United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -88/024
March 1988
&EPA
Superfund
Record of Decision
Keefe Environmental, NH
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30272-101 .
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-88/024
3. Recipient's Accession No.
I 4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Keefe Environmental Services, NH
Isecond Remedial Action
5. Report Date
03/21/88
7. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Keefe Environmental Services (KES) site is located in a semi-rural area in
Epping, New Hampshire. Surface water from sections of this site flows toward a wetland
area to the immediate south. Considerable filling and excavation have occurred at the
site using the materials for site fill, road construction, surface leveling, and dike
construction purposes. In May 1978, Mr. Paul Keefe constructed a chemical waste storage
facility by. establishing drum storage areas, large storage tanks, equipment shelters and
,a bulking area. A 700,000 gallon capacity, synthetically lined, waste lagoon was also
installed. During April 1979, the New Hampshire Bureau of Solid Waste Management
(NHBSWM) and the Division of Public Health Services (DPHS) ordered KES to clean up a
number of leaking storage tanks, ruptured drums, improperly dumped latex waste, and
contaminated soils. At this time, a series of complaints were made by local residents,
concerning strong od'ors attributed to the site. These complaints resulted in legal
action against KES. During September 1979, a surface water and ground water sampling
program identified seven chlorinated hydrocarbons in the ground water wells. This
resulted in the issuance of a second clean up order focusing on the removal of all
. leaking drums, spills, and contaminated soil, daily inspection of drums for leaks, and
reduction in total number of drums stored onsite. Beginning in November 1979, drinking
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Keefe Environmental Services, NH
Second Remedial Action
Contaminated Media: gw, soil, sw
Key Contaminants: VOCs
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
160
22. Price
(See ANSI-Z39.18)
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16. Abstract. Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the
report contains a significant bibliography or literature survey, mention it here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
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(b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names, equipment designators, etc. Use open-
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•••' : 1363 0 - 381-526 (8393) OPTIONAL rOKM 272 MCK (4-77)
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EPA/ROD/RO1-88/024
Keefe Environmental Services, NH
Second Remedial Action
16. ABSTRACT (continued)
water wells of the twelve surrounding residences were sampled by the New Hampshire Water
Supply and Pollution Control Commission (NHWSPCC) for chemical compounds and biological
parameters. The sampling indicated the presence of several VOCs in some wells. Removal
actions initiated between June 1981 and November 1982, and then again in March 1983,
removed 2,029 fifty five-gallon drums, 84 thirty gallon drums, 47 cauldrons and trays,
51 carboys, 1,630 five gallon pails, 124 empty drums, and 10 fiber and 155 miscellaneous
containers. In addition, approximately 4,100 five-gallon drums, 4 five thousand-gallon,
and 4 ten thousand-gallon above-ground tanks were removed from the site. A first
operable unit ROD, signed in November 1983, approved the removal of contents from the
lagoon, lagoon liner, and adjacent contaminated soil. This second operable unit
addresses soil and ground water contaminated with VOCs.
The selected remedial action for this site includes: in-situ treatment of soil using
vacuum extraction with discharge to the atmosphere; and ground water pump and treatment
using air stripping, filtration, and carbon adsorption with discharge to a ground water
recharge area adjacent to the wetland along the site border. The estimated present
worth cost for this remedial action is $6,100,000 with present worth O&M of $4,157,700.
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
Keefe Environmental Services Waste Site
Epping, New Hampshire
STATEMENT OF PURPOSE
This Decision Document represents the selected remedial action for
the Keefe Environmental Services Site developed in accordance with
the Comprehensive Environmental Response, Compensation and Liabil-
ity Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and to the extent practic-
able, the National Contingency Plan (NCP), 40 CFR Part 300 et sea..
47 Federal Register 31180 (July 16, 1982), 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 selected remedy
and determined, through a detailed evaluation, that the selected
remedy is consistent with New Hampshire laws and regulations.
STATEMENT OF BASIS
This decision is based on the administrative record which was deve-
loped in accordance with Section 113(k) of CERCLA and which is
available for public review at the Epping Public Library and the
EPA Library. The attached index identifies the items which com-
prise the administrative record upon which the selection of the
remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected alternative for the Keefe Environmental Services (KES)
Site includes both a source control and management of migration
component.
Source Control Alternative
Source Control Alternative SC-3A - Vacuum Extraction is selected
for treatment of contaminated soils. This alternative will involve
installation of between 13 to 20 vacuum extraction wells in the
unsaturated soils on-site. The number of extraction wells is de-
pendent upon the radius of influence each well exerts within the
soil matrix and will be determined as part of the pilot plant
studies during the design. Unsaturated soils are those which are
above the ground water table.
Four areas at the KES Site will be subject to the vacuum extraction
system. The depth to ground water in these areas varies from 7-10
feet in the central portion of the Site to 3-5 feet in the south-
western corner of the site. For the purposes of cost analysis,
the area proposed for vacuum extraction has been conservatively
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estimated at 150,000 aquare feet. This area will be confirmed
during the pilot plant atudy stage.
This alternative is expected to require relatively little time to
implement. Several vacuua wells can be completed by a single crew
in a day and collection piping and mechanical, equipment can be
installed concurrently. No soil excavation is required. Vapor
extraction can be started upon completion of the system and imme-
diate results realized.
Although the length of time for treatment is dependent upon extrac-
tion efficiency and actual soil area to be treated both of which
need to be further defined during the pilot plant study stage, five
years for treatment has been estimated.
Management of Migration Alternative
MOM-GW3B is selected for the treatment of contaminated ground
water. This alternative involves pumping contaminated ground water
and treating on-site using air stripping, filtration and carbon
adsorption and discharging the treated ground water back to the
ground. Air stripping will be preceded by coagulation/precipita-
tion for metals removal. Although no metals are above water
quality criteria, metals removal is necessary to remove iron from
the ground water to prevent the iron from oxidizing and precipitat-
ing out in the air stripper and causing operational problems.
Ground water extraction will be performed using the existing deep
bedrock well CW-3C located in the center of the Site. In addition,
two collection trenches, 1300 feet and 1000 feet long by 2 feet
wide, will be used to extract water from the sand and gravel
deposits overlying the bedrock. Estimated pumping rate for well
CW-3C is 2-5 gallons per minute and for the trenches is 2 gallons
per minute for a combined rate of 4-7 gallons per minute.
The air stream exiting the air stripper will contain volatile
organic compounds which will be treated using a vapor phase carbon
unit prior to discharge to the atmosphere. Treated ground water
from the air stripper is further treated using granulated activated
carbon to insure the discharge complies with EPA Drinking Water
Quality Standards. EPA estimates that it will take approximately
five years to reach the ground water cleanup goals.
The total present worth cost of the selected alternative is esti-
mated to be approximately 6.1 million dollars. The estimate
includes the present worth capital cost of vacuum extraction of
waste from soils ($1,138,300); the present worth cost of opera-
tion and maintenance for vacuum extraction ($3,193,900); the
present worth capital cost of ground water treatment ($799,000);
and the present worth cost of operation and maintenance for ground
water treatment ($963,800).
The present worth cost of operation and maintenance for vacuum
extraction is based upon a projected cost of $842,500 per year for
five years of operation. The present worth cost of operation and
maintenance for ground water treatment is based upon a projected
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cost of $254,240 per year for five years of operation.
DECLARATION
The selected remedy is protective of human health and the environ-
ment) attains federal and state.requirements that are applicable or
relevant and appropriate and is cost-effective. This remedy satis-
fies the statutory preference for treatment that permanently and
significantly reduces the volume, toxicity and mobility of the
hazardous substances, pollutants and contaminants, as a principle
element. Finally, it is determined that this remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
tfn
Date I Regional Admnistrator
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ROD SUMMARY
KEEFE ENVIRONMENTAL SERVICES
EPPING, NEW HAMPSHIRE
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TABLE OF CONTENTS
Page
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY 3
III. ENFORCEMENT HISTORY AND STATUS 8
IV. COMMUNITY RELATIONS: INVOLVEMENT AND CONCERNS 9
V. EVALUATION OF ALTERNATIVES 9
A. Introduction 9
B. Response Objectives 11
1. Source Control Objectives 11
2. Management of Migration Objectives 12
C. Technology Development and Screening 13
D. Development and Screening of Remedial Action
Alternatives 14
E. Detailed Analysis of Alternatives .... 19
1. SC-1 — NO ACTION 31
2. SC-2 — CAPPING 31
3. SC-3A — IN-SITU TREATMENT (Vacuum Extraction) . 34
4. SC-4A — EXCAVATION OF CONTAMINATED SOILS WITH
ON-SITE TREATMENT (Low Temperature .
Thermal Stripping) . 37
5. SC-4B — EXCAVATION OF CONTAMINATED SOILS WITH
ON-SITE TREATMENT (Soil Washing) ... 39
6. SC-7 — OFF-SITE DISPOSAL (RCRA Landfill) .... 39
7. MOM-GW1 — NO ACTION 40
8. MOM-GW3B — ON-SITE TREATMENT AIR STRIPPING/FIL-
TRATION/CARBON ADSORPTION
(Discharge to Groundwater) 42
9. MOM-GW4A — Off-Site Treatment at TSD Facility . 44
VI. SELECTION OF REMEDY 47
A. Description of the Selected Remedy 47
1. Scope of the Selected Remedy ..... 47
2. Performance Goals of the Selected Remedy .... 55
B. Statutory Determinations 58
1. Protectiveness ...... 59
2. Consistency with Other Environmental Laws ... 62
3. Cost Effectiveness and Utilization of Permanent
Solutions and Alternative Treatment Tech-
nologies or Resource Recovery Technologies to
the Maximum Extent Practicable 63
C. State Acceptance 71
D. Community Acceptance 71
E. Conclusion 71
VII. STATE ROLE '..... 72
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FIGURES
Page
FIGURE I-i LOCATION MAP 2
FIGURE II-l WELL LOCATION MAP 7
FIGURE V-l CONTAMINATED SOILS 35
TABLES
Page
TABLE V-l REMEDIAL TECHNOLOGIES for SOURCE CONTROL 15
TABLE V-2 REMEDIAL TECHNOLOGIES for MANAGEMENT of
MIGRATION 16
TABLE V-3 TECHNOLOGIES APPLICABLE for REMEDIAL
ALTERNATIVES 18
TABLE V-4 TECHNOLOGIES for INITIAL SCREENING 20
TABLE V-5 SCREENING of SOURCE CONTROL ALTERNATIVES 21
TABLE V-6 SCREENING of MANAGEMENT of MIGRATION ALTERNATIVES . 26
TABLE V-7 SC-1, NO ACTION EVALUATION 32
TABLE V-8 SC-2, CAPPING EVALUATION 33
TABLE V-9 SC-3A, VACUUM EXTRACTION EVALUATION 36
TABLE V-10 SC-4A/4B, LOW TEMPERATURE THERMAL STRIPPING/SOIL
WASHING EVALUATION 38
TABLE V-ll SC-7, OFF-SITE DISPOSAL EVALUATION 41
TABLE V-12 MOM-GW1, NO ACTION EVALUATION 43
TABLE V-13 MOM-GW3B, AIR STRIPPING EVALUATION ........ 45
TABLE V-14 MOM-GW4A, OFF-SITE TREATMENT EVALUATION 46
TABLE VI-1 CAPITAL COST for SOURCE CONTROL 49
TABLE VI-2 OPERATION and MAINTENANCE COST for SOURCE CONTROL . 50
TABLE VI-3 CAPITAL COST for MANAGEMENT of MIGRATION 54
TABLE VI-4 OPERATION and MAINTENANCE COST for MANAGEMENT of
MIGRATION 56
TABLE VI-5 GROUND WATER CLEANUP LEVEL RISKS 57
TABLE VI-6 SOIL CLEANUP GOALS • 60
TABLE VI-7A FEDERAL ARARs for ALT. SC-3 64
TABLE VI-7B FEDERAL ARARs for ALT. MOM-GW3B 66
TABLE VI-8 SOURCE CONTROL COST COMPARISON 70
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APPENDICES
Appendix A - Keefe Environmental Services Responsiveness
Summary
Appendix B - Administrative Record Index
Appendix C - State Concurrence Letter
Appendix D - State ARARs
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ROD SUMMARY
Keefe Environmental Services Superfund Site
Epping, Mew Hampshire
j. BITE MAMB. LOCATIOM AMD DE8CRIPTIOM
The Keefe Environmental Services (KES) Site is located in a semi-
rural area just off Exeter Road (Old Rte. 101) approximately two
miles southeast of the municipal center of Epping, Mew Hampshire
(Figure 1-1). A dozen residences lie along Exeter Road near the
site providing housing for more than 30 people. There is a
chicken farm to the west of the site and a dragstrip to the east.
The site occupies six to seven acres of land north of Exeter Road
and south of the Piscassic River.
Topographic relief at the KES Site is low to moderate. The
highest elevations (El. 160+ MSL) occur at the northeast corner
of the Site and the lowest elevations in a wetland (El. 126+ MSL)
to the southwest, toward Exeter Road. Abrupt changes in eleva-
tion (greater than ten feet) are due primarily to excavation and
filling activities.
Two surface streams originate adjacent to the Site. Surface
water accumulating in a wetland area at the northwest corner of
the Site drains northwesterly toward the Piscassic River via a
brook which flows beneath the gravel pit access road. Surface
water from all other sections of the Site flows southward toward
a wetland area immediately south of the Site. Surface water sub-
sequently flows eastward from this wetland area toward the Fresh
River.
The remains of a manmade lagoon are located in the northeast
quadrant of the Site. The lagoon was emptied and breached in
early 1984 by a contractor engaged by the Mew Hampshire Depart-
ment of Environmental Services (DES) formerly known as the Mew
Hampshire Water Supply and Pollution Control Commission
(MRW8PCC). The center of the Site is occupied by three
buildings.
Considerable filling and excavation has occurred at the KES site.
Till materials have been mined from an embankment in the north-
east corner of the Site. The excavated material has been used
for (1) filling portions of the Site located at lower elevations
where standing water tended to accumulate, 2) road construction
at the Site, (3) leveling surfaces in areas formerly used for
drum storage and (4) the construction of the dike for the waste
lagoon.
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LOCUS MAP
KEEFE ENVIRONMENTAL SERVICES SITE
EPPING.N.H.
FIGURE 1-1
2000
2000
SCALE IN FEET
CAMP ORESSER& MCKEE INC.
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XI. SITE HISTORY
On March 28, 1978 Mr. Paul Keefe proposed to construct a chemical
vast* storage facility in Epping, New Hampshire. Under his plan,
AMEX, Inc. vould own the Site and Keefe Environmental Services
(KES), Inc. vould own all buildings and equipment and vould
operate the facility. Both corporations vere controlled by Mr.
Keefe. Subsequent to the Planning Board's approval of the XES
Site plan on May 31, 1978, XES began operation by establishing
drum storage areas, large storage tanks, equipment shelters and a
bulking area. A 700,000 gallon capacity, synthetically lined
vaste lagoon vas also installed. Periodic site inspections vere
made by both State and local officials and recommendations vere
made to improve site operations.
During April 1979, the New Hampshire Bureau of Solid Waste Man-
agement (MHB8WM) and the Division of Public Health Services
(DPHS) ordered KES to cleanup a number of leaking storage tanks,
ruptured drums, improperly dumped latex vaste and contaminated
soils. At this time, a series of complaints vere made by local
residents concerning the strong odors attributed to the KES Site.
As a result of the odor complaints, the Town of Epping instituted
legal action against KES in the Rockingham County Superior Court
in May 1979.
During September 1979, a surface water and ground vater sampling
program vas established. On October 16, 1979, carbon tetra-
chloride and chloroform were detected in the stream to the north-
west of the Site. A second cleanup order issued by the State in
November 1979 declared that it had identified seven chlorinated
hydrocarbons in the KES ground water wells. These chemicals were
methylene chloride, 1,1,1-trichloroethane, 1,1,2-trichloroethane,
trichloroethylene, tetrachloroethylene, carbon tetrachloride, and
chloroform. The order addressed the hazardous conditions at the
XES facility as an imminent hazard under the authority of Chapter
147:54. The order required the removal of all leaking drums, the
cleanup of spills and contaminated soil, the daily inspection of
drums for leaks and reduction in the total number of drums stored
on site. The order also mandated the development of a fire con-
tingency plan and the stabilization of the amount of hazardous
wastes accepted at the facility.
Also, starting in November 1979, drinking vater veils of sur-
rounding residences vere sampled by the Nev Hampshire Water
Supply and Pollution Control Commission (NHW8PCC) for chemical
compounds and biological parameters. This sampling indicated
that some residential veils contained elevated concentrations of
carbon tetrachloride and chloroform in addition to other com-
pounds. Potable vater sampling vas performed for approximately
six months due to suspected surface and ground vater contamina-
tion from the XES Site. The potable vater sampling program vas
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discontinued vhen all chlorinated organic compounds had diminis-
hed to non-detectable levels. Also, in November 1979, KES in-
stalled four new monitoring and observation wells in addition to
the five observation wells which previously had been installed.
In response to the State's November order, KES filed a motion for
a rehearing on December 5, 1979, denying that the conditions at
the bulking and treatment facility in Epping constituted an im-
mediate threat to public health and the environment. Also in
December, a Master's Report, issued by the court in the Town's
litigation, called for cleanup measures similar to those desc-
ribed in the State's November 1979 order and further required
analytical testing of each drum, employee safety equipment and
permission for unannounced on-site inspections by the Town.
Further, in December 1979, after KES filled a wetland area to
allow access to the four newly installed observation wells, the
NHWSPCC issued a wetlands violation notice to Mr. Keefe ordering
KES to refrain from all construction activities until the re-
quisite permits were granted.
