69
Dover, I, as a state senator for this district,
can't pass up this opportunity to express my
concern about where the money to fund cleanup will
come from.
As you heard earlier from State
Representative Janet Wall, the State is in. a real
fiscal crisis.
It's my hope that the State senate i
will be able to put back the,funds for the waste
water treatment plant, but if we cannot the city
of Dover is looking at a 13.9 million dollar cost
for the waste water treatment plant.
If that
comes on top of 26 million for the cost of cleanup!
of the landfill, clearly that's a burden that the
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State, the city of Dover, the town of Madbury, the I
other responsible parties and the EPA to reach a I
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1 oca 1 _.lxpayer is not goi ng to be 'able to pay.
Therefore we can hopefully all work together.
cooperative agreement on how we can best cleanup
the 1 andfi 11 in. everyone's best interests.. Thank
you.
DAN COUGHLIN:
Thank you.
What is your
name, please?
JEANNE SHAHEEN:
Yes.
My name is Jeanne
Shaheen, and I'm a resident of the town of
Madbury.
,
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DAN COUGHLIN:
Okay.
Anybody e1,se?
toni ght.
We thank you for your participation
I'd like to remind you that May 24th is
the close of comments.
If you do want to make
written comment, please do so.
Make sure they are
postmarked by May 24th.
The address is included
in the Proposed Plan.
And it's also on the board,
Cheryl tells me.
So we thank you for coming, and
I declare the hearing closed.
We will be here to
answer any questions up front if you'd like.
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C-[-R-T-I-F-I-C-A-T-[
I
to be a ,I
I hereby certify the above 71 pages
true and correct transcription of the tape
recorded on April 16th 1991, .at the Dover Public
Hearing, Dover, New Hampshire, to the best of my
knowledge, skill and ability.
- -
"
Nancy D. Lowney
I
Certified Court Reporter'
Notary Public
'" ..~/'
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Dover Municipal Landfill
NPL Site Administrative Record
Index
ROD Signed: September 10, 1991
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
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Introduction
This document is the Index to the Administrative Record for the. September 10, 1991 Record
of Decision (ROD) for the Dover Municipal Landfill National Priorities List (NPL) site. Section I
of the Index cites site-specific documents and Section n cites guidance documents used by EP A
staff in selecting a response action at the site.
The Administrative Record is available for public review at EP A Region I's Office in Boston,
!vI~~dL.hu::t:i.~~, i111U it\. the Dover Public Library 73 Locust Street, Dover, New Hampshire. This
Index contains confidential documents that are available only for judicial review. Questions
concerning the Administrative Record should be addressed to the EPA Region I site manager.
The Administtative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERa..A), as amended by the Superfund Amendments and
Reauthorization Act (SARA). . .
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L.
Section I
Site-Specific Documents
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1.0
ADMINISTRATIVE RECORD INDEX
for the
Dover Municipal Landfill NPL Site.
. (ROD Signed: September 10, 1991)
Pre-Remedial
1.1
CERCUS Site Discovery
1.2
"Notification of Hazardous Waste Site" Form, EPA Region I (June 8, 1981)
with attached Letter from Jay E. Stephens, City of Dover to Paul Dade, EP A
Region I.
Preliminary Assessment
1.
1.
2.
"Potential Hazardous W aste Si~ Identification and Preliminary Assessment"
Form, EPA Region I (March 13, 1981).
"Potential Hazardous Waste Site Identification and Pre1imii1ary Assessment"
Form, EPA Region I (October 15, 1981).
"Potential Hazardous Waste Site Identification and Prelimirtary Assessment"
Form, EPA Region I (May 3, 1982) with attached National Priorities List
Checklist of Data Requirements.
3.
1.3
Site Inspection
"Potential Hazardous Waste Site - Site Inspection Report" Form, EP A Region I
(September 24, 1981).
Remedial Investigation (RI) and Field Elements Study (PES)
3.0
3.1
1.
Correspondence - Remedial Investigation (RI)
1.
Letter from Paull. Cavicchi, State of New Hampshire Water Supply and
Pollution Control Commission to Judy Bersin (February 23, 1981). ConcerriIng
well water testing on February 11, 1981 and the precautionary recommendation
that the water supply not be used for drinking purposes.
Memorandum from Paul J. Cavicchi, State of New Hampshire Water Supply
and Pollution Control Commission to File (March 23, 1981). Concerning
results of a meeting to discuss groundwater contamination in the vicinity of the
site.
Trip Report on a Visit to Dover Municipal Landfill Site, Tom Roy, State of New
Hampshire Bureau of Waste Management, Susan Hanamoto and Steve
Mangion, EP A Region I (September 24, 1981). Concerning inspection of
contaminated water.
Letter from Dan H. Allen, state of New Hampshire Water Supply and Pollution
Control Commission to Robert Steele, City of Dover (January 15, 1982).
Concerning agreement that a second round of sampling, as recommended by
Camp, Dresser & McKee, is advisable.
Memorandum from John R. Moebes, EP A Region I to Menill S. Hohman, EP A
Region I (August 9, 1983). Concerning transmittal of the second Draft
Remedial Action Master Plan and recommending its release.
2.
3.
4.
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Page 2
3.1
COlTCspondence - Remedial Investigation (RI) (cont'd.)
6. Letter from John F.Zipeto, EP A Region I to Robert D. Steele, City of Dover
(September 14, 1983). Concerning transmittal of the Final Remedial Action
Master Plan.
7. Letter from John F. ZipetO, EP A Region I to Michael Donahue, State of New
Hampshire Water Supply and Pollution Control Commission
(September 14, 1983). Concerning transmittal of the Final Remedial Action
Master Plan. .
8. Letter from Timothy J. Porter, EPA Region I to Jean Doherty (October 4, 1984).
Concerning transmittal of the Final Remed:ial Action Master Plan.
9. Letter from Patrick G. Gillespie, Wehran Engineering Corporation to Richard H.
Pease, State of New Hampshire Water Supply and Pollution Control
Commission (July 1, 1985). Concerning transmittal of the Phase I
Hydrogeological Investigation Report for review.
10. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Patrick G. Gillespie, Wehran Engineering
Corporation (February 14,1986). Concerning the request that additional
background information be submitted and the status of all deliverables be
reported.' .
11. . Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Renny Peny, City of Dover (April 15, 1987)
with attached map of observation wells, "Water Quality Monitoring Data-
OW-I" and "Water Quality MonitOring Data - OW-IA". Concerning
groundwater samples taken from observation wells and notification that the
. lower aquifer (observation well OW-I) is contaminated.
12. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Ferioli (May 17, 1988).
. Concerning negative results of water samples taken from the local water suppl).
we~ . -
13. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Susan Conner (May 17, 1988). Concerning
negative results of water samples taken from the local water supply well.
14. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Thomas Dubois
(May 17, 1988). Concerning negative results of water samples taken from the
local water supply well.
15. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Wagner (May 17, 1988).
Concerning negati.ve results of water samples taken from the local water supply
well. . .
16. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Delp (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well. .
17. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. D. Dubois (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well. .
18. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Nystedt (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well. .
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Page 3
3.1
COITespondence - Remedial Investigation (RI) (cont'd.)
19. Letter from RichardH. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Miles (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
~~ .
20. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Dowaliby (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well. .
21. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. H. Ekola, Sr. (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well.
22. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. ~d Mrs. K. Purrington (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well.
23. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Dumas (May 17, 1988).
Concerning neg'ative results of water samples taken from the local wate~ supply
well.
24. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Doherty (May '17, 1988).
Concerning negative results of water samples taken from the local water supply
well.
25. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Gagnon (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well.
26. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. R. Grant (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well.
27. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. A. Purrington (May 17, 1988).
Concerning negative results of water samples taken from the local water supply
well.' .
28. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Doherty (June 9, 1988).
Concerning negative results .of water samples taken from the local water supply
. well. .
29. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Dubois (December 7, 1988).
Concerning negative results of water samples taken from the local water supply
well.
30. Letter from Richard H. Pease, State of New Hampshire Water Supply and
Pollution Control Commission to Mr. and Mrs. Connors (December 7, 1988).