On April 23, 1980, a court order specified the basis by which KES
could continue to operate in a safe manner while abating the
problems present on site. The court found that the site, as it
operated at the time, no longer presented a grave and immediate
threat to human public health and the environment beyond its
boundaries. The court stated that the majority of life-threaten-
ing conditions which previously existed had been brought within
acceptable levels of control.
On June 5, 1980, the Attorney General's .Office notified KES of
the State's recommended sampling and analysis procedures for the
new and existing monitoring wells and for the surface waters on
and around the KES Site. The required analytical parameters
included color, chemical oxygen demand (COD), nitrogen, iron,
manganese, chromium, copper, arsenic, potassium, sodium, zinc,
chloride, pH, specific conductivity, sulfate, total dissolved
solids and total organic carbon. A monthly gas chromatographic
scan was recommended to identify and quantify any volatile and
non-volatile organics detected in the sample. Surface waters
adjacent to the KES Site were to be sampled and analyzed on a
quarterly basis.
On January 21, 1981, due to financial constraints, Keefe Environ-
mental Services, Inc. filed for reorganization in Federal Bank-
ruptcy court. Following a court investigation which showed that
a reorganization plan could not be formulated to successfully
operate KES, Mr. Keefe filed for voluntary bankruptcy and the
Site was abandoned.
The lagoon was sampled by EPA on February 17, 1981. EPA declared
an emergency at the KES Site on February 27 because the lagoon
was close to overflowing. EPA's Field Investigation Team (FIT)
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contractor began sit* investigations, including emergency lagoon
berm stabilization work under Section 311(k) of the Clean Water
Act. OB March 3, 1981, the EPA's Emergency Response Team (BRT)
from Edison, Mew Jersey, used a mobile carbon filter unit to draw
the lagoon down 3 1/2 feet. The lagoon was eventually drawn down
four more times.
During the Spring of 1981, rising temperatures caused expansion
of the contents of a number of drums, resulting in drum failures
and leaking of contents onto the ground. The increased tempera-
ture also accelerated the deterioration of drums containing acid.
EPA engaged Marlyn Engineering for a drum stabilisation program
consisting of overpacking, poly-capping, snap-capping or trans-
ferring ruptured drums. A subcontract with Rockingham Security
for a 24-hour security guard at the site was included. These
contracts were funded under the Comprehensive Environmental
Response Compensation and Liability Act of 1980 (CERCLA).
Between June 11, 1981 and November 19, 1982 the State and several
generators engaged in a joint, cooperative cleanup effort. As a
result of this effort the following materials were removed: 2029
fifty-five gallon drums, 84 thirty gallon drums, 47 cauldrons and
trays, SI carboys, 1630 five gallon pails, 124 empty drums, 10
fiber and 155 miscellaneous containers.
EPA engaged a contractor in July 1982 to remove imminent health
hazards (such as shock-sensitives, explosives, water reactives,
toxic gases and spontaneous combustibles) from warehouses at the
KES Site. In addition, storage tank contents were to be removed
as well as all on-site dumpsters. A Remedial Action Master Plan
(RAMP) was prepared and submitted in the Fall of 1982 which
outlined possible future long term remedial actions. In March
1983 the state of Mew Hampshire, through a Cooperative Agreement
with the EPA, removed approximately 4,100, 55-gallon drums, four
5,000-gallon and four 10,000 gallon above ground tanks and seven
dumpsters from the Site. In November 1983, the State contracted
to have the 700,000-gallon lagoon drained and the liner disposed
of.
Tighe and Bond Consulting Engineers were engaged by the NHWSPCC
to perform a Remedial Investigation (RI) in July 1983 and the RI
report was accepted by the NHWSPCC in October 1984. Camp Dresser
£ McKee, Inc. (CDM) was engaged by the NHWSPCC in August 1985 to
perform a Supplemental Remedial Investigation and Feasibility
Study (F8). The results of the RI, supplemental RI and FS are
summarised below. For details please refer to these documents.
As a result of the field investigations conducted by both Tigbe &
Bond Consulting Engineers and Camp Dresser & McKee, Inc., four
•ones of potential soil contamination were delineated. These
•ones were characterized by high organic vapor concentrations in
soil gas samples detected with field monitoring equipment. Three
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of tbe potentially contaminated zones are located at the site
perimeter in low lying areas which receive surface runoff from
the Site. The fourth zone is located on a flat graded area.
Sporadic areas of discolored soil and vegetative stress are lo-
cated within this zone.
Analytical data indicates that the ground water on-site is con-
taminated with volatile organic compounds which, for the most
part, are present in both the shallow bedrock and overburden
aquifers. The distribution of contaminants at the Site suggests
the existence of two possible source areas of contamination. One
area is located in the central portion of the Site in the vicin-
ity of the chemical bulking and storage area. The second area is
located in a wetland at the southwest corner of the site. In
bedrock well CW-3C and overburden well CW-3A which, as shown on
Figure II-l, are both located in the central portion of the site
near the old chemical bulking and storage areas, the concentrat-
ions of volatile organics are approximately 1 ppm and 12 ppm,
respectively. In overburden wells CW-5B and CW-5A, both located
down gradient from CW-3C and CW-3A in the southwest corner of the
Site, total volatile organic concentrations approach 5 ppm and 9
ppm, respectively.
Shallow bedrock contamination in the location of monitoring well
CW-3C may be attributable to leakage between well CW-3A and CW-3C
and not vertical migration through natural materials. Bedrock
contamination in the vicinity of monitoring well CW-5C may have
resulted from cross contamination with the surficial monitoring
well and/or vertical migration of contaminants through natural
materials. Available information indicates there is no wide-
spread contamination of the bedrock aquifer.
The elevated concentrations of ground water contamination present
in overburden well CW-3A suggest that the source of contamination
in this area may originate in the central portion of the site in
the vicinity of the chemical bulking and storage areas. Contami-
nation in overburden wells CW-5A and CW-5B is thought to origi-
nate from contaminated surface runoff from the site which pooled
in this area and infiltrated into the ground water.
Residential well data, obtained throughout the remedial investi-
gation indicate that nearby residences are not being affected by
contaminants from the KES Site. Data suggests that the residen-
tial wells south of the Site are supplied from the bedrock and
overburden aquifers which flow from the south toward the Site.
Volatile organic contaminants have been detected in streams
originating in the vicinity of the KES Site. However, the
concentrations of volatile organics decrease to below detectable
quantities within 500 feet of the Site. Based upon these obser-
vations, it is suggested that surface flow does not provide a
pathway for contaminant migration from the Site.
-------
, IM
X'v
FIGURE n-1 ,
SURFICIAL POTENTIOMETRIC SURFACE MAP
HOWTN
LEOCNO
Wli ObvnoMl Wtiliii Elevations
-------
8
Contamination at the KES site is alleged to have originated from
leaking storage tanks, ruptured or leaking drums and from leaking
in ground bulking vats. These source materials were eliminated
during the initial removal activities/ however, there is con-
tamination present in the soil, ground water and surface water.
The health risks associated with present conditions at the KES
Site were evaluated for ingestion of contaminated well water,
dermal contact and subsequent ingestion of contaminated surface
soils and dermal contact with surface waters. At the present
time there are no detected contaminants in residential water from
wells adjacent to the Site, so risks associated with drinking
this water cannot be calculated. However, assuming that con-
taminated ground water was to migrate off Site and impact res-
idential wells at contaminant levels equal to what presently
exists, the incremental risk associated with drinking the water
would be 1.1 x 10~3. This risk level exceeds the recommended
risk range of 10~* to 10""7 for Superfund sites. Assuming un-
restricted use of the Site in the future, the risk associated
with drinking the ground water below the site would be 1.1 x 10~3
to as high as 6.6 x 10~2. The risks associated with dermal
contact, and subsequent ingestion of contaminated soils and
contact with contaminated surface waters were determined to be
within a range of 10~8 to 10~10 for both present and future site
use. The Site was listed on the NPL on October, 1981.
III. ENFORCEMENT HISTORY AND STATUS
From 1982 to 1986, EPA undertook extensive efforts to negotiate
with all identified potentially responsible parties (PRPs) to
achieve a settlement with respect to liability for past and
future costs of response actions at the site. On March 19, 1986,
a consent decree among EPA, the State of New Hampshire, the Town
of Epping and 127 settling PRPs was entered. On March 20, 1987,
a memorandum of agreement among EPA, the State of Mew Hampshire,
the Town of Epping, the United states Navy and the United States
Air Force was finalized.
In general, the terms of the Consent Decree and Memorandum of
Understanding provide that the settling parties shall pay the
United States government and the State of New Hampshire specified
shares for past and future costs of response actions at the Site.
All past and future costs, however, were not recovered from the
settling parties.
Approximately 30 PRPs were not parties to the consent decree with
EPA and the State. EPA presently intends to seek all past and
future costs that were not recovered from the settling parties
from these non-settling PRPs.
-------
IV. QomiUMlTT BKLATIONSs INVOEVBMBPIT AMP CONCERNS
Community relations activities conducted at the XE8 Site to date
have included:
• NHDE8 held a public meeting on September 19, 1985
to discuss the results of the Remedial Investiga-
tion Report.
• NHDES issued a press release on December 26, 1987
notifying the public of the availability of the
Draft Supplemental Remedial Investigation (RI) ,
Draft Feasibility Study (FS) and Proposed Plan.
• EPA mailed letters to PRPs on December 31, 1987
notifying them of the availability of the Supple-
mental RI, Draft FS and Proposed Plan.
• MHDES held a public informational meeting on
January 6, 1988 to discuss results of the Draft
Supplemental RI, Draft FS and the Proposed Plan.
• EPA held a public meeting on January 21, 1988
to receive oral comments on the Draft Supplemental
RI, Draft FS and Proposed Plan.
• EPA conducted a public comment period on the Draft
Supplemental RI, Draft FS Proposed Plan from
January 7, 1988 through February 17, 1988.
V. BVALUATIQM Q» ALTERNATIVES
A. Introduction
on October 17, 1986, the President signed into lav the
Superfund Amendments and Reauthorization Act of 1986
(SARA) amending the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) . Prior
to October 17, 1986', actions taken in response to re-
leases of hasardous substances were conducted in accor-
dance with the revised National Oil and Hasardous sub-
stances Pollution Contingency Plan (NCP) , 40 CFR Part
300, dated November 20, 1985. Generally, the purpose of
the NCP is to effectuate the response powers and respon-
sibilities created by CERCLA. In accordance with Section
105 of CERCLA as amended by SARA, the current NCP is
being revised to reflect the additional provisions of
SARA. In the interim, prior to the revision of the NCP,
the procedures and standards for responding to releases
of hazardous substances, pollutants and contaminants
shall be in accordance with section 121 of CERCLA as
amended and to the maximum extent practicable, the cur-
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10
rent NCP.
SARA retains the original CERCLA mandate for protective
and cost-effective remedial actions. According to Sec-
tion 300.68(a)(l) of the NCP, remedial actions are those
responses to releases that are consistent vith a per-
manent remedy to prevent or minimize the release of
hazardous substances or pollutants or contaminants so
that they do not migrate to cause substantial danger to
present or future public health or welfare or the en-
vironment. SARA adds a new statutory emphasis on risk
reduction through destruction or treatment of hazardous
waste rather than protection achieved through prevention
of exposure. Section 121 of SARA also establishes a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous wastes over remedies that do not achieve such
results through treatment. Furthermore, CERCLA requires
that EPA select a remedy that is protective of human
health and the environment, that is cost-effective and
that utilizes permanent solutions and alternative treat-
ment technologies, to the maximum extent practicable.
In accordance with CERCLA and the NCP, the primary remed-
ial response objectives for Superfund remedial actions
are:
• prevent or mitigate further releases of contaminants
to surrounding environmental media;
• eliminate or minimize the threat posed to public
health or welfare or the environment;
• reduce the volume, toxicity or mobility of hazardous
wastes through the use of treatment technologies; and
• utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable.
Section 300.68 of the NCP, in conjunction with the EPA
guidance document entitled "Guidance on Feasibility
Studies under CERCLA," also sets forth a remedial alter-
native development and remedy selection process consis-
ting the following seven steps:
1. Identify the nature and extent of contamination and
threat presented by the release [§300.68(f)].
2. Identify general response actions that may be needed
to remedy the release [§300.68(e)]
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11
3. Identify and screen remedial technologies potentially
applicable to wastes and site conditions
[S300.68(e)].
4. Develop alternatives to achieve site-specific ob-
jectives [§300.68(f)] .
5. Initial screening of alternatives [§300.68 (g) ].
6. Detailed analysis of alternatives [§300.68 (h) ].
7. Selection of remedy [§300. 68 (i)] .
Both CERCLA as amended and the NCP require first the
identification of the nature and extent of contamination
at the Site. Beyond the initial site characterization,
CERCLA retains the basic framework for the remedial
alternatives development and remedy selection process
enacted through the NCP, but each phase is modified to
reflect the provisions of CERCLA.
The nature and extent of contamination and the threat
presented by the release at the Site was documented in
the Remedial Investigation for the site and presented as
part of the discussion on Site History. A discussion of
how CERCLA affects each particular phase of the remedy
selection process follows.
B. Response Objectives
Consistent with the NCP, remedial response objectives for
the KE8 Site were developed for source control measures,
which address source areas of contamination and manage-
ment of migration measures, which address areas that have
been affected by the migration of contaminants away from
the source areas.
1* S^yrc, e Control Obi ectives
The remedial response objectives for source control
measures are:
• prevent or mitigate the further release of contami-
nants to surrounding environmental media;
• eliminate or minimise the threat posed to public
health, welfare and the environment from the source
area; and
• reduce the volume, toxicity or mobility of hazardous
substances, pollutants and contaminants.
-------
12
The first objective entails addressing the migration
pathways of contaminated soils at the RES Site. The
primary migration pathway identified at the KES Site is
the downward migration of contaminants from the soils
into the ground water of the overburden and bedrock
aquifers.
The second objective entails addressing the exposure
pathways, receptor populations and levels of exposure
associated with the soil source areas. Human health
risks are the primary concern of this objective. Risks
associated with dermal contact, inhalation and subsequent
ingestion of soil are evaluated with the primary receptor
population defined as young children living near or on
the site.
The third objective entails use of on-site treatment
technologies which will result in a permanent solution
with emphasis of innovative technologies where
practicable.
According to the National Contingency Flan (NCP) , all
applicable or relevant and appropriate federal public
health and environmental requirements must be identified
and "...EPA believes that those requirements must be met
in order to achieve an effective CERCLA remedy." (Federal
Register Vol. 50, Mo 224, November 20, 1985), 40 CFR
Part 300. When evaluating measures to isolate the source
areas, the requirements of RCRA (Resource Conservation
and Recovery Act) , and TSCA (Toxic Substances Control
Act) , SDWA (Safe Drinking Water Act) , and CAA (Clean Air
Act) among others will be used to ensure protection of
the public health, welfare and the environment. These
laws address not only eliminating direct contact with
source material but also potential releases, i.e., to
ground water or surface water from source material.
Currently there are no federal requirements which con-
tain standards or target levels which apply to soils.
Therefore, when considering treatment or removal of waste
and soil source areas, a combination of risk analysis and
an engineering-based cost effectiveness will be used to
develop target levels which will be protective of the
public health, welfare and the environment.
2* Mmiaq^aent of Migration Objectives
The remedial response objectives for management of migra-
tion measures are:
* preventing or mitigating migration of contaminants
beyond their current extent; and
-------
13
eliminating or minimizing the threat posed to the
public health, welfare and environment from the
current extent of contaminant migration.
The first objective entails addressing the migration
pathways of contaminated ground water. These pathways
include further transport within the bedrock aquifer via
ground water flow through bedrock fractures, surficial
discharge or contaminated ground water via the upward
component of ground water flow and migration of contami-
nants in surface water flow through ground water re-
charge.
The second objective entails addressing the exposure
pathways, receptor populations and levels of exposure
associated with contaminated ground water. Again, human
health risks are the primary concern. Receptor popula-
tions identified include the people residing in homes
along Exeter Road.
Target levels for remediating ground water are outlined
in applicable or relevant and appropriate Federal public
health and environmental requirements including: the
Safe Drinking Water Act maximum contaminant levels
(MCLs); the Office of Drinking Water Health Advisories;
the Clean Water Act Ambient Water Quality Criteria; and
RCRA Subpart F ground water corrective action regula-
tions .
c. Technology Development and Screening
The "Guidance on Feasibility studies Under CERCLA" dated
June 1985 and the National oil and Hazardous Substances
Pollution Contingency Plan (NCP) set forth the process by
which remedial actions are evaluated and selected. The
screening process consists of seven steps previously
mentioned in the Introduction to this Section. Data for
step one of the process (nature and extent of contamina-
tion) are provided by the Remedial Investigation Report
and Supplemental Remedial Investigation Report. The
threat presented by the contamination is evaluated in
Section 8.0 of the Supplemental Remedial Investigation
Report, Baseline Risk Assessment. Steps two through
seven of the process are carried out in the Feasibility
Study independently for source control and management of
migration responses. The alternative selected for the
IBS Site consists of both a source control alternative
and management of migration alternative.
Pursuant to §300.68(e) of the HCP, EPA determined general
response actions, identified as response categories
within the Feasibility Study, which are based on the
-------
14
results of the field investigation and the findings of
the Remedial and supplemental Remedial Investigation
Reports. EPA then screened specific technologies con-
sidering the waste-limiting (waste characteristics that
limit the effectiveness of a technology) and site-limit-
ing (site characteristics such as high ground water table
or soil permeability,that preclude the use of a technol-
ogy) factors unique to the site, and the level of techni-
cal development for each technology.