Concerning negative results of water samples taken from the local water supply
well. '
31. Letter from Richard H. Pease, State of New Hampshire Water Supply and
. Pollution Control Commission to Mr. and Mrs. Thomas Dubois
(October 12, 1989). Concerning negative results of water samples taken from
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Page 4
~.1
COITespondence - Remedial Investigation (RI) (cont'd.)
32. Letter from Richard H. Pease, State of New Hampshire Water Supply"and
Pollution Control Commission to Susan Conner .(October 12, 1989).
Concerning negative results of water samples taken from the local water supply
well. "
3.1
COITespondence - Field Elements Study (FES)
33. Letter from Cheryl L. Sprague for Paul N. Marchessault, EPA Region I tp
Randall L. Lund, Davidson Interior TrimfTextron (July 19, 1989). Concerning
field locations for the proposed monitoring wells.
34. Letter Report from Walter L Graf Ir., GeolResource Consultants, Inc. to
Cheryl L. Sprague, EPA Region I (September 19, 1989). Concerning a
summary of drilling activities for monitoring well MW -10 1 during the period of
August 9-25, 1989." "
35. Letter from Richard C. Cote, HMM Associates, Inc. to Cheryl L. Sprague, EP A
" Region I (January 23, 1990). Concerning transmittal of the pages to be insened
into the January 8, 1990 "Draft Field Elements Study," HMM Associates.
36. Letter from Richard C. Cote,HMM Associates, Inc. to Cheryl L. Sprague, EPA
" Region I (March 6, 1991). Concerning modifications to the Management of
Migration Alternative MM-4. "
,...,
3.2
Sampling and Analysis Data
Sampling and Analysis Data - Remedial Investigation (RI)
Memorandum from C. E. Fuller, Camp Dresser & McKee, Inc. to Don Muldor
(March 23, 1981). Conct:ming analysis of water samples taken from private
residential wells near the site. The following are attached:
A. "Sample & Site Data - Water Analysis - Fonner Landfill Area."
B. "Test Locations - Existing Wells."
C. "Certificate of Laboratory Analysis," Camp Dresser & McKee, Inc.
(April 3, 1981).
D. "CertiflCate of Laboratory Analysis," Camp Dresser & McKee, Inc.
(April 8, 1981). "
Letter from Rance G. Collins, City of Portsmouth to Paul J. Cavicchi, State of-
New Hampshire Water Supply and Pollution Control Commission
(June 5, 1981). Concerning transmittal of the results of surface water samples
for volatile organic analysis.
Letter from Brook S. Dupee, State of New Hampshire Division of Waste
Management to Beattice Fogg, City of Dover (August 10, 1984). Concerning
attached results of a private analysis of water which is discharging from the site
and recommending that direct contact with run-off water be avoided.
The remairUng Sampling and Analysis DatIJ for the Remedial Investigation (Rl) may be
reviewed, by appointment only, at EPA Region I, Boston, Massachusetts.
1.
2~
3.
Sampling and Analysis Data - Field Elements Study (FES)
4.
Letter from Cheryl L. Sprague, EP A Region I to Randall L Lund, Davidson
Interior Trimffextron (October 3, 1989). Concerning the Air Monitoring
Program at the site.
Split Sampling Results, State of New Hampshire Department of Environmental
Services (October 1989).
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Page 5
3.2
Sampling and Analysis Data - Field Elements Study (FES) (cont'd.)
6. Memorandum from David N. Pease, Resource Analysts, Inc. to William Rice,
State of New Hampshire Department of Environmental Services
(November 3, 1989). Concerning the attached: .
A. "Certificate of Approval- Wastewater Analysis."
B. "Certificate of Approval- Drinking Water Analysis."
C. Test results for pesticides, PCBs, and acidlbase/neutral extractable organic
compounds. -
7. Letter from Richard H. Pease, State of New Hampshire Department of
Environmental Services to Cheryl L. Sprague, EPA Region I (January 5, 1990).
Concerning transmittal of attached Chain of C~tody forms and split sampling
results taken at the site on November 12 - 13, 1989.
8. Memorandum from Richard C. Cote, HMM Associates, Inc. to Cheryl L.
Sprague, EP A Region I (March 7, 1990). Concerning the treatability study
work plan and the attached list of wells and parameters to be sampled.
9. Letter from Walter L. Graf Jr., GeolResource Consultants, Inc. to Cheryl L.
Sprague, EP A Region I (March 13, 1990). Concerning the attached data ,
comparison tables for samples split between HMM Associates, Inc. and the
GeolResource ConsultantS, Inc. oversight team between '
November 6 - 11, 1989. '
10. Letter from Cheryl L. Sprague, EPA Region I to Randall L. Lund, Davidson
Interior Trimffextron (January 9,1991). Concerning transmittal of the
"Ambient Air Risk Summary." .
11. Letter from Richard H.Pease, State of New Hampshire Department of '
Environmental Services to Cheryl L. Sprague, EPA Region I (March 7, 1991).
Concerning the results from sampling conducted on February 19, 1991 at
B-8WT and B-8U monitoring wells. .
12. Letter from Richard H. Pease, State of New Hampsitire Department of
Environmental Services to Cheryl L. Sprague, EPA Region I (March 26, 1991).
Concerning the results from sampling conducted on March 8, 1991 from eight
wells at four locations between the Bellamy Reservoir and the Dover Municipal
Landfill.
3.4
The remaining Sampling and Analysis Datafor the Field Elements Study (FES) may
be reviewed, by appointment only, at EP A Region I, Boston, Massachusetts.
Interim Deliverables
Reports - Remedial Investigation (RI)
1.
"Remedial Action Master Plan," NUS Corporation (September 1983).
The maps associated with the record cited as entry rWmber 2 are oversized and may be
reviewed, by appointment only, at EP A Region I in Boston, Massac.husetts.
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"Phase I Geophysical Investigations," Weston Geophysical Corporation for
Wehran Engineering Corporation (March 1985).
"Quality Assurance Project Plan," Wehran Engineering (April 1985).
"Appendices - Quality Assurance Project Plan," Wehran Engineering
(April 1985).
3.
4.
The maps associated with the record cited as entry number 5 are oversized and may be
reviewed, by appoinrment only, at EPA Region I in Boston, Massachusetts.
5.
"Data Report - Phase I - Field Investigations," Goldberg-Zoino & Associates,
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3.4
Page 6
Interim Deliverables (cont'd)
Reports - Remedial Investigation (RI) (cont'd)
6.
"Quality Assurance ProjeCt Plan," State of New Hampshire Water Supply and
Pollution Control Commission (October 1986). . .
Comments - Remedial Investigation (RI)
Comments Dated December 4, 1985 from Richard R Pease, State of New
Hampshire Water Supply and Pollution Control Commission on the March 1985
"Phase I Geophysical Investigations," Weston Geophysical Corporation for
Wehran Engineering Corporation.
Reports - Field Elements Study (FES)
7.
8.
9.
"Quality Assurance Project Plan - Enforcement Support," Jacobs Engineering
Group, Inc. (July 12, 1989). .
"Quality Assurance Project Plan for the Field Elements Study," HMM
Associates, Inc. (August 8, 1989).
3.6. Remedial Investigation (RI) Reports
Reports - Remedial Investigation (RI)
1.
"Volume I - Remedial Investigation," Goldberg~Zoino & Associates, Inc. and
Wehran Engineering Corporation (November 1988).
The 11Il1ps associated with the record cited as entry number 2 are oversized and may b.P '\
reviewed, by appointment only, at EPA Region I in Bosto", Massachusetts.
2.
3.
. ". /
"Volume IT - Remedial Investigation - Tables and Figures," Goldberg-Zoino &
Associates, Inc. and Wehran Engineering Corporation (November 1988).
"Volume ill - Remedial Investigation - Appendices A-H," Goldberg-Zoino &
Associates, Inc. and Wehran Engineering Corporation (November 1988).
"Volume IV - Remedial Investigation - Appendices I & J," Goldberg-Zoino &
Associates, Inc. and Wehran Engineering Corporation (November 1988).
"Section 8 - Risk Assessment - Volume I - Remedial Investigation," Wehran
Engineering Corporation (February 1989).
Reports - Field Elements Study (FES)
4.
5.
6. "Draft Field Elements Study," HMM Associates (January 8, 1990).
7. ''Draft Field Elements Study and Supplemental Risk Assessment," HMM
Associates (May 18, 1990).
8. "Draft Field Elements Study and Supplemental Risk Assessment - Appendices,"
HMM Associates (May 18, 1990).
9. "Fmal Field Elements Study and Supplemental Risk Assessment," HMM
Associates (February 11, 1991).
10. "Final Field Elements Study and Supplemental Risk Assessment - Appendices,"
HMM Associates (February 11, 1991).
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Page 7
Comments - Field Elements Study (FES)
11. Comments Dated January 14, 1991 from Cheryl L. Sprague,EPA Region I on
the May 18,1990 "Draft Field Elements Study," HMM Associates, Inc.
12. Comments Dated January 29, 1991 from Cheryl L. Sprague, EPA Region I on
the May 18, 1990 "Draft Field Elements Study," HMM Associates, Inc.
13. Cross-Reference: Letter from Cyndi Peny, United States Department of the
Interior to Cheryl L. Sprague, EP A Region I (May 24, 1991). Concerning
comments on the February 11, 1991 "Final Field Elements Study and
Supplemental Risk Assessment.," HMM Associates and the February 28,1991
"Final Feasibility Study," HMM Associates, Inc. [Filed and cited as entry
number 2 in 16.1 Correspondence] .
3.7
\V ork Plans and Progress Reports
Work Plans - Field Elements Study (FES)
Reports
1.
"Work Plan for Dover Municipal Landfill Field Elements Study," HMM
Associates, Inc. (August 23, 1989).
Comments
2.
Letter from Cheryl L. Sprague, EP A Region I to Randall L. Lund, Davidson
Interior Trimffextron (September 18, 1989). Concerning EP A approval of the
Field Elements Study QualitY Assurance Project Plan, Field Elements Study
Work Plan, and the Feasibility Study Final Work Plan pending one correction to
the Field Elements Study Work Plan.
Responses to Comments
Letter from Richard C. Cote, HMM Associates, Inc. to Paul Marchessault, EP A
Region I (October 3, 1989) with the attached "FS Field Element Work Plan
Addendum" and "Draft Project Schedule." Concerning the correction requested
by EP A in the September 18, 1989 letter.
Progress Reports - Field Elements Study (FES)
3.
"Monthly Progress Status Report," HMM Associates, Inc. (August 1988).
"Monthly Progress Status Report," HMM Associates, Inc. (September 1988).
"Monthly Progress Status Report," HMM Associates, Inc. (October. 1988).
"Monthly Progress Status Report," HMM Associates, Inc. (November 1988).
"Monthly Progress Status Report," HMM Associates, Inc. (December 1988).
Letter from Sherilyn Burnett Young, Rath, Young, Pignatelli and Oyer (Attorney
for the Settling Parties) to Paul N. Marchessault., EP A Region I
(January 17, 1989). Concerning transmittal of the attached Contract Task
Summary which is a supplement to the monthly progress reports (The cost
information of the Attachment is Withheld as CONFIDENTIAL).
10. "Monthly Progress Status Report," HMM Associates, Inc. (January 1989).
11. "Monthly Progress Status Report," HMM Associates, Inc. (February 1989).
12. "Monthly Progress Status Report," HMM Associates, Inc. (March 1989).
13. "Monthly Progress Status Report," HMM Associates, Inc. (April 1989).
14. "Monthly Progress Status Report," HMM Associates, Inc. (May 1989).
15. "Monthly Progress Status Report," HMM Associates, Inc. (June 1989).
16. "Monthly Progress Status Report," HMM Associates, Inc. (July 1989).
17. "Monthly Progress Status Report," HMM Associates, Inc. (August 1989).
4.
5.
6.
7.
8.
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Page 8
3.7
Work Plans and Progress Reports (cont'd)
Progress Reports - Field Elements Study (PES) (cont'd)
3.9
,18. "Monthly Progress Status Report," HMM Associates, Inc. (September 1989).
19. Memorandum from Richard C. Cote, HMM Associates, Inc. to Cheryl L..
Sprague, EPA Region I (October 16, 1989). Concerning the status of sediment,
surface water, and air sampling.
20. "Monthly Progress Status Report," HMM Associates, Inc. (October 1989) with
attached "Soil Borings - Phase n Summary - 11/10/89."
21. "Monthly Progress Status Report," HMM Associates, Inc. (November 1989).
22. "Monthly Progress Status Report," HMM Associates, Inc. (April 1990).
Health Assessments
4.0
"Health Assessment for Dover Municipal Landfill," Department ofHea1th and
Human Services Agency for Toxic Substances and Disease Registry (A TSDR)
(April 12, 1989). '
Feasibility Study (FS) .
4.1 Correspondence
1.
4.2
Cross-Reference: Letter from Richard C. Cote, HMM Associates to Cheryl L.
Sprague, EP A Region I (March 6, 1991). Concerning modifications to the .
Management of Migration Alternative MM-4 [Filed and cited as entry number 36
in 3.1 Correspondence].
Sampling and Analysis Data
, '\
1.
The record cited in entry number 1 may be reviewed, by appointment only, at EPA
Region I, Boston, Massachusetts.
.
1.
Routine Sampling Results from Selected Wells at the Site (Samples Collected
March 15, 16, and 17,1989) State of New Hampshire Department of
Environmental Services. .
4.6
Feasibility Study (FS) Reports
. Reports
Some figures associated with the record cited as entry number 1 are oversized and may
be reviewed, by appointment only, at EP A Region I in B()ston, Massachusetts.
"Draft Feasibility Study," HMM Associates, Inc. (June 1990).
"Draft Feasibility Study - Appendices," HMM Associates, Inc. (June 1990).
"Draft Feasibility Study," HMM Associates, Inc. (November 1990).
Letter from Richard C. Cote, HMM Associates to Dover Landfill PRP Group
(May 1, 1989). Concerning the attached report. [This document was submitted
. to EPA Region I in November 1990 as "Draft Feasibility Study - Appendices -
Arsenic," HMM Associates, Inc.]
Some figures associated with the record cited as entry number 5 are oversized and may
be reviewed, by appointment only, at EP A Region I in Boston, Massachusetts.
1.
2.
3.
4.
5.
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o
v
Page 9
4.6
Feasibility Study (FS) Reports (cont'd.)
Reports (cont'd.)
6. ''Draft Feasibility Study - Appendices - Groundwater-Remediation Time Frame
Model," HMM Associates, Inc. (January 30, 1991).
7. "Final Draft Feasibility Study," HMM Associates, Inc. (February 6, 1991).
8. "Final Draft Feasibility Study - Appendices," HMM Associates, Inc.
(February 6, 1991). . .
9. Letter from Richard C. Cote, HMM Associates, Inc. to Cheryl L. Sprague, EP A
Region I (February 20, 1991) with the attached "Draft Feasibility Study-
Appendix VIII Estimates of Remediation Time Frame." Concerning the
Groundwater-Remediation Time Frame Model.
10. "Final Feasibility Study," HMM Associates, Inc. (February 28, 1991).
11. "Final Feasibility Study - Appendices," HMM Associates, Inc.
(February 28, 1991).
Comments
12. Comments Dated August 31,1990 from Cheryl L. Sprague, EPA Region Ion
the June 1990 "Draft Feasibility .Study," HMM Associates, Inc.
13. Comments Dated January 4,1991 from Cheryl L. Sprague, EPA Region I.on
the November 1990 "Draft Feasibility Study," HMM Associates, Inc.
14. Cross-Reference: Comments Dated January 29, 1991 from Cheryl L. Sprague,
EPA Region Ion the May 18, 1990 "Draft Field Elements S~y," HMM
Associates, Inc. [Filed and cited as entry number 12 in 3.6 Remedial
Investigation (RI) Reports].