Tables v-l and V-2 summarize the general response cate-
gories and the applicable technologies screened for
source control and management of migration, respectively.
Table V-3 presents the technologies which emerged from
the screening process.
D. Development & Screening of Remedial Action Alternatives
Section 300.68(f)(l) of the NCP requires that, to the
extent that is both possible and appropriate, at least
one remedial alternative shall be developed as part of
the Feasibility Study in each of the following cate-
gories:
• Alternatives for treatment or disposal at an off-site
facility as appropriate;
* Alternatives that attain applicable or relevant and
appropriate Federal public health and environmental
requirements;
' As appropriate, alternatives that exceed applicable or
relevant and appropriate Federal public health and
environmental requirements;
• As appropriate, alternatives that do not attain ap-
plicable or relevant and appropriate Federal public
health and environmental requirements but will reduce
• the0likelihood of present or future threats from
hazardous substances and that provide significant
protection to public health and welfare and the
environment. This must include an alternative that
closely approaches the level of protection provided by
alternatives that attain applicable or relevant and
appropriate requirements.
• No action alternative.
This development of alternatives must also comply with
SARA. Section 121(d) of CERCLA basically codifies EPA's
CERCLA Compliance Policy. First published as an appendix
to the preamble of the NCP, this policy requires that
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15
TABLE V-l
REMEDIAL TECHNOLOGIES FOR SOURCE CONTROL
(1) MO ACTION
Site Security
(6)
< 2) CQNTAINMgNT
Capping
Multi-Layer Systems
Surficial Stabilization
(3)
IN-SITU
(4)
Aeration
Solvent Extraction
Soi1 T1ushi09
Aerobic Biogradation
Anaerobic Digestion
Enzynatic Degradation
Ox idation
Reductive Dechlorination
Neutralization
Hydrolysi s
Enhanced Photolysis
In-Situ Heating
Artificial Ground Freezing
Vacuum Extraction
Vitrification
Thernoset F i xatives/Poly*er ization
Ceaent and Silicate based
Fi xatives/Grouting
• e
REMOVAL
Excavation
(*) ON-«ITr MTORABg
Haste Pile
Storage Vault
Storage Bins
Storage Bags
Tank/Oru* Storagi
(7)
ON-8ITE TRgATMgNT
Cenent ft Silicate based
Fixatives/Grouting
Ther«oplastic Fixation
Theraosets
Surface Nacroencapsulation
Absorbents
Vi tr i fication
Drying Beds
Filtration
Pressure Filtration
Classification
Screens and Sieves
Classifiers
Carbon Adsorption
Powdered Activated Carbon
Addi tion
Evaporati on
Solvent Extraction
Mechanical Aeration
Anaerobic Digestion
Co«posting
Landfa r•ing
Cnjyaatic Degradation
Ox i dat i on
Reduct i on
Neutralization
Hydrolysis (base-catalyzed)
Rotary Kiln
Ceaent, Li Me ft Aggregate
Kiln Concentration
Multiple Hearth Incineration
High Temperature Fluid Wall
Infrared Incineration
OM-«ITg
RCRA Landfill
aiTg TREATMENT
RCRA Hazardous Waste TSD
(Treatment/Storage Disposal)
Faci1i ty
*
(9) OFF-SITE DISPOSAL
RCRA Landfill
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16
TABLE V-2
REMEDIAL TECHNOLOGIES FOR MANAGEMENT OF MIGRATION
<1) NO ACTION
Moni tor ing
(2) CONTAINMENT
Slurry Walls
Grout Walls
Sheet Piling
Block Displacement
Bottom Seal Grouting
< 3) DIVERSION
Slurry Walls
Grout Walls
Sheet Piling
Ground Water
T rench
Inte r ce pto r
(4) CQLLgCTION
Ground Water Interceptor
T r ench
Collector wells
(5) IN-SITU TREATMENT
Precipitation/Coagulation/
F 1 occu1 at i on
Carbon Adsorption
Permeable Bed Treatment
Aerobic Biodegradation
Anaerobic Digestion
On idation
Reduction
Neutralization
Hydrolysis
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17
TABLE V-2 (CONTINUED)
REMEDIAL TECHNOLOGIES FOR MANAGEMENT OF MIGRATION
(9 )
Municipal Wastevater Treatment Facility
RCP.A Hazardous Mast* Treatment
Storage Disposal
Resource R*cov*ry
•iodegradation
Chcaical Tr»at*«nt
( 1O)
(11)
NPOES Oischar«*
••M*r Lin*
Surface Water
D**p W*ll Injection
QM-SITE piapoaoL
. •
NPOES Oischarg*
Sewer Line
Surface Water
Spray Application
Seepage Basins and Ditches
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IS
TABLE V-3
TECHNOLOGIES APPLICABLE FOR REMEDIAL ALTERNATIVES
SOURCE CONTROL
MANAGEMENT OF MIGRATION
(!) MO ACTION
Site Security
(2) CpLLECTTQN
Capping
( 3 ) IN-SITU TREATMENT
Soil Flu *hi ng
VACUUM Extraction
(4) REMOVAL
Excavation .
(5) QM—SITE STORAGE
(1> MO ACTION
Honi tor ing
< 2 > COLLECTION
Wast* Pile
Storag* Bins
(6) QN-SITE TREATMENT
Mechanical Aeration
Low Temperature Thermal
Str i PP i ng
Soil Washing
Biological Decomposition
Inc i ner at i on
(7) ON-SITE DISPOSAL
RCRA Landfill
(8) OFF-SITE TREATMENT
RCRA TSD Facility
(9) OFF-SITE DISPOSAL
RCRA Landfill
Ground Water Interceptor
Trench (French Drain)
( 3 ) IN-SITU TREATMENT
Aerobic Biodegradation
{4) .REMOVAL
Ground Water Interceptor
Trench (Overburden)
Extraction Wei 1
(Bedrock Only)
(5) QM-8ITE TREATMENT
Vapor and Liquid Phase
Carbon Adsorption
Air Str i pp i ng
Steaa Stripping
Activated Sludge
Recircu1 ation Systems
(7) OFF-SITE DISPOSAL
NPDES Discharge (Surface
Water )
Ground Water Discharge
(6) OFF-SITE TREATMENT
Municipal WasteMater
Treatment Facility
RCRA Hazardous Waste Treat-
•ent/Storage/Disposal
Facility
( 9 ) OFF-SITE DISPOSAL
NPDES Discharge
(Surface Water)
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19
Superfund remedial actions attain applicable or relevant
and appropriate requirements (ARARs) of other Federal
statutes. While Section 300.68(f) of the NCP specifical-
ly refers to ARARs in regard to the Development of Alter-
natives, CERCLA incorporates this requirement into statu-
tory law, while adding the provision that remedial ac-
tions also attain state requirements more stringent than
federal requirements if they are also applicable or
relevant and appropriate and identified to EPA in a
timely manner. The new statutory requirements and pref-
erence for treatment that reduces the volume, toxicity or
mobility of hazardous waste, further modifies the process
by which remedial alternatives are developed.
Alternatives developed and considered for initial screen-
ing at the KES site are listed in Table V-4. The purpose
of the initial screening is to narrow the list of potent-
ial remedial actions for further detailed analysis.
Criteria listed in §300.68(g)(l)-Costs; (g)(2)-Acceptable
Engineering Practice; and (g)(3)-Effectiveness of the NCP
were used in the initial screening process. Consistent
with Section 121(b)(2) of CERCLA, innovative technologies
were carried through the screening process if they of-
fered the potential for better treatment performance or
implementability or less adverse environmental impacts
than other available technologies or lower costs than
demonstrated technologies. Results of the initial scre-
ening of alternatives process are presented in Table V-5
and V-6.
E. Detailed Analysis of Alternatives
After the initial screening, a detailed evaluation of
each of the five source control alternatives and three
management of migration alternatives remaining was con-
ducted. Section 300.68(h) of the NCP states that a more
detailed evaluation will be conducted of the limited
number of alternatives that remain after the initial
screening. The detailed analysis of each alternative
shall, as appropriate, include:
1. Refinement and specification of alternatives in
detail, with emphasis on use of established technology.
Innovative or advanced technology shall, as appropriate,
be evaluated as an alternative to conventional tech-
nology.
2. Detailed cost estimation including operation and
maintenance costs and distribution of costs over time.
3. Evaluation in terms of engineering implementation,
reliability, and constructability.
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20
TABLE V-4
TECHNOLOGIES FOR INITIAL SCREENING
SOURCE CONTROL
SC-1 No Action (with fencing)
SC-2 Capping
2A Permeable Cap
2B RCRA Multi-Layered
Cap
2C Surfic ial
Stabilization
SC-3 In-Situ Treatment
3A VACUUM Extraction
3B Soil Flushing
SC-4 On-Site Treatment
4A On-Site Aeration
4B On-Site Soil Washing
4C On-Sit* Incineration
SC-S On-Site RCRA Landfill
SC-6 Off-Site Incineration
SC-7 Off-Site RCRA Landfill
MANAGEMENT OF MIGRATION
MOM-GW1 No Action (Mith Monitoring)
HOH-GW1 In-Situ Biological Treatment
MOM-GW-3A Air Stripping/Filtration/
Carbon Adsorption (discharge
to stream)
HON-GW3B Air Stripping/Filtration/
Carbon Adsorption (discharge
to ground water)
MOM-GW3C Air Stripping/Biodegradation/
Filtration/Carbon Adsorption
(discharge to groundwater)
NOM-GW4A Off-Site Treatment at a RCRA
Treatment storage and
Disposal Facility
MOH-GW4B On-Site Air Stripping Pre-
treatment Mith Off-Site
Treatment at a Publicly
Owned Treatment Works
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21
TABLE V-5
SCREENING OF SOURCE CONTROL ALTERNATIVES
REMEDIAL ALTERNATIVE
COSTS
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
No Action
(with -fencing)
•12O.OOO
capital
•1O.OOO
Annual 1y
O*M -Tor
SO year %
\. Eliminate ace*** to con-
taminated soil source areas
2. Extends period of poor
ground Mater by allowing
continued release of con-
taminants from soil source
to ground Mater.
This alternative has been
retained for detailed
evaluation as a basis for
comparison to other
alternatives as specified
in 1300.68(f><1)(v) of
the NCP.
Permeable Capping
A. Permeable Cap
Surficial
stabilization
•3OS.OOO
Capital
•24,OOO
Annua11y
OtM
•243.OOO
Capital.
•26.OOO
Annual 1y
OfcN
1. Eliminate access to con-
taminated soil source areas.
2. Extend* period of poor
ground Mater by allowing
continued release of con-
taminants from soil source
to ground Mater.
C. RCRA Multi-Layered
Cap
•2.000.000
Cap i tal
3. Re s tr i c t s
of site.
futur e use
Alternative SC-2C has
been retained for de-
tailed evaluation while
SC-2A and SC-2B have been
screened out. A multi-
layered RCRA cap Mill
prevent further migration
of contaminants into
ground Mater. Mill prevent
leachate seeps and pro-
vide a physical barrier.
It Mill provide greater
environmental and public
health protection than
SC-1. despite an order
of magnitude greater
costs. 3C-2A and SC-2B
have been screened out
in accordance with
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22
TABLE V-5 (CONTINUED)
SCREENING OF SOURCE CONTROL ALTERNATIVES
REMEDIAL ALTERNATIVE
COSTS
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
ac-2 (continued)
•4O.OOO
Annua11y
OftM
4. SC-2B and 3C-2C will
vent infiltration into
contaminated soils and
therefore limit Migration
of conta•inant».
pre- S30O.68(«)(3) in that
they do not effectively
contribute to the pro-
tection of public health
and welfare and the
environment in comparison
9C-2C.
SC-3C
In-Situ Treatment
A. Vacuum Extraction
*4OO .OOO
to
•65O.OOO
Capital
• 1 .000.000
to
•1.5OO.OOO
Annua11y
OtM for 2
year *
1. Eliminate access to
contaminated source areas
2. Reduction or elimina-
tion of contaminants in
soil source areas.
Alternative 3C-3A has been
retained for detailed de-
velopment because it pro-
vides greater environ-
mental and public health
benefits than 3C-1. Site
conditions are also
amenable to effective
implementation of this
treatment method.
3. Unimpeded future
of site.
u se
4. Removal of hazardous
nature of soil source
area without problems
associated with ex-
cava t i on.
5. Eliminates hazard from
spills associated with
transport of contaminated
soils.
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23
TABLE V-5 (CONTINUED)
SCREENING OF SOURCE CONTROL ALTERNATIVES
REMEDIAL ALTERNATIVE
COSTS
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
Soil Flushing
.4OO.OOO
Capital
•19O.OOO
Annual 1y
O*M 5
year s
6. Mitigates potential for
off-site Migration of
contaminants after treat-
Ment is coMpleted.
7. Potential release of air
•Missions froM treatMent
(SC-3A only ) .
8. Potential increase of
contaminants entering
ground Mater during short-
tern iMpact or treatMent.
Alternative SC-3B has been
retained for detailed
evaluation under alter-
natives MOM-3B and 3D.
They involve collection
and treatMent of ground
water followed by
recharge back to the
ground as a disposal
Method for the treated
Mater .
9. Generation of residuals
after treatMent that re-
quires handling of disposal
On-9ite TreatMent
(Mith excavation)
On-Site Aeration
•3.400.00
Capital
•2.SOO.OOO
OftN
(2-3 year s)
1 . E1i M i na te
contaminated
areas.
access to con-
soi1 source
2. UniMpeded future use of
site.
3. Mitigates potential for
off-site Migration of con-
taM inant s.
Alternative SC-4A and
SC-4B Mere retained for
detailed developMent
since they have the saMe
environMenta1 benefits
for treating organic-
contaMinated soils and
equipMent costs.
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24
TABLE V-5 (CONTINUED)
SCREENING OF SOURCE CONTROL ALTERNATIVES
REMEDIAL ALTERNATIVE
COSTS
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
On-Site Soil Washing
On-Site Incineration
ac-s
On-Site RCRA Landfill
•6.&OO.OOO
Capital
•1.500,000
O&H
2-2 1/2
year *
•13.3OO.OOO
Capital
•6.OOO
Annua1
O&M
2-2 l/2cyr«.
• 1 .4OO.OOO
Capital
•42.000
Annua1
OfcH
4. Potential
• •i * » i ons due
5. Potential
*•i s s i on* due
re 1ea se of air
to excavation.
release of air
to excavation.
6. Generation of residuals
after treatment.
Alternative SC-4C Mas
screened out in accor-
dance with 1300.68(0)
(1) and (3). The costs
are an order of Magnitude
greater than those for
SC-4A and 4B. without
providing significantly
greater environmental
benefi ts.
7. Adverse environmental impact
of treatment on the neighborhood.
1. Eliminate access to con-
taminated soil source areas
2. Mitigates potential for
off-site migration of
contaminants.
3. Restricts future use of
site .
4. Potential release of
emi s s i ons.
lir
This alternative has been
screened out in accordance
with I30O.68(9)(3). This
alternative is of less
environmental benefit than
the on-site treatment
alternative. SC-4 and it
is of less benefit to
public health, due to
excavation activities.
when compared to the
capping alternative SC-2.
5. Potential releases
associated with excavation.
-------
25
TABLE V-5 (CONTINUED)
SCREENING OF SOURCE CONTROL ALTERNATIVES
REMEDIAL INVESTIGATION
COSTS
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
Off-Site Incineration
•34.OOO.OOO
1. Eliminate access to con-
soil source area*.
2. Mitigates potential -for
off-site Migration of con-
taminants.
3. Unimpeded future use of
site.
4. Potential for releases
associated with excavation.
This alternative has been
screened out on the basis
or 1300.68(0) ( 1 ) and (3).
The environmental benefit
for off-site incineration
was not significantly
greater than off-site land
disposal alternative SC-7
although the cost of
incineration is greater.
5. Potential for releases
and safety problems due to
extensive handling and
transportation.
ac-T
Off-9ite RCRA Landfill
•15.OOO.OOO
1. Eliminate to contaminated
soil source areas.
Unimpeded
This alternative has been
retained because it has a
better environmental im-
future use of site. pact than corresponding
on-site alternatives due
3. Mitigates potential for off- to the existence of a
site migration of contaminants. properly sited and
operating facility.
4. Potential for releases
associated with excavation
5. Potential for releases and
safety problems due to extensive
handling and transportation.
-------
26
TABLE V-6
SCREENING OF MANAGEMENT OF MIGRATION ALTERNATIVES
RESIDENTIAL ALTERNATIVE COST ENGINEERING PRACTICES/EFFECTIVENESS COMMENTS
NOM-GWl 435.000 Capital 1. Ground Mater Mill cleanup This alternative may be
No Action •3O.OOO/yr O&H with tine a* a result of viable for this site and
natural processes. has been retained -for
detailed development
2. Includes Monitoring to to provide a basis for
detect off-site contami- comparison to other
nation that could threaten other alternatives a s
other nearby residential stipulated in i3OO.68(f)
areas. (l)(v) of the NCP .
3. Requires institutional con-
trols restricting the use of
the aqu i f er .
4. No release from future
liability if contamination
migrates off-site.
MOM-GW2 i
e
In-Bitu Biological 936. OOO Capital 1. As above This alternative has been
Treatment *14.4OO/yr o&M screened out on the basis
2. Hay accelerate the cleanup of i 3OO . 68 { g ) ( 2 ) . Al-
of ground Mater. though this alternative
i 9 no t a proven tech-
3. As above nology. it has shoMn pro-
4. Does not actively control mise as a passive
ground Mater contamination treatment system. However
continued discharge and the time required to
migration of contaminants attain targeted levels
may approach that of the
5. Uncertainty involved in no-action alternative.
areal extent of treatment (Considering that
effectiveness. naturally occurring pro-
cesses have already
6. Will not breakdown all reduced contaminant
compounds present. levels).
-------
27
TABLE V-6 (CONTINUED)
SCREENING OF MANAGEMENT OF MIGRATION ALTERNATIVES
RESIDENTIAL ALTERNATIVE
COST
ENGINEERING PRACTICES/EFFECTIVENESS
COMMENTS
MOM-GW3
On-Sit* Treatment
A . Air Str i pping
Fi1trat ion/Carbon
Adtorpt i on
(Discharge to
stream)
•218.OOO
Capital
•22.OOO/yr
OftM
As above
2 .
As above
3. Re1ease
1iabi1i ty
from f utur•
Air Strippi 09
Fi1tration/Carbon
Adsorption (Dis-
charge to ground
water)
•7OO.OOO
Capital
•250.OOO
Yr-OkM
4. Does not restrict Tutur*
or require institutional
contro1s.
5. Construction of
•facility May create
negative visual inpacts.
Alternative MON-GN3 has
been screened out on the
basis of *3OO.68(g)(2).
Discharge of treated
ground water to local
waterways generally
requires extensive re-
gulatory review and
permitting. Alternative
MOM-GW3C has been screened
out in accordance with
•3OO.60(9)(3). MOM-GW3C
provides no store environ-
mental or public health
benefits than MOM-GM3B
and there are greater
uncertainties associated
with the effectiveness of
biodegradation.
Air Stripping
Biodegradation/
Fi1tration/Carbon
Adsor pt i on
•8OO.OOO
Capital
«2OO.OOO/Vr
OKM
-------
28
TABLE V-6 (CONTINUED)
SCREENING OF MANAGEMENT OF MIGRATION ALTERNATIVES
RESIDENTIAL ALTERNATIVE
COST
ENGINEERING PRACTRICES/EFFECTIVENESS
COMMENTS
HOM-QW4
Off-Site Treatment
A .
TSD Facility
POTW with On-
Si te Air
Str i pp i ng
•217.000
Capital
91 .000.000
Year/O&M
•145.OOO
Capi tal
•3OO.OOO
O&M
1 . As above
2. Will not breakdown all
compound* present.
3 . R*lease
liability.
f r om -future
4. Does not restrict future
use or require institutional
contr o1s.
HOM-GM4B has been screened
out in accordance with
•3OO.66(9)(2). Ground
Mater is considered a
hazardous Material and
can only be trucked to a
RCRA permitted TSO
Fac i1ity.
5. Potential for spills during
transport via trucking or in
sewer line.
NOTES: (3OO.OOO O&M) OftM Costs are user fees or tipping fees for disposal of contaminated ground
water which will be incurred over the life of removal scheve.
(Costs) O*M costs given are annual costs (no present analysis was performed)
-------
29
4. An assessment of the extent to which the alternative
is expected to effectively prevent, mitigate or minimize
threats to and provide adequate long-term protection of
public health/ welfare and the environment. This
includes an evaluation of the extent to which the alter-
native attains or exceeds applicable or relevant and
appropriate Federal public health and environmental
requirements (ARARs). Where the analysis determined that
public health and environmental requirements are not
applicable or relevant and appropriate, the analysis, as
appropriate, evaluates the risks of the various exposure
levels projected or remaining after implementation of the
alternative under consideration.
5. An analysis of whether recycle/reuse, waste minimiza-
tion, waste biodegradation, destruction, or other ad-
vanced, innovative or alternative technologies is
appropriate to reliably minimise present or future
threats to public health or welfare or the environment.
6. An analysis of any adverse environmental impacts,
methods for mitigating these impacts and costs of mitiga-
tion. In addition, Section 121(b) of CERCLA requires
that remedial actions in which treatment which permanent-
ly and significantly reduces the volume, toxicity or
mobility of the hazardous substances, pollutants, and con-
taminants is a principal element, are to be preferred over
remedial actions not involving such treatment. The offsite
transportation and disposal of hazardous substances or con-
taminated materials without such treatment should be the
least favored alternative remedial action where practicable
treatment technologies are available. The President shall
conduct an assessment of permanent solutions and alternative
treatment technologies or resource recovery technologies
that, in whole or in part, will result in a permanent and
significant decrease in the toxicity, mobility, or volume of
the hazardous substance, pollutant or contaminant. In making
such assessment, the President shall specifically address
the long-term effectiveness of various alternatives. In
assessing alternative remedial actions, the President shall,
at a minimum, take into account:
A. The long-term uncertainties associated with land dis-
posal .
B. The goals, objectives and requirements of the Solid Waste
Disposal Act.
C. The persistence, toxicity, mobility and propensity to
bioaccumulate of such hazardous substances and their
constituents.
-------
30
D. Short and long-term potential for adverse health effects
from human exposure.
E. Long-term maintenance costs.
F. The potential for future remedial action costs if the
alternative remedial action in question were to fail.
6. The potential threat to human health and the environment
associated with excavation, transportation and redisposal
or containment.
The Office of Solid Waste and Emergency Response (OSWER),
through Directive 9355.01-21, consolidates the evaluation
criteria from both §300.68(h) of the NCP and §121(b) of
CERCLA into nine key criteria. The nine criteria are:
1. Reduction of Toxicity, Mobility or Volume
2. Implementability and Reliability
3. Short-term Effectiveness
4. Compliance with ARARs
5. Long-term Effectiveness
6. Cost
7. Community Acceptance
8. State Acceptance
9. Overall Protectiveness of Human Health and the Environ-
ment
These nine criteria were used in evaluating each of the
alternatives which passed the initial screening. The
evaluation in respect to criteria 1-6 is presented in Table
V-7 through V-14. Criteria 9, Overall Protectiveness of
Human Health and the Environment, is discussed following the
discription of each alternative. With respect to Criteria 7,
Community Acceptance, EPA has received no comments from local
residents during the formal comment period. The comments EPA
has received from others are included in the Administrative
Record. These comments are summarized and responded to in
the Responsiveness Summary attached hereto. In regard to
Criteria 8, State Acceptance, the New Hampshire Department of
Environmental Services (DES) has reviewed the various alter-
natives and has indicated its support for the selected
remedy.
-------
31
1. BC-1 — HO ACTION
Under the No-Action Alternative for source control, contam-
inated soils identified during the field screening and
laboratory analysis programs, will remain in place. Public
access to the Site will be limited by use of the existing
fence surrounding the Site. The existing buildings on-site
will remain under this alternative as well as with all source
control alternatives under consideration. Measures such as
learning and seeding the Site will be instituted along the
south and west borders of the Site. Fence maintenance and
sampling programs will be implemented and continued for 30
years or until contaminant levels in soils decreased through
natural processes to a point where they no longer presented a
threat to public health .or the environment.
The sampling program will consist of obtaining ten soil
samples every three months for the 30-year period.
Levels of contamination detected in soils on-site do not
present a significant health risk in terms of dermal contact,
inhalation or subsequent ingestion. However, the downward
migration of contaminants from soils to the ground water may
prolong the poor quality of the ground water and increase the
potential for off-site migration to residences along Exeter
Road. Assuming factors for ground water recharge rate, soil
moisture content, annual percent decrease in contaminant
concentration, area of contaminated soils, and no chemical
and/or biological degradation, mathematical analysis
estimates that as long as 200 years may be needed for the
ground water beneath the Site to'reach drinking water
quality.
A summary analysis of the No-Action Alternative in accordance
with the first six OSffER criteria is presented in Table V-7.
The overall ranking for the no-action alternative is low for
protection of human health and the environment based on its
lack of compliance with ARARs, its failure to reduce toxic-
ity, mobility or volume and its lack of long-term effective-
ness to protect public health and the environment.
2. 8C-2 — CAPPING
This alternative consists of constructing a multi-layered
impermeable cap over the entire 7.4 acre XES Site (323,000
ft.). The multi-layered cap design consists of a three-
layered system which has an upper vegetative layer, underlain
by a drainage layer over a low permeability layer. The
vegetative layer is supported by the topsoil layer, the
drainage layer is composed of sand or gravel and the low
permeability layer consists of a combined synthetic and soil
liner system. This design is consistent with the require-
ments of the Resource Conservation and Recovery Act as
-------
TABLE V-7
SC-1 - NO ACTION EVALUATION
Remedial
Alternative
SC-1
lo Icttoa
Peaciai/
Keiltoriai
Omall lukiaf
Lev
Capital Ceil
lltl.IOO
Preieit Valve of
0 1 R Coitt
IJJUOO
Total Preicat
Vortk Coiti
IW.OOO
Reduction of
Toxicity,
Mobility or
Volume Reliability
Lou fcdiu
Coatuiaaati eu kc Tie feiet uf be
iioUted frei tke duajed or vudiliud
popilatioa eliilaatiai 10 lealer effectmlf
tie tkreat of direct reitrietiif lite
eeattet. iccen.
Ceattiiatati «ill eoa-
tiaae to leiek (rei
tke toili to tke
frouadvater.
Kill lot liiaifieutlf
or peruaeatlf redact
volue, toiieity or
lobillty of
coataiiaitioa.
Inplementability Short-Term
(jonstructability Effectiveness
lifi
liiile eoittrtetioi
teckilqui iee4e4 to
«e|eUtt ud feace tke
lite.
Boiiteriaj projrsa eu
be iiileteitd viU
little diffic«lt».
fedlu
iltkoifk •enoaatl dill
tot k« reqiirei to di-
rectlf kudle kaurioii
Mitei, tkej dill ke
vorkiaf iltk coiU.il-
aited loili dirlai tke
«e|etatioa operatloa.
Compliance
with Long-Term
ARARs Effectiveness
U*
Doei lot coil It «itk
ICIi-U CM *irt U4
Ittbiirti 1 (Oroiid-
wter Protectioili
6 (Clome iid Poit-
Cloiire), liecitive
Order lltlt; ud Piik
ud Illdllfi Coordiu-
tioi let.
Boei lot coiplf vitk
tke liteit of im to
•eriueitlf or ilfiifi-
cutlf redice tke rol-
ue, toiiclt; or 10-
billtf of eoitiiiiuti.
Lo«
Coatuliiiti ire tot
reioved or readered
•op-kiurdo«i.
Coituiiut coatiet
vitk i leuoiilly klfk
titter table ii poiiible.
Pitire lite ud irei
developieat reitricted.
Coatuiiuti ire left
oa lite, reqilrUi 5-
jeir IAU re*le«.
-------
33
TABLE V-8
SC-2 - CAPPING EVALUATION
Remedial
Alternative
Reduction of
Toxicity,
Mobility or
Volume
Reliability
Iitplementability
Constructability
Short-Terro
Effectiveness
Conpliance
with
ARARs
Lonq-Term
Effectiveness
ic-:
eitire titt
Hitk atlti-
luer.lCII eta
Otertll laikial
lov
Cipitil Coiti
12,102,100
Frtiett Vilae of
Oil Colt
II02.SOO
Total Preitit
Vortk Coiti
II,Oil,100
Lou
Iliaiiitei direct or
Mill klom oi|oiare.
Coituiute4 aoili ire
iot reaotei.
Vill aot liiaifieaatlf
redvee tkt toUao or
toiicitf of eutaaiaa-
tioi.
Vill ro4aee tke M-
kility of coituiiuti,
kit riiia| vater takle
eo«14 itill coitiet
eoituiaitt4 toili.
Pereolitloi of riiafall
ii eliaiiite4, kit
leiekiii tkrotfk eea-
taet nitk froiii'vtttr
ii iot.
Liter ieiift kat a
fiaitt lift of
iptrotiaatolj 20-JO
ftari.
dotii| ttekitltliei
ktrt keei laeettifillf
atol it otker laperfati
oitei.
Iwkjtet tt fallart 4it
tt iiffortatial icttle-
Mat of uili.
lilk
lelatlie eaat of it-
itallatiet.
•oiitorlii proirai eaa
ke ii|leacate4 *itk
littlt iiffietltf.
Miu
U*
U«
Pottatial eitotvre of Coopliei vitk Kli II Caatuiaaiti ire tot
mrkeri aa4 reoiioiti
to ftlititi itit aai
tapor Hiiiitn iirln
ityliHttttiii.
aiiiteiiiet of to|t-
tative eottr.
rtaetH or rei4erei
toi-kaurioii.
Cfl Part til lakparta
G (Cloaart aa4 Poit-
Clooirt); tiecatlve
Ot4«r lltN u4 tkt Coataiiaut eutaet
Plak i liUllft C«or4l- vitk a ieu.ulIj ki|k
aatloa act. water takle it pouikle
Doei aot ceipli nitk
ICU II CPt Put til,
P.
loot tot eoaflf »ltk
tkc iateat of IMA to
peraueitli or ii|il-
eaatly re4ace tkc tol-
OM or toiieitf of eoi-
taiiaaatt. Ie4aeei ao-
kilitf, k«t riiiai
nater takle air ke i
irokleo.
Coataaiaaata art left
oa lite, rttjtlriai I-
rear III! retloi.
Cap kai aa eipeete4
life of tO-10 feari.
Patare lite 4erelopt«it
reaaiai Iiaite4.
-------
34
amended in 1984. In addition to construction costs, opera-
tion and maintenance of the cap for a thirty-year period will
include maintenance of the vegetative top layer/ well
sampling and erosion control.
The purpose of a cap is to control the migration of wastes as
well as prevent the assimilation of the contaminated source
areas with non-contaminated media. A cap can mitigate these
conditions by acting as an infiltration barrier. However,
seasonal fluctuation in the ground water table can result in
the continued leaching of contaminants into the ground water.
Table V-8 presents an evaluation of the capping alternative
in respect to the first six OSWER criteria. The overall
ranking for this alternative is low for protection of human
health and the environment. While capping limits mobility of
contaminants, there is no permanent or significant reduction
in the volume or toxicity of contaminants. The leaching of
contaminants through contact with seasonal rising water table
remains a concern.
3. 8C-3A — IN-SITU TP*VTMENT (Vacui"P Extraction)
This alternative involves the in-place treatment of soil con-
tamination using a technology called vacuum extraction.
Vapor extraction wells are installed into the soils above the
ground water table. Vacuum piping is attached to each well
and also to a vacuum pump. The pump creates a vacuum at each
well and causes air to flow from the surrounding soils to the
wells. As the air passes over the contaminated soils, a mass
transfer between the contamination and the air occurs. The
contaminated air is then collected from each well through the
vacuum piping to a condenser where moisture is removed.
Finally, the contaminated air is sent through columns of
activated carbon where the contaminants are removed prior to
the air being discharged to the atmosphere, operation and
maintenance costs for this alternative include power,
personnel and monitoring.
The maximum area requiring vacuum extraction is estimated at
150,000 square feet and is shown on Figure V-l.
Approximately five years of treatment will be necessary to
lower the concentration of contamination in this area of
soils to an acceptable level. Target concentration levels
are discussed in Section VI.A.2. and VI.B.I. of this Summary.
During the initial design phase of this alternative, a soil
sampling program will be implemented to verify soil areas
which require treatment. Soils which exceed the cleanup
goals established in Section VI.B.I. of this Summary will be
treated.
Although classified as an innovative process, vacuum extrac-
-------
35
/ / '"•'*'
•- - ', ! I
KCEFE ENVIRONMENTAL SERVICES
EPPING; NEW HAMPSHIRE
CAMP DRESSER t MCKEE
AUGUST 1987
FIGURE v-i
ESTIMATED AREAS OP
CONTAMINATED SOILS
-------
TABLE V-9.
SC-3A - VACUUM EXTRACTION EVALUATION
Reduction of
Remedial
Alternative
SC-1
ID litu
Treitmt
A. Vicvui
litrictioa
Omill laftkiaf
Nifk
Cipitil Coil
11,111,100
Preient Value of
0 i H Cott
tl,ll),900
Toxicity
Mobility or I"
Volume Reliability Cc
Rifk Htdiui
Treitieit of teili re- Treititot Teckiolog;
aovei tkreat. In btei mcceiifull;
vied it cleaa-up of
Iliaiaatei leickini ektiictl ipilli.
froi coituiiated loili Tkii teclnoloij it cur
to tkt froiidnater. reotlj beiaj developed
for ki»r'do«« naite
Treitieat of loili litti. Pilot itvditi
reiultt in i ptrmeit irt rtqvirtd.
ud liiRifictit re-
duction in tke TO!»M
toiicity tad lobilit;
Of CORtullMtl.
Conpliance
Inplementability Short-Term with
Constructability Effectiveness ARARs
Long-Term
Effectiveness
lediu
lelative cue of iiple- Hiiiial worker aad
aentatioa vkea coiaared reiideat eiptaire to
to remedial tecbaolo- ponikle vapor eaii-
giei refiiriaf aoili aioai dariaf tke
ud treataeat proceaa.
Pouible »»§cr eiit-
lion fret eitrtettoi
I treittcit operttiou.
Coipliti «itk ICU 41
cn r»tt ti< iibiwti
P, C, J; liecutire
Order I1IIB, ud tke
Fitk i lildlife C«erdi-
•itiin Act.
Cotillei «itk tke ii-
teit of im ii tktt •
ptrwaeit redietioi ii
TtlMt, toiieitf tad
•obiliti of eoatMt-
atati ii provided.
lilt
Icaovil of ctatuiaiati
froi tke loili Hill
•itiiate dewi«trd ai-
irttioa of coatui-
iMti to tke |roaad-
•ater, ud accelerate
iroiadvater cleti-iip.
leioul of coataiiaaati
froa tke loili redvcei
tke riik of derail coa-
tact aad iofeition of
coatuiaaBta.