15~ Comments Dated February 20, 1991 from Andrew W. Serell for Sherilyn
Burnett Young, Rath, Young, Pignatelli and Oyer (Attorney for PRP Steering
Committee) on the February 6, 1991 "Final Draft Feasibility Study," HMM
Associates,Inc.
.16. Comments Dated February 22, 1991 from Cheryl L. Sprague, EPA Region I on
the February 6,1991 "Final Draft Feasibility Study," HMM Associates, Inc.
17. Cross-Reference: Letter from Cyndi Perry, United States Department of the
. Interior to Cheryl L. Sprague, EPA Region I (May 24, 1991). Concerning
comments on the February 11, 1991 "Final Field Elements Study and
Supplemental Risk Assessment," HMM Associates and the February 28, 1991
"Final Feasibility Study," HMM Associates, Inc. [Filed and cited as entry
number 2 in 16.1 Correspondence]
Responses to Comments
4.7
18. Correction Guide from HMM Associates, Inc. to the Comments Dated
January 4, 1991 from EPA Region I on the November 1990 "Draft Feasibility
Study," HMM Associates, Inc.
Work Plans and Progress Reports
4.9
"Final Work Plan Dover Municipal Landfill Feasibility Study," HMM
Associates, Inc. (September 8, 1989).
Proposed Plans for Selected Remedial Actions
1. "EPA Proposes Cleanup Plan for the Dover Municipal Landfill Site," EPA
Region I (March 1991).
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5.0
Page 10
Record of Decision (ROD)
5.1
Correspondence
1.
5.3
Letter from Robert I. Gallo, McNeill & Taylor (Attorney for the Town of.
Madbury) to Iohn T. McNeil, EPA Region I (March 26, 1991). Concerning the
request that the public comment period on the March 1991 Proposed Plan be
extended an additional thirty days.
Letter from Andrew W. Serell, Rath, Young, Pignatelli and Oyer (Attorney for
the PRP Steering Committee) to Cheryl L. Sprague, EPA Region I
(March 29, 1991). Concerning the request that the public comment period on the
March 1991 Proposed Plan be extended an additional forty-five days.
Letter from Menill S. Hohman, EPA Region I to Robert I. Gallo, McNeill &
. Taylor (Attorney for the Town of Madbury) (AprilS, 1991). Concerning
notification that the public comment period has been extended thirty days and
will now close on May 24, 1991. .
Letter from Merrill S. Hohman, EPA Region I to Andrew W. Serell, Rath,
Young, Pignatelli and Oyer (Attorney for the PRP Steering Committee )
(April S, 1991). Concerning notification that the public comment period h8$
been extended thirty days and will now close on May 24,1991.
Letter from Philip I. O'Brien and Robert Varney, State of New Hampshire
Department of Environmental Services to Iulie Belaga, EP A Region I
(September 9, 1991). Concerning state concurrence. with the selected remedy.
Responsiveness Summary
2.
3.
4.
5.
1.
Cross-Reference: Responsiveness Summary is an attachment to the
September 10, 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 comment period.
2.
Comments Dated April 12, 1991 from David S. Allen and Richard G. McCann,
City of Portsmouth on the March 1991 Proposed Plan.' .
The record cited as entry number 3 is oversized and may be reviewed, by
appointment only at EPA Region I, Boston, Massachusetts.
3.
4.
"An Updated Public Health Evaluation of the Dover Municipal Landfill," .
Environmental Standards, Inc. for Dover Landfill PRP Group (May 18, 1991).
Comments Dated May 22, 1991 from John and Linda Sibik on the March 1991
Proposed Plan.
Comments Dated May 23, 1991 from Otis E. Periy, Green Fields Farm on the
March 1991 Proposed Plan.
Comments Dated May 23, 1991 from George Maglaras, City of Dover on the
March 1991 Proposed Plan.
Comments Dated May 23, 1991 from Robert I. Gallo, McNeill & Taylor
(Attorney for the Town of Madbury) and Christopher A. Wyskiel, Wyskiel, Boc
& Reid (Attorney for the Town of Madbury) on the March 1991 Proposed Plan
with the attached Exhibits A through P.
Letter from Christopher A. Wyskiel, Wyskiel, Boc & Reid (Attorney for the
Town of Madbury) to Cheryl L. Sprague, EPA Region I (May 24, 1991).
Concerning corrections to be made to the Comments Dated May 23, 1991 on the
March 1991 Proposed Plan.
Comments Dated May 24, 1991 from David B. Wright, City of Dover on the
March 1991 Proposed Plan with the attached financial charts.
S.
6.
7.
8.
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u
o
5.3
5.4
Page 11
Responsiveness Summary (cont'd.)
10. Comments Dated May 24, 1991 from GaryM. Garlield and John A. Gilbert,
Balsam Environmental Consultants, Inc. for the Dover Municipal Landfill PRP
Group on the March 1991 Proposed Plan. .
11. "Comments on the EPA Preferred Remedy for the Dover Landfill Site," Balsam
i::.nvironmental Consultants, Inc. for the Dover Municipal Landfill PRP Group
(May 24, 1991).
12. Letter from Gary M. Garfield and John A. Gilbert, Balsam Environmental
Consultants, Inc. for the Dover Municipal Landfill PRP Group to Cheryl L.
Sprague (May 24, 1991). Concerning the attached "Alternative Remedy for the
Dover Landfill Superfund Site," Balsam Environmental Consultants, Inc. for the
Dover Municipal Landfill PRP Group.
13. "Petitions to the City of Dover, New Hampshire."
The following citation indjcateS a document received by EP A Region I after the
foT71llJl public comment period.
14. Comments Dated May 24, 1991 from Kenneth R. Mahony, City of Portsmouth
on the March 1991 Proposed Plan.
Record of Decision (ROD)
9.0
State Coordination
1.
"Record of Decision," EP A Region I (September -10, 1991).
9.1
Correspondence
1.
"A95 State Clearinghouse Form," State of New Hampshire Office of State
Planning with the following attachments: .
A. "Authorization to File Application," State of New Hampshire Office of
State Planning (October 12, 1983).
B. "Acknowledgement," State of New Hampshire Office of State Planning
(September 22, 1983).
C. "Request for Review of Project Notification," State of New Hampshire
Office of State Planning (September 22, 1983).
10.0 Enforcement
10.3 State and Local Enforcement Records
1.
Letter from David B. Wright, City of Dover to Cheryl L. Sprague, EP A
Region I (February 20, 1991). Concerning an update on the status of the
Municipal Ordinance. .
11.0 r.::::~:~~y Responsible Party
11.7 PRP Steering Committee pocumenis
1.
Letter from Andrew W. Serell, Rath, Young, Pignatelli and Oyer (Attorney for
PRP Steering Committee) to Gretchen M. Muench, EPA Region I
(June 20, 1990). Concerning notification that Rosen Trucking and United
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Page 12
11.7 PRP Steering Committee Documents (cont'd.)
2.
Letter from Andrew W. Serell, Rath, Young, Pignatelli and Oyer (Attorney for
PRP Steering Committee) to Gretchen M. Muench, EPA Region I
(July 6, 1990). Concerning notification that Cleary Oeaners has joined the
Dover Landfill PRP Group. .
Letter from Sherilyn Burnett Young, Rath, Young, Pignatelli and Oyer (Attorney
for PRP Steering Committee) to Cheryl L. Sprague, EP A Region I
(February 27, 1991). Concerning transmittal of the attached signature pages to
the Site Trust Agreement ,
Cross-Reference: Letter from Daniel Coughlin. EP A Region I to Randall Lund,
Davidson Interior TrimlTextron (April 1, 1991). Concerning additional tasks to
be completed under the Administrative Order [Filed and ci~ as entry number 2
in 11.9 PRP-Specific Correspondence].
Cross-Reference: Letter from Gary M. Garfield and John A. Gilben, Balsam
Environmental Consultants, Inc. for the Dover Municipal LandfIll PRP Group to
Cheryl L. Sprague (May 24, 1991). Concerning the attached "Alternative
Remedy for the Dover Landfill Superfund Site," Balsam Environmental
Consultants, Inc. for the Dover Municipal Landfill PRP Group [Filed and cited
as entry number 12 in 5.3 Responsiveness Summaries].