Total PreieRt
Vortk Coit
M,lit,200
-------
37
tion has been used successfully in pilot studies in
California and Minnesota. This process is also being demon-
strated and evaluated for use at a Superfund Hazardous Waste
Site in Massachusetts.
Table v-9 presents an evaluation of this alternative with
respect to the first six OSWER criteria. This alternative
received an overall ranking of high for protection of human
health and the environment, because it eliminates leaching of
contaminants from soils to the ground water by permanently
and significantly reducing the volume and toxioity of con-
taminants. This alternative complies with all applicable or
relevant and appropriate Federal and state requirements.
4. SC-4A — EICAVATIOM OF CO1ITM*TMATBD SOILS WITH OM-SITB
Low temperature thermal stripping requires the excavation of
contaminated soils and consolidation into a central area for
processing. The process itself consists of a mechanical
aeration system, such as a rotary drum or screw auger device.
The soils are heated and induced air flow applied. Contam-
inants are released from the heated soils by the churning
action.
The induced air flow captures the contaminants and passes
them to an after burner for destruction. Treated soils will
be sampled and analyzed to ensure that the proper degree of
treatment is achieved. The soils will then be used on-site
for grading. Operation and maintenance of this system in-
cludes power, fuel, personnel, equipment, rental equipment,
sampling and analysis.
Results from several pilot studies on heavily contaminated
soils has demonstrated that greater than 99 percent removal
of volatile organic compounds can be achieved. A maximum of
approximately 20,800 cubic yards of contaminated soils will
be treated. Assuming the process will treat 10,000 pounds of
contaminated soils per hour for 12 hours per day, the opera-
tion would be expected to be complete within two to three
years. As with alternative SC-3A, actual quantities of soils.
to be treated will be verified through a detailed soil sam-
pling program during design.
Table V-10 presents an evaluation of the Low Temperature
Thermal Stripping Alternative with respect to the first six
OSWER criteria. This alternative received an overall ranking
of high for protection of human health and the environment as
it eliminates leaching of contaminants from soils to the
ground water by permanently and significantly reducing the
volume and toxicity of contaminants. This alternative will
also comply with all applicable or relevant and appropriate
-------
BLE
TABLE V-10
SC-4A/4B - LOW TEMPERATURE THERMAL STRIPPING/
Remedial
Alternative
licavation of
Contaiinated
Soils «ith
on-iite treatient
A. UN Teipera-
ture fkeraal
Strippinl
Reduction of
Toxicity
Mobility or
Volume
Hi|b
Reioval of soili re-
loves tkreit.
BliiiRites leackini
of contaiiaanti froi
soils to irouadvater.
Reliability
SOIL WASHING
Inplementability
Cons true tabi 1 i ty
li|k
Tecknoloif kai been
used and demonstrated
to be effective at
otker katardous uaite
sites.
EVALUATION
Short-Term
Effectiveness
Hilk/Hediua Hediui
Proceii equipment for Hiniial worker aad
tkerial strippinl of reiident eiposure to
contaiiaaati froi loili possible vapor eiia-
caa be obtained vitk lions durin| tke
little difficalt}. treatient proceii.
flobilisatioa and itart- Potential of worker
Oonpliance
with
ARARs
Long-Term
Effectiveness
fliik lilk
Coiplies Nitb 1CIA 41 leioval of contaiinanti
CFI Part 114 Subparti froa tke soils «ill
G, L, I; liecitive iiti|ate douanard li-
Order llllfi, and tke fratiea of coataii-
Fisk t Vildlife Coordi- aants to tke irouad-
aation Act. water, and accelerate
iroaadnater clean-up.
8. Soil Vatkint
Overall Bankinl
Capital Costi of
Tkerial Strippinl
13,905,000
Preient Value of
0 I R Cost of
Tkerial Strippinl
(Z.SM.OOO
Total Present
Vortk Costs of
Tkerial Strippinl
$8,519,000
Capital Costi of
Soil laikini
16,705,000
Preient Value of
0 a H Coiti of
Soil itsiint
11,120,100
Total Preient
Vortk Coiti of
Soil Vaskinl
up of proceii equip-
teat it relatively
eaij.
lieavatioa aad treat-
lent equipient sabject
to adjutieit, uiite-
aance lad breakdown.
eipoiure to contaai-
aaled soils dirinl
eicavatioa aad soili
kaadlini operatioai.
Possible fugitive duit
and vapor eiissieaa
froi soils eicavatioa
aad kaadlini, aad froi
treatieat optratioss.
tent of SAIA ia tkat a
peruneat redaction ii
voUae, toiiciti aad
•obilit; of coatui-
auts ie provided.
leioval of coataiiaaati
froi tke sails reduces
tke riik of derial coa-
tact and iaieitioi of
coitaiiauts.
-------
39
Federal and State requirements.
5. BC-4B —— glCAVATIOM OF COMTAMTMATBD
OM-8TR TBKAmsm (Soil Washina)
The soil washing alternative involves excavation, mixing of
the soil with a laaching medium and axtraotion of tha leaeh-
ing medium and assoeiatad contamination from tha soil. Tha
contaminated soils ara passad through a sarias of raaetion
vassals where they ara mixed with a leaching medium. The
laaching medium "washes'* the contaminants from the soils.
For the contaminants at the KE8 Site, a water/surfactant or
water/methanol rinse is considered to be technically feasible
and cost effective. Pilot studies conducted during design of
this system will determine which of the two extract solutions
is most suitable.
The soil/water mixture is then transferred to a plate and
frame filter press for dewatering of the "cleaned" soils.
The dewatered soils are returned to the excavation. The con-
taminated leachate would be treated by a ground water treat-
ment system. In addition to the capital expense for equip-
ment, operation and maintenance of the alternative includes
personnel, replacement of leaching medium, power, sludge
disposal, sampling and analysis. Operation is expected to
last for two years based on processing 10,000 lbs./hr., 12
hrs./day, 5 days/week. Actual volume of soils to be treated
will be verified during the initial phase of design.
Soil washing/extraction has been applied at a number of
industrial, defense and superfund sites throughout the
country, as well as several industrial sites in Europe. The
primary contaminants that this technology has been applied to
in the past are heavy metals such as lead, mercury and
chromium. The mining industry has also utilized this tech-
nology for the recovery of gold, silver and other precious
metals. The petroleum industry has for many years used the
extraction process for the removal of phenolics, pyridines
and quinolines from crude coal tars with the use of caustic
and acid washes.
Table V-10 presents an evaluation of Soil Washing with
respect to the first six OSWER criteria. This alternative
received an overall ranking of high for protection of human
health and the environment. As with alternative SC-4A, soil
washing is a proven technology which will permanently and
significantly reduce the volume and toxicity of contaminants.
6. 8C-7 •• OFF-I
The off-site disposal alternative entails the excavation of
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40
contaminated soil with disposal at a RCRA approved off-site
landfill. The procedures necessary to implement this alter-
native include excavation, devatering, transportation,
disposal and site restoration.
After the soil is excavated, the moisture content of the soil
must be reduced before it can be transported in accordance
with RCRA 40 CFR Section 264.314. Several options for the
devatering process include mechanical dewatering (i.e. a
rotary kiln), open bed aeration and the addition of absorbent
material to the soils. Mechanical dewatering, in the form of
a rotary kiln, is preferred because it does not generate an
aqueous sidestream and can also achieve the smallest volume.
Operation and maintenance costs for this alternative are low
in comparison to the other source control alternatives. This
is because excavation and hauling would be performed by a
contractor and are considered part of the capital expense.
Operation and maintenance will include on-site personnel for
overview, maintenance of the fence and labor and equipment
for erosion control. This alternative will require approxi-
mately one year of operation.
Table v-ll presents an evaluation of Off-Site Disposal with
respect to the first six OSWER criteria. The overall ranking
of this alternative is medium for protection of human health
and the environment. Although the contaminated soils are
removed from the site, this alternative does not result in a
permanent reduction in the volume or toxicity of the con-
tamination as required by CERCLA Section 121.
7. MOM-GW1 — MO ACTION
This alternative involves a long-term monitoring effort to
assess off-site migration of contaminants and any subse-
quent impacts which may result if this alternative is
chosen. As migration proceeds from source areas to the
Site boundaries, natural processes act to reduce
contaminant -levels in the various environmental media.
These processes include volatilization, biodegradation and
dilution with contaminant-free water. The no-action
alternative depends upon these processes to significantly
minimize off-site contaminant migration. If adverse off-
site impacts occur, corrective action is required.
Groundwater monitoring includes evaluating background water
quality and the water quality leaving the Site. Background
water quality can be assessed by monitoring upgradient
wells CW-1A and CW-1C.
Downgradient monitoring wells CDM-1A, CDM-2B, CDM-3A, CDM-
3B, CDM-5A and CDM-5B can be used to assess the ground
-------
41
TABLE V-ll
SC-7 - OFF-SITE DISPOSAL EVALUATION
Remedial
Alternative
SC-1
licavatioh of
Coatuinated
Soili aad Off-
lite Diapoial
in i ECU
landfill
Overall taakiftf
Nediua
Capital Colt
111,4(4,000
Preaeat Value of
Old Coit
111,100
Total Preeent
VorU Coat
111,411,100
Reduction of
Toxicity
Mobility or Inplementability
Vblume Reliability Cons true tability
Rediu
leaoval of aoila re*
•OTta tateat trot, tie
leeft lite.
Iliaiaatei leacklai
froi contuiaated aoila
to tie (rondMter.
Tkere la ao perauent
redictioa ii tke vel»ie
or toiieitf of coitui-
aaata aa coatuiiatei
aoili are relocated
retker tku treated.
lediM Redin
Teckeoloif kae aeea licavatioa teckii«.aee
•aed ud deioaatrated are reUtiiely aiiile.
te be effective at
otker kaiardoaa nute Ufiatical proileu
litea. aaiociatd titk traaa-
aart to otker full
Poteatial rial of re* of tke coutrf.
leate of ctatuiaaiti
frta tke ICU ludfill.
Oocrpliance
Short-Term with Long-Term
Effectiveness ARARs Effectiveness
•ediu
Poaaikle f«4iti»e diet
ud vator eiiaaioii
froi aoila eicavatioa
ud iudlii|.
Poteatial ciiata for
eipoem to tke aokllc
die to accideat d trial
traaatort.
learkr reaidetta, cape*
cialli ckildrea tt •
ireater ritk lu to
iacrcaeed trick
traffic.
Leu
Coipliei iltk ICU (0
CPI fart 114 likptrta
6, L, 1; Isecative
Order lllll, ud tke
Piik I liUllfe Coorll-
aatioa Act.
loci lot eetfli vitk
tke lateat of IftU aa
•ffilte IliptMl •Itk-
••t treaUeit doee lot
provide • periucit
aoUtioa ui le a leaet
favored tlteraative.
UN
C«ataaiauta are re*
•oved free tke lite
aid firtker coatMi-
aatioa of Ike croud*
•ater la aitiuted.
Poteatial eiiata tor
failare of or ftUre
reipoue dork at tke
ICU Ludfill.
leMvod coatuiaated
Mill reuia ia
kturdeu fora, volue
ud toiicltf.
-------
42
water quality of flow exiting the Site. Under the no-
action response, additional monitoring wells are installed
to monitor ground water quality flowing off-site in the
vicinity of the Unnamed Tributary. These wells form a
cluster with one well in the overburden and one well in the
bedrock. Residential wells along Exeter Road also would
have be sampled.
A quarterly sampling and analysis of these wells would be
conducted until the potential threat is eliminated. The -
sampling results would be evaluated regularly in order to
estimate plume migration and dispersion potential off-site.
The quarterly sampling is anticipated to extend over at
least a ten-year period, after which fewer wells may be
monitored on a bi-yearly basis. If data from the previous
monitoring results strongly indicate that there is no
potential threat, the monitoring may be stopped. Migration
of contaminants off-site into the Unnamed Tributary would
be monitored on a quarterly basis for at least five years.
The time to reach acceptable cleanup levels in ground water
beneath the source soils is estimated to be 200 years (ref.
to discussion for SC-1, No Action).
Table v-12 presents an evaluation of the No-Action Alterna-
tive for the management of migration with respect to the
first six OSWER criteria. This alternative received an
overall ranking of low for the protection of human health
and the environment because it does not provide for the
permanent reduction of volume, toxicity or mobility of con-
taminants and does not comply with applicable or relevant
appropriate Federal and State requirements.
8. MOM-GW3B — ON--SITE TREATMENT:AIR STRIPPING/FILTRATION/
CARBON ADSORPTION (Discharge to Groundwater)
This alternative involves removing contaminated ground
water from both the sand and gravel deposits and the
bedrock aquifer on the Site. Ground water removal will be
accomplished using collection trenches in the sand and
gravel deposits, and existing bedrock wells. The ground
water would be pumped to a vessel where it will be allowed
to trickle down over a packing material while air is forced
upward. As the air passes over the contaminated ground
water, the contaminants are stripped from the ground water
and are carried off with the air stream. The air stream
containing the contaminants is then treated in activated
carbon columns prior to release to the atmosphere. Ground
water from the air stripper would also receive further
treatment with activated carbon before discharge to a
ground water recharge area adjacent to the wetland along
the western border of the site.
-------
43
TABLE V-12
MOM-GW1 - NO ACTION EVALUATION
Remedial
Alternative
Reduction of
Toxicity
Mobility or
Volume Reliability
Iirplanentability
Cons true tability
*
Short-Term
Effectiveness
Compliance
with
ARARs
Long-Term
Effectiveness
ROB-MI
lo Action
Owill lukiiif
Lot.
Cuitil Coiti
tit,too
Redim/loN
Tie iitvril elcMiiii
of Ike tuifer Hill
tike uij yeiri.
No itreu kti beet
obiemd ii tie let-
ludi.
Preieit ViUe of Potutiil receitori
0 i R Coiti
11,001,000
Totil treteit
Vortk Coiti
11,044,100
ire eurreitlf let
•till iiucted til
driikiii niter.
Uv
Oi otker litei vitk
•iiilir coituiiuti,
tkt tive eitiuted
fer Html cleiniii
of tke iqnifer rufed
froe SO to 2(0 teiri.
lilk
Centmctiei ud iiile-
•eitikilitf ire eiiil|
iccoiiliiked.
Coiti ire leu.
Coitiiwd freudvlter
•oiitoriii ii euily
iiiltMited.
UK
l«ei tko«|k receit
veil teiti do lot
iidicite tie ireitice
of coituiiuti, tke
tkreat of coitiued
•igntioi of coitui-
uted frovidviter to
poteitiil men re-
it in.
Doei tot coiilf »itk
ICU-40 cn Part IM
likpirt F; liecitiT*
Order 11110; Stond-
mter Protectiei Itri-
ten; ud Fill ud
Vildlife Coordiiitioi
Act.
loci lot cowlf vitk
Siri reMirevcit of
leriueit redtctiu ii
tolue, toiicltj, or
•obilitf of coitul-
uitt.
Coituiiuti ire left
u lite reqiirin
S-yeir UIA refiev.
Uv
Groudviter reiiiu eoi-
tuiuted.
Poteitiil for fitire
cutuiutioi of mrly
doteitic velli.
littril reitoritioi of
tke iqiifer vill be
(ridiil, ttkii| uif
yeiri.
fitire develipteit ii
tke irei vill reitlt
ii iicreued |roud-
•iter luiiii ud tkere-
fore iicreued lifritioi
••tut ill.
-------
44
Operation and maintenance costs for this alternative
include labor for operations and maintenance, chemicals,
power, materials and supplies, water and metal sludge
disposal. Chemical costs are estimated based on the chemi-
cal required for pH adjustment, coagulation and carbon.
Disposal costs include the cost for sludge disposal at an
approved facility. Assuming a ground water removal rate of
4-7 gallons per minute and implementation of a source con-
trol treatment alternative, approximately five years will
be required to attain an acceptable cleanup level in the
ground water. With no soil treatment, a significantly
longer period of ground water treatment may be necessary.
Table V-13 presents an evaluation of this alternative with
respect to the first six 08WER criteria. The overall
ranking for this alternative is high for protection of
human health and the environment because it provides per-
manent treatment significantly reducing the toxicity of the
contamination. This alternative also complies with all
applicable or relevant and appropriate Federal and State
standards.
9. MOM-GW4A — OFP-SITE TPKVTMEHT XT TSD FACILITY
This alternative entails extraction of contaminated ground
water, bulk containerization and transportation to a RCRA
Treatment, storage and Disposal (TSD) facility. It should
be noted that §121 of CERCLA states that off-site transport
or disposal without treatment is a least favored alterna-
tive. This alternative uses the same extraction scenario
as described in MOM-6W3B. The contaminated water, which is
pumped from the bedrock wells and collection trench, is
temporarily held in storage tanks on-site for transport to
an off-site RCRA treatment storage and disposal facility.
An estimated volume of between 42,000 and 72,000 gallons of
contaminated ground water will be disposed of weekly.
Operation and maintenance costs for this alternative
include personnel for operating and maintaining the pumping
facility, power, effluent disposal, sampling analysis. •
Assuming the same ground water removal rates as with Alter-
native MOM-GW3B and implementation of a source control
treatment alternative, approximately five years of pumping
will be necessary to restore the ground water to drinkable
quality.
Table V-14 presents an evaluation of this alternative with
respect to the first six OSWER criteria. Although this
alternative provides a permanent reduction in the volume of
contamination, it is given an overall ranking of only
Medium for protection of human health and the environment
due to increased safety risks associated with the transport
of contaminated ground water.
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45
TABLE V-13
MOM-GW3B - AIR STRIPPING EVALUATION
Remedial
Alternative
MR-CHI
tetonl will
Oi-Sitt
Tttttteit
A. Air Strippiii
Nitk Carkoit
Adiorptioa nd
Diickirfe to
Grovaduattr
Omill tankiac
lilk
Capital Coitt
IW.OOO
•reieat Valae of
0 1 R Coiti
WJ.IOO
Totil Preiett
lortk Coiti
II.W.IOO
Mobility or Inplementability
Volune Reliability Constructability
lill
lill treit iroaadvater
to Mil.
Poteitial tkreat fraii
coataaiaatei |rouid-
mUr it litiitted.
Tlii treatieat proceii
vill remit it a per-
•ueit aad aiiaificut
red»ctioi it felu« ud
lilt
Utit pr«ctnti aid
tiailar iff leu kaie
provta laeceiifil at
otket l»»erf»ad litct.
Ptritdic itaitoriai
•f rcaiieatial «lli
vill cmtime dirin
elcai-ii.
1
toiieitf of eeitiiiiuti.
Htdi»i/li|k
Tic iraccii t^tiptcit
it Hbitaatialli itl(-
coitaiied aad kai kcei
ceaitraettd ud tptra-
ted at otkcr ittei vitk
little diffictltj.
litrutiM of |r»»id-
Mtct fr«a tkt tarfi-
cial aid bedrock a^ai-
fer «| be difficult.
Tke tile retired to
cttraet froiidv*ter ia
difficilt to predict.
Qrtaidtater puflai
aad irocen eo.aiaacat
ia lakject ta roatiae
atckaaical kreadoni,
aaiateaaace aad
retain.
Short-Term
Effectiveness
lilk
licatatioa of treackei
(or collectioa of
iroudnater ia tke nr-
ficial aquifer aaf re-
aalt ia vorker eipoaare
to »at*r aad partica-
late eaiiiion.
larricadiif treackei
akoald proflde for
•orker tafetf dartai
iraaadmter eitractioa.
lacreaied riak
aiiociated »itk potea-
tial (or ipilla dariaf
coataiaeriiatioa aad
traaiport.
with Long-Term
ARARs Effectiveness
lilk
Coapliea nitk ICU-41
CM Part H«, ud
liccative Order lllll;
Iriaklai later Itu-
darda; Croaadvater
Protectioa Itraten;
aad Fiak ud lildlife
Coardiaatiaa let.
Catpllei «itk tke ii-
tcat »f lUi to it.
tidt a ptrMiaat or
aifaificut retactioa
ia tke foUae, toiicitf
ud aoktlit) of coa-
tuiauti.
liH
laprmaeit to tke
lioloiical eaviroaaeat
•ill ae rapid aid
fatart aae of tke aa.ai-
fer cu ke reitored.
foteatial tkreat froa
coatuiaated froaad-
vattr aiiratioa it
ai tinted.
Maced eipoaare po-
teatial froa coataai-
aattd iraaadvater to
tke local popalatioa.
-------
TABLE V-14
MOM-GW4A - OFF-SITE TREATMENT EVALUATION
Remedial
Alternative
Reduction of
Toxicity
Mobility or
Volume Reliability
Implementability
Cons true tability
Short-Term
Effectiveness
Ccrpliance
with
ARARs
Long-Term
Effectiveness
non-cm
teaoval and Off-
tite Treititit it
an TSO Ficilitj,
Overall tinkinf
Hedua
Capital Coiti
i, 100
Preieat Value of
0 a II Coiti
11,101,100
Total Preient
Vortk Coiti
Bilk
Potential tareat froa.
coataaiaated froiiad-
vater ia aitifated.
teaoval and treatneat
providei a tifaifieaat
aod perauitat redactioa
in tie voluie, toiicity
and nobility of COB-
taniaaata.
lilk
Unit proceaiea aad
aiailar ifiteai lave
proven ucceutal at
otier Saperfaad sitei,
Periodic toiitoriai
of reaidential nelli
•ill coatiaae dorin|
clean-up.
U«/Hedi«i
Iitractioa of
vater trot tie aarfi-
cial aad bedrock aqui-
fer iaj be difficult.
Groaadvater paipiaf
eqaiptent ia aakject
to roatiae atckaaical
breakdonna, aaiateaaace
aed repaira.
lacretaed riak aiaeci-
ated litk poteatial
apilla dtrlai traaa-
port of coataiiiate4
froaadvater.
Ucatlai a TSD facility
•af be a preklei.
Hediu
licaiatioa of trenckea
for collection of
grovadvater ia tke aar-
ficial aqaifer iai re-
aalt ia worker eipoanre
to vapor aad partica-
late eiiaaioaa.
larricadiaf treackea
akoald provide for
worker aafetf daria|
fronadiater eitractioa.
lacreaaed riak aaaoci-
ated iltk potential
apilla dariai traaa-
port of coatuiaated
|rouad«ater.
Hediai
Coipliea litk ICIA-M
CPt Part tM aad
liecatlve Order 1ISII;
Driakiaf later Staa-
darde; 6reaad«sUr
Protectioa Itrateu;
aad Piak aad lildlite
Coordiaatioa let.
altkoalk tkia alteraa-
tive providea a peria-
aeat and aiiaificaat
redactioa la tke vol-
ne, toiiciti aa4 10-
kilit; of coataaUaata,
tke traaaport of kaiar-
doaa nateriala off alti
•akea tkia a leait
favored alteraatiu.
Inproveneat to tke
kioloiical eavironneat
•ill be rapid aad
faUre aae of tke aqai-
fer can be reatored.
Peteatial tkreat fron
coataaiaated iroud-
•ater ni|ratioa ia
litigated.
ledaced eipoaare po-
teatial froa coataai-
nated |roaad«ater to
local pepalatien.
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47
VI. PfflrlPCTIOM Ol
A. Description of the Selected Remedy
The remedial action selected for implementation at the Xeefe
Environmental Services Superfund Site is consistent with the
Comprehensive Environmental Response, Compensation and Liabil-
ity Act of 1980 (CERCLA) as amended by the Superfund Amendments
and Reauthoriiation Act of 1986 (SARA) and, to the extent
practicable, the National Contingency Plan (NCP) 40 CFR Part
300 et sea.. 47 Federal Register 31180 (July 16, 1982) as
amended. The selected remedial action is a comprehensive
approach for site remediation which includes a source control
and management of migration component. A comprehensive ap-
proach is necessary in order to achieve the response objectives
established for site remediation and governing legal require-
ments.
The source control component of the selected remedy is in-situ
treatment utilizing vacuum extraction as described for Altern-
ative 8C-3A in the Detailed Evaluation of Alternatives (Section
V.E.).
Vacuum extraction involves the removal of unsaturated soil
source contamination by developing a vacuum-within the soil
matrix in order to induce air and contaminant flow through the
pore structure. As soil gas migrates through the pore spaces,
mass transfer between the trapped residual unsaturated con-
tamination and the air occurs, releasing the contamination.
This facilitates contaminate removal without soil excavation.
Reports indicate significant quantities of contamination can be
removed in this manner in a relatively short time frame. For
example, over 250 pounds per day (18.8 gallon per day) of
Carbon Tetrachloride (CCL4) was removed from a clay soil matrix
using this technique at a recent tank farm spill.
Vacuum extraction is classified as an active vapor collection
system. It consists of vapor extraction wells, vapor collec-
tion headers, vacuum blowers or pumps and vapor collection
(condensers) and/or vapor treatment (carbon adsorption) equip-
ment. The technology is not considered extremely innovative as
a few case histories are available.
Four areas at the KE8 Site may be subject to the vacuum ex-
traction system. The depth to ground water in these areas
varies from 7-10 feet in the central portion of the Site to 3-5
feet in the southwestern corner of the Site. A maximum area of
150,000 square feet is estimated for vacuum extraction. This
area will be confirmed through additional soil sampling during
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48
the pilot plant study stage of remedial design. In the areas
where the water table is high (i.e., the southwestern portion
of the site), the vacuum extraction system may be more diffi-
cult to operate due to the increased moisture that will
undoubtedly be removed during extraction. However, if ground
water extraction and treatment systems are installed, the
ground water depth will drop allowing for improved efficien-
cies. Although the length of time for treatment is dependent
upon extraction efficiency and actual soil areas to be treated,
both of which will be further defined during the pilot plant
study stage, five years for treatment has been conservatively
estimated for costing purposes.
This alternative is expected to require relatively little time
to implement. Several vacuum wells can be completed by a
single crew in a day and collection piping and mechanical
equipment can be installed concurrently. No soil excavation is
required. Vapor extraction can be started upon completion of
the system and immediate removal of contaminants realized.
The extracted gas will contain high levels of volatile organic
compounds (VOCs) and moisture. Moisture will be removed by a
sloping header followed by a water cooled condenser to remove
any remaining moisture and some VOCs. Water for the condenser
will be supplied by the ground water treatment system recom-
mended for the management of migration alternative. Moisture
collected in the condenser will be returned to the ground water
treatment system for treatment. The system provides a high
degree of flexibility. Valve adjustments enable the operator
to maximize (or minimize) flow from an area. Flow adjustments
are made initially so that most of the extracted flow is from
the area of highest contamination. As concentrations are found
to decrease, adjustments can be made so that most of the flow
is directed toward areas having the highest contaminant levels.
Capital costs include costs for extraction wells, vapor collec-
tion header piping, blowers and associated valves, electrical
fixtures, etc., condensers and carbon canisters. Additional
costs include provisions for pilot studies and sampling equip-
ment (bottles, coolers and car rental). These costs are
presented in Table VI-1. Operation and maintence costs include
costs for electricity, small material costs such as tools,
lubrication and belts, manpower costs and other annual costs
such as insurance, security and administration. Additional
soil and vapor sampling are included in this estimate to fur-
ther define existing soil contamination and to provide documen-
tation for system performance. Table VI-2 illustrates these
costs and the total cost for this alternative. The management
of migration component of the selected remedy is MOM-6W3B
consisting of air stripping, filtration, carbon adsorption and
discharge back to ground water.
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49
TABLE VI-1
CAPITAL COSTS FOR SOURCE CONTROL*
Quantity
Vapor extraction 200
well (drilling,
stone, piping,
etc.), in place
Well connection 20
lateral (10 ft.
piping valve,
excavation,
fittings, etc.),
in place
Vapor collection 1,000
header ,
in place
Blower facility 1
{blowers(s), safety
dev i ces, va1ves,
foundation, piping,
fencing, electrical
components and
service connection},
in place
Mobile Treatment 1
Facility
Sampling Equipment 1
Electrical Utilities
Engineering & Design(15%)
Contractor Profit (10%)
Contingency (15%)
Pilot Studies
Unit
Vert. Ft.
Unit Cost
$ 115
Each
2,250
Linear Ft.
150
Lump Sum
150,000
Each 300,OOO
Each 7,500
Subtotal Cost
Total Cost
$ 23,000
45,000
150,OOO
150,000
300,OOO
7,500
30.400
705,900
105,885
70.59O
105,885
150.000
$1.138,260
*SOURCE: SCS Engineers 1980 (updated to 1/88)
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50
TABLE VI-2
OPERATION AND MAINTENANCE COSTS FOR SOURCE CONTROL
Item Quantity Annual Unit Cost $
Maintenance Lump Sum $ 11,200
Power Lump Sum 43,700
Sampling Labor Costs 640 Manhours 28.0OO
@$45/manhour
Personnel 14,000 Manhours 630,000
645/manhour
Analytical Laboratory Costs 200 Soil and Vapor 100,000
samples
@$500/sample
On-Site Analytical . 640 Manhours 28.800
Capabilities @$45/manhour
(Vapor Sampling Only) $ 842,500
Five-year Present Worth of O&M Costs: $3,193,900
Total Cost: $1,138,270 + $3,193,900 = $4,332,170
^Quantities are per year allowing for quarterly sampling of site
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51
This alternative entails extracting contaminated ground water
from both the overburden and bedrock aquifers, treating it on-
site using air stripping, filtration and carbon adsorption and
discharging it to the ground water. Air stripping is preceded
by coagulation/precipitation for metals removal in a clarifier
and followed by neutralisation.
The metals analyses seem to indicate that no metals are present
above water quality criteria; however, metals removal is neces-
sary to remove iron from the ground water. Although no iron
analysis data is available for the ground water at this Site,
ground water containing VOCs typically contains large quan-
tities of iron due to leaching out from the soil. This iron
must be removed before the water enters the air stripper, or
else the iron will oxidize and precipitate out onto the tower
packing causing operational problems. A coagulation/precipit-
ation system will typically remove metals down to a few parts
per billion.
around water from the bedrock will be extracted using the
existing deep (115 feet) ground water extraction well CW-3C and
CW-5C. The estimated pumping rate for CW-3C and CW-5C will be
2-5 gallons per minute (gpm). In addition,'two , two-foot wide
collection trenches and overburden well CW5A will be used to
extract water from the overburden aquifer. Combined length of
the two-foot wide trenches is 2300 feet. The estimated pumping
rate for the removal of ground water from the trenches and well
CW-5A is 2 gpm. The combined rate of ground water* removed from
the wells and the trenches is 4 to 7 gpm. Based on the volume
of the aquifer, the pumping rate of 4 gpm represents a volume
treated of o.l pore volumes per year. The exact location and
sizing of the ground water extraction system will be accom-
plished during the design phase.
The coagulation/precipitation operation is carried out in a
reactor/clarifier. This single unit combines chemical mixing,
flocculation and settling. The unit and all chemical feed and
storage systems would be located in a building to prevent
freezing during winter operation. Chemical coagulation with
alkali reduces the concentration of metals to the 0.01 to 0.5
ppm range depending on the metal and its oxidation state.
The metal hydroxide sludge from the bottom of the reactor/clar-
ifier is continuously pumped to a sludge thickener/holding tank
where the sludge is temporarily stored and thickened. The
thickened sludge is then pumped to 55-gallon drums. Approxi-
mately one, 55-gallon drum of sludge would be produced per day.
This estimate will be confirmed or modified by the treatabil-
ity study. The sludge will be classified as a Resource conser-
vation and Recovery Act (RCRA) hazardous waste and will require
disposal at a licensed hazardous waste treatment, storage and
disposal facility (T8D).
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52
Air stripping is used to remove toxic volatile organics from
the ground water. Air stripping is relatively inexpensive yet
an effective means of removing contaminants from the ground
water. The air stripping units consist of packed towers filled
with plastic packing media such as polypropylene rings. Air is
blown countercurrent to the flow of liquids. The packing
height is estimated to be approximately 12 feet for removal of
VOCs up to 90 percent. This process is very effective in
removing volatile organic compounds which are the major concern
at the KES Site.
The air stream exiting the air stripping towers contains vola-
tile organic compounds and must be treated prior to discharge
to the atmosphere. The processes available for removing volat-
ile organic contaminants from the air stream are vapor phase
carbon or flaring of the air stream. Vapor phase carbon adsorp-
tion would be the most economical, based on the expected air
flow and composition of organics in the air. The tower exit
air is dehumidified and passed through vapor phase activated
carbon beds where the volatile organic compounds are selective-
ly adsorbed and thus removed from the air stream.
The treated ground water from the air stripping tower dis-
charges to a neutralization tank, where the pH is lowered to
between 6 and 8. A pH of 7 is neutral being neither acidic or
alkaline.
The effluent from the neutralization tank is pumped through a
pressure filter to remove suspended solids which may clog the
activated carbon columns. The filter media consists of
finely-graded layers of gravel and sand. A backwash water
system is used to wash the filter medial periodically. The
contaminated backwash water is recycled to the reactor/clarif-
ier for treatment.
Granular activated carbon is used in the final treatment pro-
cess to adsorb the remaining toxic organic compounds from the
ground water. Activated carbon is effective in adsorbing a
wide range of organic compounds. Data compiled by Shuckrow et
al, show that activated carbon can achieve high removal ef-
ficiencies of 80 to 100 percent for many of the 126 compounds
on EPA's priority pollutant list. The combination of chemical
coagulation and activated carbon should reduce organic and
metal concentrations to below the National Water Quality Crite-
ria. Pilot testing will be required to confirm these removal
efficiencies.
Treated ground water from the carbon contractors will be pumped
to recharge beds located along the western border of the Site
next to the wetlands. The recharge beds allow the treated
ground water to be discharged uniformly to the ground and
ultimately into the ground water aquifer and wetland. Other
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53
discharge alternatives such as direct discharge to the wetland
and ground water discharge along the eastern border of the
Site were also evaluated. A ground water discharge along the
eastern border of the Site was eliminated because of the very
tight soils on-site and the quantity of treated ground water
which will be discharged. The soils covering moat of the Site
are a weathered till which is not conducive to ground water
movement. Because of this tight soil condition, a trench
system for collecting overburden ground water is proposed
rather than extraction wells or a series of well points. Once
the collection trenches are installed, very little area will
remain to construct recharge trenches. Also, the collection
trenches will collect only about two gallons per minute of
ground water from the sand and gravel deposits. The recharge
trenches will have to be sised for a combined flow of 4-7
gallons per minute. The siiing of a recharge trench system to
handle this larger flow is possible along the western border
of the Site where the soils are not as tight and the depth to
ground water very shallow. Treated ground water discharged to
recharge trenches along the western border of the Site will
almost immediately enter the natural ground water system and
ultimately the wetland. A direct discharge to the wetland was
also evaluated, since the treated ground water will meet
drinking water quality, a direct discharge to the wetland will
not result in adverse impacts. The added flow to the wetland
will also serve to maintain the wetland during periods of dry
weather. The recharge trench system was chosen over a direct
discharge because it will provide a more uniform distribution
of flow and eliminate potential problems with erosion or freez-
ing conditions in cold weather.