Letter from Young, Rath, Young, Pignatelli and Oyer (Attorney for PRP
Steering Committee) to Daniel Coughlin, EPA Region I (May 30,1991).'
Concerning a response to the April 1 , 1991 Letter from EP A Region I to Randall
Lund, Davidson Interior TrimlTextron regarding additional tasks to be completed
under the Administrative Order.
""0
3.
4.
5.
6.
11.9 PRP-SpeciflC Correspondence
.
1.
Letter from Merrill S. Hohman, EP A Region I to attached list of Addressees
(March 15, 1991). Concerning notification of potential liability for the Dover
. Municipal Landfill site and the invitation to voluntarily participate in the site
cleanup.
Letter from Daniel Coughlin, EP A Region I to Randall Lund, Davidson Interior
Trim/fextron (April 1, 1991). Concerning additional tasks to be completed
under the Administrative Order.
Letter from George A. Thomas, State of New Hampshire Treasury Department
to Cheryl L. Sprague, EPA Region I (May 16, 1991). Concerning the inability
of the City of Dover to fInance sixty-three percent of the site cleanup.
Letter from David B. Wright, City of Dover to Cheryl L. Sprague, EP A Region
I (May 17, 1991). Concerning the attached resolution of the Dover City Council
regarding the site on May 8, 1991.
Letter from David B. Wright, City of Dover to Cheryl L. Sprague, EP A Region
I (May 24, 1991). Concerning confmnation that EPA Region I has received the
May 16, 1991 Letter from David B. Wright, City of Dover to Cheryl L.
Sprague, EP A Region I.
Letter from Roben J. Gallo, McNeil & Taylor (Attorney for the Town of
Madison) to John T. McNeil, EPA Region I (June 6,1991). Concerning the
requested information regarding propeny owned by the Town of Madbury
which may exist between the Dover Municipal Landfill and the Bellamy
Reservoir. '
2.
3.
4.
5.
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Page 13
11.9 PRP-Specific Correspondence (cont'd.)
The map died as an attachmem to the record cited below may be reviewed, by
appointment only, at EPA Region I Boston, MassachusettS.
8.
Letter from David B. Wright, City of Dover to Cheryl L. Sprague, EPA Region
I (June 11, 1991). Concerning the requested infonnation regarding property
owned by the Town of Dover and the attached: .
A. "Hazardous Waste Landfill District I," City of Dover (May 13, 1987).
B. "Health, Public, and Chapter 152 S.treetS and Sidewalks," City of Dover
(April 10, 1991).
C. "Proposed Hazardous Waste Protection Zone Map," City of Dover
(January 28, 1991).
Letter from John E. Peltonen, Stark and Peltonen (Attorney for the City of
Dover) to John T. McNeil, EPA Region I (June 25, 1991). Concerning
notification that the February 1991 "Conducting Remedial
Investigations/Feasibility Studies for CERCLA Municipal Landfill Sites," EP A
Region I should be considered in the Record of Decision.
7.
u
13.0 Community Relations
13.2 Community Relations Plans
1.
"Community Relations Plan," NUS Corporation (July 1985). .
13.3 News ClippingslPress Releases
1. "Environmental News Release," EPA Region I (July 20, 1983). Concerning
notification of a public meeting on August 9, 1983 to discuss the Remedial
Action Master Plan.
2. "Press Release," State of New Hampshire Water Supply and Pollution Control
Commission (April 4, 1984). Concerning the announcement that a Cooperative
Agreement has been reached between the State of New Hampshire and EP A.
3. "Environmental News," ErA Region I (August 16, 1988). Concerning the
announcement that the State of New Hampshire and EP A have reached an
agreement with the City of Dover and eight potentially responsible parties.
4.. "Environmental News," State of New Hampshire Department of Environmental
Services (December 16, 1988) with the attached "New Hampshire Depanmenfof
Environmental Services Background Infonnation for Press Release Announcing
DES Release of the Remedial Investigation." Concerning the release of the
Remedial Investigation Report.
5. "Environmental News," State of New Hampshire Department of Environmental
Services (March 9, 1989). Concerning the announcement that the Risk
Assessment for the site has been released.
6. "Environmental News," EPA Region I (March 15, 1991). Concerning the
announcement that EP A has proposed a $25 million cleanup plan for the site.
7. "Environmental News," EPA Region I (April 5, 1991). Concerning the
announcement that EP A has made a correction in the March 1991 Proposed Plan
and that the public comment period has been extended until May 24, 1991.
8. "Bankruptcy Filing Rate Soars," The Union Leader - Manchester, NH
(April 15, 1991).
9.. . "State Pollution Control Commission Updates Progress at Dover Municipal
Landfill," State of New Hampshire Water Supply and Pollution Control
Commission. Concerning an update of site activities.
10. "State Pollution Control Commission Updates Progress at Dover Municipal
Landfill," State of New Hampshire Water Supply and Pollution Control
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Page 14
13.4 Public Meetings
1.
Cross-Reference: "Environmental News Release," EP A Region I
(July 20, 1983). Concerning notification of a public meeting on August 9. 1983
to discuss the Remedial Action Master Plan [Filed and cited as entry number 1 in
13.3 News ClippingslPress Releases]. .
Attendance Ust, Remedial Action MasterPlan Public Meeting for the Dover
Municipal Landfill (August 9, 1983). .
Meeting Agenda, Remedial Action Master Plan Public Meeting for the Dover
Municipal Landfill (August 9, 1983) .
Memorandum from John F. Zipeto, EPA Region I to Project Files
(August 11, 1983). Concerning the August 9, 1983 Public Meeting.
Meeting Agenda, Public Meeting for the Dover Municipal Landfill
(December 13, 1984) with the attached:
A. "Fact Sheet"
B. "State to Present a Public Informational Meeting on the Dover Municipal
Landfill Remedial Investigation on December 13, 1984," State of New
Hampshire Water Supply and Pollution Control Commission.
Meeting Agenda, Public Meeting for the Dover Municipal Landfill
(March 30, 1989) with the attached "New Hampshire Department of
Environmental Services Dover Municipal Landfill Remedial Investigation."
"Final Summary of the March 25, 1991 Public Informational Meeting on the
Proposed Plan & Feasibility Study," Alliance Technologies Corporation.
Transcript, Dover Municipal Landfill Public Hearing (Apxjl 16, 1991).
"Statement of Richard R. Houghton, Chainnan, Madbury Board of Selectmen
Submitted to EPA Region I at the April 16, 1991 Public Hearing" with attached
Exhibits.
2.
3.
4.
5.
6.
7.
8.
9.
13.5 Fact Sheets
"Fact Sheet," State of New Hampshire Department of Environmental Services
(July 30, 1987). Concerning past remedial actions at the site.
13.6 Mailing Lists
1.
The record cired as entry number 1 is wirhheld as CONFIDENTIAL and available only
for judicial review.
Letter from Richard R Pease, State of New Hampshire Department of
Environmental Services to Paul Marchessault, EPA Region I (April 27, 1989).
Conccm.ing transmittal of the attached mailing list.
14.0 Congressional Relations
1.
14.1 Cone~dence
-2.
1.
Letter from Roben C. Smith, Member of the U.S. House of Representatives to
Michael R. Deland, EPA Region I (pebruary 4,1988). Concerning the issue of
providing credit incentive for private parties to participate in the Remedial
Investigation.
Letter from Paul Keough for Michael R. Deland, EP A Region I to Roben C.
Smith, Member of the U.S. House of Representatives (March 1, 1988) with the
attached Letter from Roben C. Smith, Member of the U.S. House of
Representatives to Michael R. Deland, EPA Region I (February 4, 1988).
Concerning clarification of the results of the admiiristrative order signed on
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Page 15
16.0 Natural Resource Trustee
16.1 Correspondence
,--
, 2.
1.
Letter from Bruce Blanchard, United States Depai1ment of the Interior to David
Webster, EPA Region I (December 29,1988). Concerning the preliminary
natural resources survey.
Letter from Cyndi Perry, United States Department of the Interior to Cheryl L.
Sprague, EPA Region I (May 24, 1991). Concerning commentS on the
February 11, 1991 "Final Field ElementS Study and Supplemental Risk
Assessment," HMM Associates and the February 28, 1991 "Final Feasibility
Study," HMM Associates, Inc. -
Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Cheryl L. Sprague, EP A Region I
(June 5, 1991). Concerning information on a protective ecological level for
arsenic in sediment -
3.
16.3 Natural Resource Trustee Release
Letter from Roben Pavia, U .5. Department of Commerce National Oceanic and
Atmospheric Administration to Dennis P. Gagne, EPA Region I
(March 20, 1990). Concerning the attached Preliminary Natural Resource
Survey.
16.4 Trustee Notification Form and Selection Guide
1.
1.
Letter from Patricia L. Meaney for Menill S. Hohman, EP A Region I to Sharon
Christopherson, United States Department of Commerce National Oceanic and
Atmospheric Administration (May 15, 1987). Concerning the attached "Trustee
Notification Form" and "Guide to Trustee Selection."
Letter from Patricia L. Meaney for Merrill S. Hohman, EP A Region I to William
Patterson, United States Department of Commerce National Oceanic and
Atmospheric Administration (May 15, 1987). Concerning the attached "Trustee
Notification Form" and "Guide to Trustee Selection."
2.
17.0 Site Management Records
17.1 COlTCspondence
Letter from Arthur L. Hoffman, City of Dover to Robert Donovan, Lakes
Region Disposal Co., Inc. (April 10, 1979). Concerning the quantities and
characteristics of the sludge produced by the Dover Sewage Treaanent Plant.
17.7 Reference Documents
1.
The records cited below as entries number 1 and 2 may be reviewed, by appoinrment
only, at EPA Region I, Boston, Massachusetts.
L
2.
"Analytical Methods for the Prediction of Leachate Plume Migration," Douglas
C. Kent, Wayne A. Pettyjohn, and Thomas A. Prickett (Spring 1985).
"Conducting Remediallnvestigations/Feasibility Studies for CERCLA Municipal
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Page 16
17.8 State and Local Technical Records
Repons
..
1.
2.
"Report on Grolmd Water Jnvestigation at 'The Hoppers' for the City of Dover," .
Camp Dresser & McKee, Inc. (March 1971). .
Trip Repon on a Visit to the Dover Municipal Landfill Site, William J: Carter
and Jay Stevens, State of New Hampshire (July 25, 1975). Concerning a soil
site investigation.
"Report on Groundwater Supply Investigations at 'The Hopper's,'" Camp
Dresser & McKee, Inc. (Januaty 1978)..
"Report to the Board of Water Commissioners on New Water Supply Sources
and Improvements," Camp Dresser & M~Kee, Inc. (November 1979).
"Tolend Road Landf1l1 Site Investigation," Camp Dresser & McKee, Inc.
(July 1982).
3.
4.
'. .
5.
Comments
6.
Comments Dated September 21,1982 from Dan H. Allen, State of New
Hampshire Water Supply and Pollution Control Commission on the July 1982
"Tolend Road Landfill Site Investigation," Camp Dresser & McKee, Inc.
The Sampling and Analysis Data for rhe Site Management Records may be
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<1
Section II
-------
13.
14.
15.
GUIDANCE DOCUMEmS
EP A guidance documents may be reviewed at EP A ~egion I, Boston, Massachusetts.
General EPA Guidance Documents
1.
"Protection of Wetlands (Executive Order 11990), Appendix D," Federal Reiister
(Vol. 42), 1977.
2.
U.S. Environmental Protection Agency. Guidance Manual for Minimizini! Pollution from
Waste Disposal Sites (EPA/600/2-78/142), August 1978.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Biode~dation and Treatabilitv of Specific Pollutants ~A/600/9-79/034), October 1979.
3.
4.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Carbon Adso~tion Isotherms for Toxic Or~anics.(EPA/600/8-80/023), April 1, 1980.
5.
-
U.S. Environmental Protection Agency. Office of Water and Waste Management
Evaluatin~ CoverSvstems for Solid and Hazardous Waste. 1980.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Costs of Remedial Response Actions at Uncontrolled Hazardous Waste Sites.
April 15, 1981.
6.
7.
U.S. Environmental Protection Agency. Office ofWatcr and Waste Management.
Eni!ineerin~ Handbook for Hazardous Waste Incineration (SW-889, OSWER Directive
9488.00-5), September 1981.
8.
\
9.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.", j
Evaluatin~ Cover Systems for Solid and Hazardous Waste (Revised Edition) (SW-867,
OSWER Directive 9476.00-1), September 1982.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Linini of Waste Impoundment and Disposal Faci1ities (SW-870, OSWER Directive
9480.00-4), March 1983. .
10.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory. -
Handbook for Evaluatini Remedial Action Technolo~ Plans ~A/60012-83/076),
August 1983.
"Final and Proposed Amendments to the National Oil and Hazardous Substances Pollution
Contingency Plan," .. (Title 40,- Part 300), September 8, 1983.
"National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
Re,ulations (Title 40, Part 300), 1985. .
"National Oil and Hazardous Substances Pollution Contingency Plan," Federal Re~ister
(Vol. 55, No. 46), March 8, 1990. .
11.
12.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Corrimuni~ Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6),
September 1983. .
U.S. Environmental Protection Agency. Office of Research and Development and Office o~
Emergency and Remedial Response. Case Studies 1-23: Remedial Response at Hazardou
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16.
17.
10
, ".
l,
19.
Q
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
Page 18
"National Emission Standards for Hazardous Air Pollutants AsbestOs Regulations," Code of
Federal Re~ulations (Title 40, Part 61), April 5, 1984.
U.S. Environmental ProteCtion Agency. Environmental MonitOring Systems Laboratory.
SoH Sampline Quality Assurance User's Guide (EPA/600/4-,84/043), May 1984.
U, S Environmental Protection Agency. Office of Ground-Water Protection.
Ground-Water Protection Strateay (EPA/440/6-84/002), August 1984.
U.S. Environmental Protection Agency. Environmental Criteria and Assessment Office.
Health Effects Assessment Documents (58 Chemical Profiles) (EPA/54O/1-861001-o58),
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 Re~ster
(Vol. 49, No. 209), October 26,1984.
U.S. Environmental Protection Agency. Hazardous Response Support Division. Standard
Qperatine Safety Guides, November 1984.
U.S. Environmental Protection Agency. ,Office of Solid Waste and Emergency Response.
Field Standard Qperatine Procedures Manual #4: Site EntIy (OSWER Directive
9285.2-01), January I, 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
field Standard Qperatine Procedures Manual #8: Air Surveillance (OSWER Directive
9285.2-03), January I, 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatine Procedures Manual #9' Site Safety Plan (OSWER Directive
9285.2-05), April 1, 1985.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Project Summmy: Settlement and Cover Subsidence of Hazardous Waste
Landfil1s (EPA/600/S2-85/035), May 1985.
U.S. Environmental Protection Agency. Environmental Research Laboratory. EPA Guide
for Minimizine the Adverse Environmental Effects of Cleanup of Uncontrolled
Hazardous-Waste Sites (EPA/600/8-85/008), June 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investieations under CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) (EPA/540/G-85/002), June 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibitity Studies under CERCLA (Comprehensive Environmental Response.
Cm:n-p~sation. and Liability Act) (EPA/540/G-85/003), June 1985.
Record of Decision, McKin, Gray, Maine, EP A Region I, Boston, Massachusetts,
July 22, 1985.
U.S. Environmental Protection Agency. Environmental MonitOring Systems Laboratory.
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36.
37.
38
39.
40.
41.
42.
43.
44.
45.
Page 19
31.
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
Tmdcolo~ Handbook (OSWER Directive 9850.2), August 1, 1985.
'\ .
32.
33.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
Endaneennent Assessment Handbook. August 1985.