Ground water extraction and treatment will proceed for five
years or until cleanup goals, as presented in Table VI-5, have
been achieved, which ever is sooner. If, after five years the
cleanup goals have not been achieved, an evaluation will be
performed to determine if the cleanup goals are still valid and
technically attainable. Ground water treatment will cease upon
achieving cleanup goals in the influent to the treatment facil-
ity and all monitoring wells. Upon ceasing ground water treat-
ment, the monitoring wells will continue to be sampled to
insure that cleanup goals have been achieved.
Capital costs include costs for extraction wells, vapor collec-
tion header piping, blowers and associated valves, electrical
fixtures, etc., condensers and carbon canisters. (See Table VI-
3). Additional costs include provisions for pilot studies and
sampling equipment (bottles, coolers and car rental). Opera-
tion and maintenance costs include costs for electricity, small
material costs such as tools, lubrication and belts, manpower
costs and other annual costs such as insurance, security and
administration. Additional soil and vapor sampling will be
included in this estimate to further define existing soils
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54
TABLE VI-3
CAPITAL COSTS FOR MANAGEMENT OF MIGRATION
COST
Collection System $ 70,000
Coagulation/Precipitation 42,000
Air Stripping 29,000
Pumping 42.00O
Sludge Thickener 3,500
Building 27,000
Electrical 17,000
Sitework 25,000
Discharge System * 19,000
Dual Media Filtration 47,000
Carbon Adsorption 133,500
Vapor Phase Carbon 64.000
TOTAL $ 519,000
Pilot Treatability Study $ 150,000
Engineering Administration (10%) 52,000
Contingencies (15%) 78,000
TOTAL PROJECTED COST $ 799,000
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55
contamination and to provide documentation for system perfor-
mance. Table VI-4 illustrates these costs.
Ground water and soil cleanup levels for the Keefe Environ-
mental Services Site were developed on the basis of the Base
Line Risk Assessment, Chapter 8 of the Supplemental Remedial
Investigation, and the evaluation of the No-Action Alternative
in the Feasibility study. The base line risk assessment deter-
min'ed the present and future potential risks to public health
and the environment associated with the exposure to the con-
taminants from the Keefe Environmental services site in the
absence of any remedial action. The no action evaluation in
the Feasibility Study established goals for cleanup. Since the
soil contamination of the Xeefe Environmental Services Site is
the source of ground water contamination, cleanup goals were
set for both ground water and soils. The point at which the
ground water cleanup goals are attained was chosen as anywhere
beneath the site.
Of the eighteen compounds detected in ground water and/or soils
at the KES Site, five compounds were selected as human health
indicator compounds based on their potential carcinogenic
effects. The indicator compounds selected for the KES Site are
Benzene, Tetrachloroethylene, Trichlorethylene, 1-2 Dichloroet-
hane and 1-1 Dichloroethylene. The National Primary Drinking
Water Standard/Maximum Contaminant Level (MCL) for Benzene,
Trichloroethylene and 1-2 Dichloroethylene is 5 part« per
billion while the MCL for l-l Dichloroethylene is 7 parts per
billion. An MCL for Tetrachloroethylene has not been
developed; however, it has similar chemical, physical and
toxicological properties as Trichloroethylene and therefore
the same standard of 5 parts per billion will be used. The
cleanup goals for ground water are set at these levels. The
cumulative risk associated with these proposed cleanup goals
falls within EPA'a acceptable risk range of 10~4 to 10~~ and
are presented in Table VI-5. Assuming that the concentration
of these indicator compounds will remain proportionally the
same during treatment, in reducing the level of Benzene down to
its MCL of 5 parts per billion (ppb), the concentrations of
Tetrachloroethylene, Trichloroethylene and l-l Dichlorethylene
could be reduced to 2ppb each and for 1-2 Dichlorethane may be
reduced to as low as 0.3ppb. At these levels, the incremental
lifetime cancer risk from exposure to ground water containing
this chemical mixture could be as low as 1.4 x 10~5. Actual
cleanup levels attained should result in a cancer risk ranging
between 1.4 and 5.7 x 10~5.
Estimated soil source contaminant goals were based on the
allowable ground water concentration. The estimated adsorption
coefficient, which is the ratio of the concentration of the
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56
TABLE VI-4
OPERATION AND MAINTENANCE COSTS FOR MANAGEMENT OF MIGRATION
Annual Costs
Personnel $ 68,320
Maintenance 33,600
Power 3,360
Chemicals 28,000
Water 1,120
Sample and Analysis 89,600
«
Sludge Disposal 30.240
TOTAL $ 254,240
5-Year Present Worth Cost
$254,240 x 3.791 = $963,800
30-Year Present Worth Cost
$254,240 x 9.427 = $2,396,700
The total estimated cost for this option is the sum of the capital
costs and the operation and maintenance costs.
This sum is:
5-Year: $799,000 + $ 963,800 = $1,762,800
30-Year: $799,000 + $2,396,700 = $3,195,700
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Compound
Benzene
Tetrachloroethylene
Trichloroethylene
1,2-Dichloroethane
1,1-Dichloroethylcne
57
TABLE VI-5
GROUND WATER CLEANUP LEVEL RISKS
Group
Classification*
A
B
B
B
C
Cleanup Goal (MCLs)
(ppb)
5
5
5
5
7
Cancer Risk
4.2x10-•
7.1xlO-«
1.8xlO-«
13.2xlO-«
30.5xlO-«
Group A & B Risk
Group A,B & C Risk
2.6xlO-»
5.7xlO-»
*Reference:
Superfund Public Health Evaluation Manual
Office of Emergency and Remedial Response EPA/540/1-86/060
•EPA
Category
Description
of Group
Description of Evidence
Group A
Group Bl
Group B2
Group C
Group D
Group E
Human Carcinogen
Probable Human
Carcinogen
Probable Human
Carcinogen
Possible Human
Carcinogen
Not Classified
No Evidence of
Carcinogenicity
in Humans
Sufficient evidence from epidemiologic
studies to support a causal association
between exposure and cancer
Limited evidence of carcinogenicity in
humans from epidemiologic studies
Sufficient evidence of carcinogenicity
in animals, inadequate evidence of
carcinogenicity in humans
Limited evidence of carcinogenicity in
animals
Inadequate evidence of carcinogenicity
in animals
No evidence for carcinogenicity in at
least two adequate animal tests or in
both epidemiologic and. animal studies
Source; Federal Register, Vol. 49, No. 227 pp. 46294-46301
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58
soil to the concentration of the water, was used to calculate
the corresponding level of soil contamination.
The distribution coefficient, K*, was calculated for each com
pound using the following relationship:
KjJ = I Q£
where
= the distribution coefficient describing the
distribution of a chemical between a soil and
water at equilibrium, ml/g.
foc = fraction of organic content present on the soil.
Koc = the organic carbon partition coefficient, ml/g.
Typically, glacial soils contain small amounts of organic
carbon, roughly 5 percent and calculating a Kd based only upon
this parameter would yield low Kd values since clay content and
iron oxide content of soils have been shown to significantly
increase the adsorptive capacity of soils. The soils at the
KES Site have large amounts of clay material and therefore the
K£ should reflect this. Since there have been no isotherm
tests performed to determine this parameter, the K
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59
contaminants is a principal element, are to be preferred over
remedial actions not involving such treatment. The statute
also requires EPA to select a remedial action that is protec-
tiv« of human health and the environment, that is cost-effec-
tive and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. The Agency may select an alterna-
tive remedial action meeting the objectives whether or not such
action has been achieved in practice at any other facility or
site that has similar characteristics.
Further, Section 121 (d) of CERCLA provides that EPA*s remedial
action, when complete, must comply with applicable or relevant
and appropriate environmental standards established under
Federal and State environmental laws.
1. Protectiveness
a. Source Control
EPA has determined that the proposed cleanup goals for
soils, as presented in Table VI- 6, are protective of human
health and the environment based upon assumptions presented
in Section VI. A. 2. of this document and Chapter 4 of the
Feasibility Study.
These cleanup goals for soils are associated with an excess
cancer risk of approximately 5.7 x 10~5 through ingestion
of ground water. EPA has reasonably assumed in its ex-
posure analysis that the Keefe Environmental Services Site
and immediately adjacent areas could be developed in the
future. Any development in this area would rely on ground
water as a potable water source.
Soil remediation to the proposed cleanup goals is necessary
to attain a ground water cleanup level that is protective
of public health and the environment within a reasonable
time frame.
b. Management of Migration
The Agency's decision to restore the ground water at the
Site to a cancer risk level of 5.7 x 10~5 was based on
several factors. The Agency considered its ground,
Protection strategy (OWPS) (Office of Ground Water
Protection, August, 1984) which provides guidance concern-
ing how different ground waters throughout the country
should be classified and to what extent cleaning up a
particular class of ground water is appropriate. EPA also
considered the Agency's draft Guidance on Remedial Actions
for Cftin^^BJnfi^^d Ground Water at Superfund sites (October
1986) . This guidance directs the Agency to consider a 10"4
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60
TABLE VI-6
SOIL CLEANUP GOALS
Soil Cleanup Goals
Compound Koc* Kd* (ppb)
Benzene 83 4.15 20.8
Tetrachloroethylene 364 18.2 91.0
Trichloroethylene 126 6.3 31.5
1,2-Dichloroethane 14 0.7 3.5
1,1-Dichloroethylene 65 3.25 22.8
1 Koc is the organic carbon partition coefficient.
Ref: Superfund Public Health Evaluation Manual
(Draft) OERR, OWSER Dec. 1985
* Kd is the soil/water adsorption coefficient calculated by:
Kd = Koc x foe where foe is the fraction of organic carbon
present in the soil (0.05)
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61
to 10~7 rang* of risk levels in selecting the appropriate
risk level for the ground water at the Sit*.
Tb* policy und*r th* 6WP8 establishes ground water protec-
tion goals based on "the highest beneficial uses to which
ground water having significant water resources value can
presently or potentially be put." Guidelines for protec-
tion of aquifers are differentially based, relative to
characteristics of vulnerability, use and value. Under the
classification scheme, the ground water at the ICES Site is
Class IX ground water. This ground water is considered to
be a current drinking water source since ground water is
used for drinking water within a two-Bile radius of the
Site (the classification review area) .
EPA believes that active restoration of the ground water is
appropriate for the Site. Presently, the residents in the
area obtain their ground water from either the overburden
aquifer or bedrock aquifer systems. Contamination in the
bedrock aquifer has been detected at low levels beyond the
Site boundaries. Although not presently impacting existing
residential wells, continued migration of contaminants
and/or increased development resulting in increased ground
water demand could result in impacts to down gradient wells
in the future.
Finally, it is reasonable to assume that development could
occur on or near the site following remediation. As men-
tioned previously, source soils will be remediated to
levels that are. protective of human health and the environ-
ment. Under these circumstances, ground water obtained from
aquifers, directly beneath the Site, could be used for
drinking water purposes.
Consistent with the draft Guidance on Remedial Actions for
fflinated Ground Water at Superfund Sites and EPA ' s
Superfund Public Health Evaluation Manual. EPA evaluated a
risk range of 10"* to 10 7 individual lifetime cancer risks
for carcinogens in selecting a risk level for ground water.
Zn selecting the appropriate risk level for the Site and
the rate of restoration, EPA considered the following major
factors:
1. Site and ground water characteristics.
2. Cost, reliability, speed and technical feasibility of
ground water response actions.
3. Anticipated future need for the ground water.
4. Potential for spreading of the contaminant plume.
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62
5. Effectiveness and reliability of institutional
controls.
EPA applied drinking water standards (MCLs) in establishing
the appropriate cleanup level for the Site. As the legally
enforceable standards under the Safe Drinking Water Act,
MCLs determine the level of water quality that is accept-
able for consumption by people who obtain their drinking
water from public water supplies. Cleanup target levels of
5 ppb each for benzene, trichloroethylene, and 1,2-Dichlor-
oethane and a cleanup level of 7 ppb for 1,1-Dichloroethyl-
ene are equivalent to the federal requirements set under
the Safe Drinking Water Act. A standard for Tetrachloroet-
hylene has not been developed, however, it has similar
chemical, physical and toxicological properties as Trichlo-
roethylene and therefore the same cleanup level of 5 ppb
will be used. An incremental lifetime cancer risk of
5.7 x 10~5 associated with exposure to this chemical matrix
in water is considered by EPA to be adequately protective
of public health. EPA anticipates that the area surround-
ing the Site will continue to be developed, thus increasing
the future need of this aquifer.
EPA rejects 10~6 and 10~7 risk levels, due to the tech-
nical and economic infeasibility of remediating ground
water to a level more protective than the incremental
lifetime cancer risk of 5.7 x 10~5.
2. Consistency with Other Environment*"! t^wa •
Federal environmental laws which are applicable or relevant and
appropriate to the recommended source control and management of
migration alternatives at the Keefe Environmental Services Site
are:
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Executive Order 11988 (*Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
Fish and Wildlife Coordination Act
Clean Air Act (CAA)
Occupational Health and Safety Act (OHSA)
State of New Hampshire ARARs are set forth in Appendix D
As specified in the Detailed Analysis of Alternatives Section
and as presented in Table VI-7 and Appendix D, the recommended
alternative is expected to comply with the above laws. The
State of New Hampshire has not identified any ARAR more strin-
gent than those contained in the above Federal ARARs.
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63
3.
On-site soils are acting as a continuous source of volatile
organic contamination for th« ground water. Ground water in
both the overburden and bedrock aquifer systems is primarily
contaminated with VOCs tbat are carcinogens or suspected car-
cinogens. Contaminants in tbe overburden and bedrock aquifers
are migrating away from the Site.
On-site vacuum extraction is an innovative treatment technology
that will provide a permanent solution to the organic contamin-
ation at the Site. Treatment of the contaminated soils in the
unsaturated sone to proposed soil cleanup goals will reduce the
risks posed to human health from ingestion of ground water by
significantly reducing the volume and toxicity of the contamin-
ants. The soil treatment will also reduce the time for the
cleanup of ground water.
Table VI-8 presents a cost comparison of each source control
alternative.
Although Alternative 8C-1 (No Action) and SC-2 (Capping) are
less expensive than Vacuum Extraction, neither alternative
provides for a permanent and significant reduction of volume,
toxicity and mobility of the contaminants. Vacuum Extraction
is 33 percent less costly than 8C-4A (Thermal Stripping) and 49
percent less costly than SC-4B (Soil Washing) while providing
the same level of treatment. In comparison to 8C-7 (Off-Site
Disposal), Vacuum Extraction is 77 percent less expensive. In
addition, Off-Site Disposal does not comply with Section 121(b)
of CERCLA as amended in that off-site transport and disposal of
hazardous substances without treatment should be the least
favored alternative. Cleanup of the contaminated ground water
will be accomplished using the best demonstrated available
technology. The final design of the unit processes will be
determined following completion of the treatability studies
scheduled to be conducted during remedial design.
Treatment of the ground water will permanently and signifi-
cantly reduce the volume, toxicity and mobility of the
volatile organics present. Restoration of the aquifer to a
5.7 x 10~5 risk level will permit the ground water on-site to
be used for drinking water purposes in the future. Further-
more, cleanup of the ground water to the target level will
eliminate the threat posed to public health and the environment
from the future extent of contaminant migration in ground
water.
The selected ground water remediation alternative, on-site air
stripping followed by activated carbon adsorption, is more
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64
FEDERAL REQUIREMENTS
1. Hazardous Waste Regulations
(RCRA Subtitle C, 4O CFR
Part 264)
Closure and Post-Closure
(264.110 - 264.120)
(Subpart G)2
Tanks (264.19O - 264.198)
(Subpart J)2
TABLE VI-7a
FEDERAL ARARs FOR ALTERNATIVE SC-3
REQUIREMENT SYNOPSIS
* These regulations are relevant
and appropriate because they
supply standards for responding
to releases of hazardous wastes
from units analogous to source
areas at the site.
This regulation details the
specific requirements for
closure and post-closure
of hazardous waste
facilities.
This regulation outlines design
requirements for tank systems,
for storing,hazardous waste.
2. Clean Air Act
(42 U.S.C. 7401)
* National Ambient Air Quality
Standards (NAAQS) (4O CFR,
Part 52.1520 - 52.1531)
3. OSHA Requirements
(29 CFR. Parts, 1910, 1926
and 19O4)
Refer to State Implementation
Plan in Appendix D.
Part 191O specifies the 8-hour
time weighted average concen-
tration for various organic
compounds.
Part 1926 specifies the type of
safety equipment and procedures
to be followed during site
remediation.
ACTION TO BE TAKEN TO
ATTAIN ARARs
This alternative is expected
to achieve a clean closure.
However, post-closure
ground water monitoring
may be necessary, and if
so, will comply with
these requirements.
Remedial alternative may
require temporary storage
of contaminated separator
water. Design of temporary
storage facilities will
comply with these require-
ments.
Refer to State Implementa-
tion Plan in Appendix D.
* Proper respiratory gear
will be worn if it is not
possible to maintain the
work atmospheres below
these concentrations.
* All appropriate safety
equipment will be on-site
and procedures will be
followed during ground water
monitoring.
NOTES: *Applicable - *Relevant and Appropriate
* To be considered
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65
FEDERAL REQUIREMENTS
Executive Orders 11988
•(Floodplain Management) and
1199O (Protection of Wetland)2
Fish and Wildlife Coordination
Act (16 USC 661)3
TABLE VI-7a (CONTINUED)
FEDERAL ARARs FOR ALTERNATIVE SC-3
REQUIREMENT SYNOPSIS
* Part 19O4 outlines the record-
keeping and reporting require-
ments for an employer under
OSHA.
* Floodplain Management states
that federal agencies shall
reduce the risk of flood loss;
minimize the impacts of flood
on human safety, health and
welfare and restore and
preserve the natural and
beneficial values served by
floodplains. Protection of
wetlands states that federal
agencies shall minimize the
destruction, loss or degrada-
tion of wetlands and preserve
and enhance the natural and
beneficial values of wetlands.