.. .
34.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory and Office of Emergency and Remedial Response. Covers for Uncontrol1ed
Hazardous Waste Sites (EPA 54012-85/002), September 1985.
U.S. Department of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational Safety and
Health Guidance Manual for Hazardous Waste Site Activities, October 1985.
35.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Handbook of Remedial Action at Waste Di!iposal Sites (EPA/625/6-85/oo6), October 1985.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook: Remedial Action at Waste Disposal Sites (Revised)
(EP A/625/6-85/oo6), October 1985.
U.S. Environmental.Protection Agency and Michigan Department of Natural Resources.
Field Screenine for Oreanic Contaminants in Sal11Ples from Hazardous Waste Sites,
April 2, 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance Document for Cleanup of Surface Il11Poundment Sites (OSWER Directive
9380.0-6), June 1986. .
~ ./
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook for Stabilization/Solidification of Hazardous Waste
(EPA/540/2-86/001), June 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Remedial Desi~ and Remedial Action Guidance (OSWERDirective
9355.0-4A), June 1986.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Treatment Technoloey Briefs: Altematives to Hazardous Waste Landfills
(EPA/600/8-86/017), July 1986.
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), September 20, 1986.
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.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Mobile Treatment Technoloeies for Superfund Wastes (EPA 540/2-86/003 (f),
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46.
47.
48.
\,
49.
(j
50.
51.
52.
53.
54.
55.
56.
57.
58.
Page 20
U.S. Environmental Protection Agency. Co~hensive 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 Manual (EP A/540/1-86/P60, OSWER Directive
9285.4-1), October 1986.
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.
Interim Guidance on SQperfund Selection of Remeqy (OSWER Directive 9355.0-19),
December 24,1986. .
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Regions I-X; Regional
Counsels, Regions I-X, Director, Waste Management Division, Regions I, IV, V, VIT, and
VITI; 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; Director, Hazardous and Waste Division, Region X;
Erivironmental Services Division Directors, Regions I, VI, and vn (OSWER Directive
9355.0-19), December 24, 1986 (discussing interim guidance on SupeIfund selection of
remedy).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund State-Lead Remedial Project Manaiement Handbook, (EPAlS40/G-87/002),
December 1986. .
U.S. Environmental Protection Agency. Office of Ground-Water Protection. Guidelines
for Ground-Water Classification under the EPA Ground-Water Protection Strateey,
December 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Glossary (WH/FS-86-007), Winter 1986.
U.s. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Technoloey Briefs: Data Requirements for Selectine Remedial Action
Technoloey (EPA/600/Z-87/001), January 1987.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data QualitY Objectives for Remedial ReS1)Onse Activities: DevelQ.p1T1ent Process
(EPA/540/G-87/003, OSWER Directive 9355;0-7B), March 1987.
Letter from Lee M. Thomas, U.S. Environmental Protection Agency to James 1. Florio,
Chairman, Subcommittee on Consumer Protection and Competitiveness, Committee on
Energy and Commerce, U.S. House of Representatives, May 21, 1987 (discussing EPA's
implementation of the Superfund Amendments and Reauthorization Act of 1986).
U.S. Environmental Protection Agency. Quality Assurance Management Staff. Guidelines
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65.
66.
67.
68.
69.
70.
Page 21
59.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency R~se to Addressees ("Regional Administrators, Regions.
I-X; Regional Counsel, Regions I-X; Director, Waste Management Division, Regions I, r
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 Waste Division; Region X;
Environmental Services Division Directors, Region I, VI, and VIT') (OSWER Directive
9234.0-05), July 9, 1987 (discussing interim guidance on compliance with applicable or
relevantand.1lPf''''i]l~~t,.~~ems). . .
60.
Memorandum from Henry L.1..onges~U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I,
IV, V, VI, Vll; and VllI; Director, Emergency and Remedial Response Division, Region II;
Directors, Hazardous Waste Management Division, Regions m and X; Directors, Toxics
and Waste Management Division, Region IX (OSWER Directive 9355.0-20), July 23, 1987
(discussing RllFS improvements).
U.S. Environmental Protection Agency. .Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Recorrl of Decisions, (OSWER Directive
9355.0-21),.July24, 1987.
,/
61.
62.
Memorandum from Francis S. B1a.kc, General Counsel, to J. Winston Poner, Assistant
Administrator for Solid Wasre 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 (OSWER Directive 9481.00-6C,
EPA/530-SW-87-017), July 1987.
63.
64.
/ \
Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response and Gene Lucero, U.S. Environmental Protection
Agency Office of Waste Progmns Enforcement to Waste Management Division Directors,
Regions I-X and EnviromnenW Services Division Directors, Regions I, VI, and VII,
August II, 1987, (discussing land disposal restrictions).
Record of Decision, Davis Liquid Waste, Smithfield, Rhode Island, EPA Region I, Boston,
Massachusetts, September 29, 1987.
'--/
U.S. Environmental Protection Agency. Center for Environmental Research Infonnation.
A Compendium ofTechnolo~ies Used m the Treatment of Hazarrlous Waste
(EPA/62S/8-871014), September 1987.
U.S. Environmental Protection Agency. Office of Research and Development arid Office of
Solid Waste and Emergency Response. Remedial Action Costine Procedures Manual,
October 1987.
U.S. Environmet1tal Protection Agency.- Office of Emergency and Remedial Response.
Public Involvement in the Superfund PrQwam (WHIFS-87-004R), Fa1l1987.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund (WHIFS-87-QOIR), Fall 1987.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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'"
80.
81.
82.
83.
Page 22
71.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Region I-X (OSWER
Directive 9834.11), November 13, 1987 (discussing revised procedures for implementing
off-site response actions) with attached "Revised Procedures for Implementing Off-Site
Re:ponse Actions."
::.:. =~~.;~'0~m1ental Protection Agency. Office of Solid Waste and Emergency Response.
Drdft Guidance on CERCLA Compliance with Other Laws Manual (OSWER Directive
9234.1-01), November 25, 1987.
~.,
73.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Draft Guidance on CERCLA Compliance with Other Laws Manual (OSWER Directive
9234.1-01), August 8, 1988.
74.
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.
75.
"Estimated Soil Ingestion Rates for Use in Risk Assessment," Risk Analysis
(Vol. 7, No.3), 1987.
76.
US. Environmental Protection Agency. Hazardous Evaluation Division. Laboratory Data
Validation Functional Guidelines for Evaluatini Orlranics, Febmary 1, 1988.
77.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response
and Office of Research and Development The Superfund Innovative TechnoloiY
Evaluation Prowam: Prowess and Accomplishments (EPA/540/5-88/001), February 1988.
78.
Record of Decision, Keefe, Epping, New Hampshire, EP A Region I, Boston,
Massachusetts, March 21, 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Conductin~ Remedial Investi~ations and FeasibilitY Studies under
CERCLA (Comprehensive Environmental Response. Compensation. and LiabilitY Act),
March 1988. -
79.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Conductin~ Remedial Investi~ations and FeasibilitY Studies
under CERCLA (Comprehensive Environmental Response. Compensation. and LiabilitY
-&11, October 1988.
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 ll; Directors,
Hazardous Waste Management Division, Regions ill and X; Directors, Toxies and Waste
Manageinent Division, Region IX; Director, Environmental Services Division, Regions I-X
(C~1'=R Directive 9355.0-05), Apri12S, 1988 (discussing RIlFS improvements
follow-up).
U.S. Environmental Protectiori Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated GroundWater at Superfund Sites
(OSWER Directive 9283.1-2), April 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Exposure Assessment Manual (EPA/540/1-88/001, OSWER Directive
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90.
91.
92.
93.
94.
95.
.
Page 23
84.
Memorandum fonn 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, vn, and
VITI; 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 Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/540/G-88/oo2,
OSWER Directive 9230.0-3A), June 1988.
,.:..,
85.
86.
U.S. Environmental Protection Agency. Hazardous Site Evaluation Division. Laborat01)'
Data Validation Functional Guidelines for Evaluatin~ Inorranics, July 1, 1988.
87.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Catalo~ of Superfund Pro~ram Directives (Interim Version) (OSWER Directive 9200.7-01),
July 1988.
88.
U.s. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (Comprehensive Environmental Response. Compensation. and Liability Act)
. Compliance with Other Laws Manual (EPA/540/G-89/006, OSWER Directive 9234.1-01),
August 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remeciial Response.
Technol0e:Y Screenine Guide for Treatment of CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) Soils and Sludees (EPA 540/2-88/004),
September 1988. . .
89.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Field Screenine Methods Cataloe. User's Guide (EPA/540/2-88/oo5), September 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance for Conductin~ Remedial Investirations and Feasibility Studies Under CERCLA
(Comprehensive Environmental Response. Compensation. and Liability Act) (Interim Finan
(EPA/540/G-89/004, OSWER Directive 9355.3-01), October 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. -
Community Relations in Superfund: A Handbook (Interim Version), Chapter 6 (OSWER
Directive 9230.0-3B), November.3, 1988. .
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/oo3, OSWER Directive 9283.1-2), December 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
User's Guide to the Contract Laboratory Prowam (OSWER Directive 9240.0-1),
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96.
97.
,.
98.
\
99.
Page 24
Interagency Cooperative Publication. Federal Manual for Identif:yine and Delineatine
Jurisdictional Wetlands, January 1989.
~emorandum from Bruce M. Diamond, U.S. Environmental Protection Agency Office of
Waste Programs Enforcement et al. to Addressees ("Directo~, Waste Management
Division, Regions I, IV, VII, VITI; Director, Emergency and Remedial Response pivision,
Reg;on IT: Directors, Hazardous Waste Management Division, Regions ill, VI; Director,
Toxic and Waste Management Division, Region IX; Director, Hazardous Waste Division,
Region X"), February 9, 1989 (discussing interim [mal guidance on soil ingestion rares).
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.
100.
U.S. Environmental Protection Agency. Office of Research and Development
ReqJ1irements fQJ" Hazardous Waste Landfill Desi~. Construction. and Closure
(EPA/625/4-89/022), April 1989. . .
101.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARARs Q's & A's (OERR 9234.2-01FS), May 1989.
Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I,
IV, V, VII, VIII et al. (OSWER Directive 9347.2-01), June 5, 1989 (discussing land
disposal restrictions as relevant and appropriate).
102.
103.
Memorandum from Henry L. Longest II and Gerald Emison, EP A Headquarters to .
Addressees ("Regional Waste Management Division Directors; Regional Superfund Branch
Chiefs; Regional Air Division Directors; Regional Air Branch Chiefs; OERR Division
Directors; OAQPS Division Directors"), June 15, 1989 (discussing control of air emissions
from air strippers).
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Land Disposal Restrictions: Summaxy of Requirements. June 1989. .
104.
105..
U.S. Environmental Protection Agency. Risk Assessment Work Group, Region 1.
Sup,plemental Risk Assessment Guidance for the Superf}lnd Pmiram t'Draft Final)
(EPA/901l5-89/001), June 1989.
"Protection of Environment," Code of Federal Re~ulations (Title 40, Parts 190-299),
Revised as of July 1, 1989.
106.
107.
"Land Disposal Restrictions for Certain 'California List' Hazardous Wastes and
Modifications to the Framework (Final Rule)," Federal Reeister (Vol. 52, No. 130),
July 8, 1989. . .
Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division, Region I to Merrill S. Hohman, Waste Management
. Division, Region I (OSWER Directive 9355.0-28), July 12, 1989 (discussing air stripper
control guidance).
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109.
110.
111.
112.
113.
114.
115.
116.
117.
'118.
119.
120.
121.
122.
Page 25
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #1. Overview of RCRA Land Disposal Restrictions CLDRs)
(OSWER Directive 9347.3-QIFS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #2. Complyin~ With the California List Restrictions Under Land
Dispo..al Restrictions lLDRs) (OSWER Directive 9347.3-Q2FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #3. Treatment Standards and Minimum TechnoloiY Requirements
Under Land Disposal Restrictions (LDRs) (OSWER Directive 9347.3-Q3FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #4. Compb.rin~ With the Hammer Restrictions Under Land Disposal
Restrictions lLDRs) (OSWER Directive: 9347.3-Q4FS), July 1989.
U.S. Environmental.Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #5. Determini"e When Land Disposal Restrictions CLDRs) Are
Ap,plicable 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. Obtainine a Soil and Debris TreatabilitY Variance for Remedial
Actions. (OSWER Directive: 9347.3-06FS), July 1989.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance 0" Pn:pari"e Superfund Decision Documents (OSWER Directive
9355.3-02), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Risk Assessment Guidance for Superfund. Human Health Evaluation Manual Pan A,
July 1989.
"RCRA Regulations," Code of Federal Reeulations (Title 40, Part 264), July 1989.
U.S. Environmental Protection Agency. Office of Research and Development. Technical
Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments (EPA/530-SW-89-047), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (Comprehensive Environmental Response. Compensation. and LiabilitY 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. .
Record of Decision, So. Municipal, Petersborough, New Hampshire, EP A Region I,
Boston, Massachusetts, September 27, 1989.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Evaluation of Ground Watet' Extraction Remedies. Volume 1. Summary Repon
(EPA/54012-89/054), September 1989.
Memorandum from Jonathan Z. Cannon, EP A Headquarters to Regional Directors,
October 18, 1989. (Discussing considerations in ground water remediation at
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123.
124.
o
125.
"
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
Page 26
u.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
ReQ)lirements (OSWER Directive 9234.2-04), October 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Ground Water Issue - Perfonnance Evaluation of PutT\P-and-Treat Remediations .
(EPA/540/4-89/005), October 1989.
U.S. Environmental Protection Agency. OSWER Directive Initiation Request Analysis of
Treatabi1i~ Data for Soil and Debris: Evaluation of Land Ban Impact on Use of Superfund
Treatment Technoloiies (OSWER Directive 9380.3-04), November 30, 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Superfund Innovative Technolo~y Evaluation Prowant: TechnoloiY Profiles
(EPA/540/5-89/013), November 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibi1i~ Study: Develo.pment and Screenini of Remedial Action Alternatives
(OSWER Directive 9355.3-01FS3), November 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Gettine Ready Scopini the RI/FS (OSWER Directive 9355.3-01FS1), November 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Remedial Investiiation: Site Characterization and Treatabi1i~ Studies
(OSWER Directive 9355.3-01FS2), November 1989.
U.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
State and~vement in the Superfund Pro~m (9375.5-01/FS), Fa1l1989.
U.s. Environmental Pr:)tection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund - Volume I: Human Health Evaluation Manual
(Part A - Interim Final) (EPA/540/1-89/002), December 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #7. Detenninine When Land Disposal Restrictions CLDRs) are
Relevant and Appropriate to CERCLA Response Actions. (OSWER Directive
9347.3-08FS), December 1989. .
u.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - CERCLA Compliance with State
Requirements (OSWER Directive 9234.2-05/FS), December 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA COtT\Pliance with Other Laws Manual - Overview of ARARs - Focus on ARAR
Waivers (Publication 9234.2-03/FS), December 1989. .
U.s. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
Handbook on In Situ Treatment of Hazardous Waste-Contaminated Soils
(EPA/540/2-90/002), January 1990. .
U.S. Environmental Protection Agency. Risk Engineering Laboratory. PrQject Summary-
State of TechnolQey Review: Soil Vapor Extraction Systems (EPA/600/S2-89/024),
January 1990.
U.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - CERCLA Compliance with the CW A and
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138.
139.
140.
141.
142.
143.
144.
.
Page 27
"National Oil and Hazardous Substances Pollution Contingency Plan," Federal Rt:eisrer
(Vol. 55, No. 46), March 8, 1990, p. 8666.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Detailed Analysis of Remedial Action Altemativt:s (OSWER
Directive 9355.3-01FS4), March 1990.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
ROD Annual Rt:port: FY 1989 (EP AI540/8-90/(06), April 1990.
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'0".
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