* This regulation requires that
any federal agency that pro-
poses to modify a body of water
must consult with the U. S.
Fish & Wildlife Service.
ACTION TO BE TAKEN TO
ATTAIN ARARs
' These regulations are
applicable to con-
tractors involved in
in site work.
' Floodplains and wetlands
along the site boundary
are not expected to be
disrupted due to the
remedial action. Control
measures will be taken
to mitigate potential
impacts associated with
erosion, sedimentation
and resuspension of
sediments.
The U.S. Fish & Wildlife
Service and state
agencies have been con-
sulted regarding this
project.
NOTES:
Applicable
Relevant
3 To be considered
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66
FEDERAL REQUIREMENTS
Hazardous Waste Regulations
(RCRA Subtitle C, 4O CFR
Part 264)
0 Ground Mater Protection
(264.90 - 264.1O9)
(Subpart F) and Ground
Water Monitoring
(264.9O - 264.94)2
• Tanks (264.190 - 264.198)
(Supart J)1
2. Safe Drinking Water Act
Maximum Contaminant Levels
(MCLs) (40 CFR 141.11 -
141.16)2
TABLE VI-7b
FEDERAL ARARs FOR ALTERNATIVE MOM-GW3B
REQUIREMENT SYNOPSIS
0 These regulations are relevant
and appropriate because they
supply standards for responding
to releases of hazardous wastes
from units analogous to source
areas at the site.
* These regulations detail the
requirements for a ground water
monitoring program and set
concentration limits for
•hazardous constituents.
* This regulation outlines design
requirements for tank systems
for storing hazardous waste.
* Identifies cleanup levels of
specific chemicals for public
drinking water supplies based
on human health effects and
levels achievable by technology.
0 These regulations are relevant
and appropriate because the
ground Mater at the site may
be used as a potential drinking
water source.
ACTION TO BE TAKEN TO
ATTAIN ARARs
A ground water monitoring
program will be installed
to ensure cleanup goals are
attained in compliance with
Part 264 requirements.
The Remedial Alternative will
require design of temporary
storage of chemicals utilized
in the ground water treatment
facility and of contaminated
ground water in equalization
tanks at the beginning of the
treatment process which will
comply with these regulations.
RI activities identified the
presence of chemicals in the
ground water for which MCLs
are listed. These were in-
corporated into the site risk
assessment. This alternative
provides treatment to levels
equal to or less than MCLs.
NOTES:
Applicable
2 Relevant
- 3 To be considered
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67
FEDERAL REQUIREMENTS
Safe Drinking Mater Act
Maximum Contaminant Level
Goals (MCLGs) (4O CFR) '
141.50 - 141.51)2
TABLE 7b (CONTINUED)
FEDERAL ARARs FOR ALTERNATIVE MOM-GW3B
REQUIREMENT SYNOPSIS
* Identifies cleanup level goals
of specific chemicals for
public drinking water supplies
based on human health effects
ACTION TO BE TAKEN TO
ATTAIN ARARs
RI activities identified the
presence of chemicals in the
ground water for which MCLGs
are listed. These were
incorporated into the site
risk assessment.
4. Health Advisories, EPA Office
of Drinking Water3
* MCLGs, formerly known as RMCLs,
are not ARARs for this site
because EPA has determined that
MCLs are fully protective of
human health and the environment.
Although an MCL for one of the
indicator compounds, tetra-
chloroethylene, has not been
developed, it has similar chemical,
physical and toxicological pro-
perties as Trichloroethylene for
which an MCL of 5 ppb has been
developed. Therefore, the same
MCL will be used for Tetrachloro-
ethylene.
* Identifies toxicology infoi— *
mation regarding certain
chemicals which is used for
the site risk assessment.
RI activities identified
the presence of chemicals
for which health advisories
are listed. These were
incorporated into the site
risk assessment.
NOTES:
Applicable
2 Relevant
.To be considered
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68
FEDERAL REQUIREMENTS
TABLE 7b (CONTINUED)
FEDERAL ARARs FOR ALTERNATIVE MOM-GM3B
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO
ATTAIN ARARs
5.
Clean Mater Act (Section 304)
Federal Water Quality Criteria
(FWQC)2
6.
Underground Injection Control
Regulations (4O CFR 144, 145,
146 and 147)3
Title III of the CWA sets
forth standards for direct
discharge of pollutants to
the waters of the United
States. These standards are
not applicable because the
proposed facility will not
have a direct discharge. They
are, however, relevant and
appropriate because the
effluent from the ground water
treatment facility will combine
with the existing ground water
regime which eventually discharges
to the wetland adjoining the site.
This regulation outlines injection
permit requirements. -These regu-
lations would be relevant and
appropriate only if seepage pits
or equivalent are used as they
are analogous to underground
injection wells.
The proposed ground water
treatment facility will
meet or exceed all
established ambient Water
Quality Criteria.
If underground seepage
pits or equivalent are
utilized, then this
Regulation will be
complied with.
7. Clean Water Act (Section 3O3)
* State Water Quality Standards
See State ARARs in
Appendix D.
See State ARARs in
Appendix D.
NOTES:
Applicable
Relevant
To be considered
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69
FEDERAL REQUIREMENTS
TABLE 7b (CONTINUED)
FEDERAL ARARs FOR ALTERNATIVE MOM-GW38
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO
ATTAIN ARARs
8.
OSHA Requirements (29 CFR,
Parts 191O, 1926 and 19O4)i
9.
EPA's Ground Water Protection
Strategy*
Part 191O specifies the
8-hour time weighted
average concentration for
various organic compounds.
' Part 1926 specifies the
type of safety equipment
and procedures to be
followed during site
remediation.
" Part 19O4 outlines the
recordkeeping and report-
ing requirements for an
employer under OSHA.
' Defines protection policy
for ground water based on
value and vulnerability.
* Proper respiratory equip-
ment will be worn if it is
not possible to maintain the
work atmospheres below these
concentrations.
* All appropriate safety
equipment will be on-site
and procedures will be
followed during ground
water monitoring.
* These regulations are
applicable to contractors
involved in site work.
* The aquifer in the vicinity
of the site will be pro-
tected pursuant to this
strategy.
NOTES:
Applicable
Relevant
To be considered
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70
TABLE VI-8
SOURCE CONTROL COST COMPARISON
Alternative
SC-1 $
No Action
SC-2 2
Capping
SC-3A 1
Vacuum
Extraction
SC-4A 3
Lt. Thermal
Stripping
SC-48 6
Soil Mashing
SC-7 18
Off-Site
Disposal
Present
Capital
Cost
178,200
,182,400
,138,300
, 905 , 000
, 705 , OOO
,464,000
Worth Factors
Annual
O&M Cost
$ 41,900
95,700
842,500
1,505,550
991,200
11,000
2 Years
5 Years
30 Years
Treati
Period
30
30
5
2
2
2
- 1 . 736
- 3,791
- 9,427
Total
Present
Worth Costs
$ 573,000
3,084,900
4,332,200
6,519,000
8,425,700
18,483,300
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71
costly than air stripping alone. However, air stripping alone
will not attain the target cleanup goals for drinking water
quality. The alternative that requires shipment off-site of
contaminated ground water for treatment is much more costly,
does not provide greater public health protection and is of
questionable implementability.
In contrast, the no-action alternative is not an appropriate
remedy. First, such a remedy would be unreliable and not
effective in terms of protecting human health considering
future uses of the Site. Second, such a remedy does not comply
with applicable or relevant and appropriate requirements.
Finally, the no-action alternative does not meet the strong
statutory preference for remedies that employ treatment to
reduce toxicity, volume or mobility of contaminants.
Based on information contained in the Administrative Record,
EPA has determined that the selected remedial action is con-
sistent with Section 121 of CERCLA and utilizes treatment which
permanently and significantly reduces the volume, toxicity and
mobility of the hazardous substances at the Site. Further, the
remedial action is protective of human health and the
environment, cost-effective and utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable.
C. State Acceptance
The State of New Hampshire Department of Environmental Services
(NHDES) formerly the Mew Hampshire Water Supply and Pollution
Control Commission (NHWS&PCC) has reviewed the various alterna-
tives and has indicated its support for the selected remedy.
D. Community Acceptance
During the public comment period for the Draft Feasibility
Study and Proposed Plan, a number of comments and concerns were
raised by .the public. These comments and EPA's responses.are
presented in Appendix A - Keefe Environmental Services Respon-
siveness Summary.
I. Conclusion
Based on information available in the Administrative Record and
the evaluation of the alternatives against the statutory re-
quirements of CERCLA, the MCP, and the criteria contained in
O8WER Directive 9355.0-21, EPA has concluded that the selected
remedy is protective of human health, attains all applicable or
relevant and appropriate requirements and is cost-effective.
This remedy also satisfies CERCLA preference for remedies which
employ treatment as their principal element to reduce the
volume, toxicity or mobility of hazardous substances at the
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72
Site.
Although this remedy will require measures to control possible
risks related to its construction and operation, the Agency's
analysis indicates that all of these risks can be satisfac-
torily controlled. Additionally, any short-term risks appear
heavily outweighed by the long-term effectiveness and per-
manence this remedy will provide. The Agency believes this
remedy will result in a permanent solution to protect the
public health and environment resulting from the contamination
of the Site and utilizes alternative treatment technologies to
the maximum extent practicable.
VII. STATE
The state of New Hampshire Department of Environmental Services,
under a cooperative agreement with EPA, is the lead agency for this
Site. The Remedial Investigation, Supplemental Remedial Investiga-
tion and Draft Feasibility Study were prepared under the supervision
of the NHDES. The NHDES has also reviewed the Feasibility Study to
determine if the selected remedy is in compliance with applicable or
relevant and appropriate State environmental laws and regulations.
The State of New Hampshire concurs with the selected remedy for the
Keefe Environmental Services Site. A copy of the declaration of
concurrence is attached as Appendix C. In accordance with §104 of
CERCLA, the State of New Hampshire is responsible for 10 percent of
the cost of the remedial action. In the case of the selected remedy,
the state's share is estimated at $609,000.
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73
Appendix A - Keefe Environmental services Responsiveness
Summary
Appendix B - Administrative Record Index
Appendix c - state Concurrence Letter
Appendix D - State ARARs
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APPENDIX A
KEEFE ENVIRONMENTAL SERVICES RESPONSIVENESS SUMMARY
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EPA WCRK ASSIGNMENT NO. 170-1L06
UNDER EPA comma NO. 68-01-7250
FINAL RESPONSIVENESS SUMMARY
FOR THE
KEEFE Et'fl/IRONMENIAL SERVICES
SUPERFUND SITE
EFPING, NEW HAMPSHIRE
MARCH 1988
NOTICE
The informatics in this document has been funded by the United States
Environmental Protection Agency (U.S. EPA) under REM III OontraOt No. 68-01-
7250 to Ebasco Services, Inc. (Ebasco).
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TABLE OF CONTENTS
PREFACE 1
I. RESPONSIVENESS SUMMARY OVERVIEW 2
A. Alternatives Evaluated in the FS 2
B. EPA's Proposed Plan..... 3
C. Overview of Comments on the Remedial Alternatives 3
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS .. .4
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES TO THESE COMMENTS 5
Part I. Comments from the Public Hearing 6
Part II. Comments from Potentially Responsible Parties 9
A. Risk Assessment Comments 9
B. Validity of Data 10
C. Groundwater Contamination
and Proposed Groundwater Treatment Alternative 11
D. Selection of Remedial Alternative 15
E. Effectiveness of Selected Alternative
and Other Alternatives . 18
Table 1 23
IV. REMAINING CONCERNS 24
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE KEEFE ENVIRONMENTAL SERVICES SITE 25
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The U.S. Environmental Protection Agency (EPA) and the New Hampshire
Deparbnent of Environmental Services (NHCES) recently held a public ocmnent
period for interested parties to cxiiuitail on the draft Feasibility Study (FS),
and Proposed Plan prepared for the Keefe Environmental Services Superfund
site. The draft FS, completed in January 1988, examines and evaluates various
cleanup options, called remedial alternatives, for addressing contamination at
the site. EPA announced its preferred alternatives for the cleanup of the
site in the Proposed Plan issued at the start of the public cuuueiiL period.
The purpose of this Responsiveness Summary is to document EPA responses
to the comments and questions raised during the public eminent period. EPA
will consider all of the comments summarized in this document before selecting
a final remedial alternative for the Keefe site.
This Responsiveness Summary is divided into the following sections:
I. Responsiveness Summary Overview - This section briefly outlines the
proposed remedial alternatives as presented in the draft FS,
including EPA's preferred alternativesas described in the Proposed
Plan, and provides a general overview of public comments on the
alternatives.
II.
III.
Background on Community Involvement and concerns - This section
provides a brief history of the site and of community interests and
ns regarding the Keefe site.
- This section summarizes both
written and oral comments received from the public during the public
comment period and provides EPA responses to them. These comments
are categorized into responses to comments made at the hearing,
responses to comments from the Potentially Responsible Parties
(PRPs).
and
IV.
.2
- This section describes con
during the P**?"**!!*! Design and
to
phase of the cleanup process.
srns that EPA needs
LL Action (RD/RA)
Attachment A - This attachment includes a list of the community relations
activities conducted at the Keefe Environmental Services site by the
State of New Hampshire and EPA during the past five years.
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I. RESPONSIVENESS SCMARY OVERVIEW
A. Alternatives Evaluated in the FS
The draft FS identifies and evaluates nine remedial alternatives that are
judged by EPA to be effective for dealing with contamination at the Keefe
Environmental Services site. The nine remedial alternatives are organized
into two categories: 1) source control alternatives, and 2) management of
migration alternatives.
1. Source Control
The purpose of implementing a source control remedial alternative at the
Keefe site is to address soil contamination, which is considered to be a
source of groundwater contamination. The draft FS for the Keefe Environmental
Services site evaluated the following six source control alternatives:
a. no action (soils)- involves leaving contaminants untreated on site,
and fencing and monitoring the site;
b. capping - involves installing a muti-layer barrier system to keep
precipitation from filtering through the contaminants and
potentially spreading contamination;
c. in-situ treatment (vacuum extraction/activated carbon) - see section
I., B. for description;
d. on-site low temperature thermal stripping - involves excavating
contaminated soil using heated air to remove contaminants in an on-
site facility;
e. soil washing - involves processing excavated soils in solvents to
remove contaminants; and
f. off-site disposal - involves excavating contaminated soil and
disposing of it at an off-site, EPA-apprcved disposal facility.
2. Management of Migration
The FS also evaluated three alternatives to manage the migration of
contaminants by treating contaminated groundwater so that contaminants will
not travel away from the site through the groundwater. These management of
migration alternatives were:
a. no action (qroundwater) - would require no treatment, only long-
term montioring of contamination levels in the groundwater;
b. off-site treatment - involves pumping contaminated water for
transport to an off-site waste facility; and
c. on-site air-stripping - See section I.,B. for description.
2
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B. EPA's Pttyjuud Plan
EPA's preferred alternative for remediation of the site is a combination
of a source control alternative, In-situ Treatment (designated as SC-3 in the
FS) , and a management of migration alternative, On-site Air Stripping
(designated as MM-GW3B in the FS) . In-situ Treatment will involve use of a
vacuum extraction system, installed on the site, that causes air to flow
through contaminated on-site soils, creating a transfer of the contaminants
into the air. The air is collected and passed through activated carbon
columns to remove contaminants. This alternative is called in-situ treatment
because contamination is treated in place without disturbing site soils.
After EPA conducts a pilot study to determine the effectiveness of vacuum
extraction at the Keefe site, this treatment system will operate for
approximately two-to-five years.
On-site Ajr {Ftrjrpirn will entail pumping contaminated groundwater cut of
the ground to an on-site mobile air-stripping unit where air is passed over
the groundwater. The air flow strips the contaminants frcrn the groundwater
and transfers contaminants to the air. The air is passed through columns of
activated carbon to remove the contaminants before the treated water is
discharged to the on-site wetlands. Groundwater is to be be pumped and
treated until the water meets or exceeds EPA standards for drinking water
quality. This is estimated to take five years. '
C. Overview of Public Cements on the Ppmartiai Alternatives
EPA received oral Garments during the public hearing, and written
comments during the 30-day public comment period on the FS and Proposed Plan.
Section III of this document summarizes the comments received and EPA's
responses. For the purposes of this Responsiveness Summary, EPA has addressed
the comments received during the public hearing separately from comments
received from potentially responsible parties (PRPs) . The PRPs include
parties identified by EPA as having generated, transported or disposed of
hazardous material at the site.
The comments received at the public hearing questioned the technical
feasibility of using EPA's selected remedy for source control at the site, and
addressed issues related to the protection of wetlands during site cleanup.
In general, the PRPs questioned the adequacy of EPA's study both of the site
and the risks posed to human health and the environment by the site; and
questioned the appropriateness and cost effectiveness of EPA's proposed
cleanup plan for the site.
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n. BAO33CUND CN OJfUNITY BiTOLVEMENT AND OCNCBNS
Keefe Environmental Services (KES) operated the 7.5 acre site as a
chemical waste storage facility between 1978 and 1981. During its operation
the site consisted of drum storage areas and a waste lagoon with an
approximate capacity of 700,000 gallons. Wastes accepted at the site included
solvents, acids, organic sludges, and caustics. The site is located about two
miles southeast of the center of Epping, New Hamphshire, approximately 1000
feet north of Exeter Road. There are a dozen residences, housing
approximately 30 people, near the site along Exeter Road.
Neighbors' complaints about the odors in the vicinity of the site,
coupled with a town-wide fear of the potential for fire or explosion of
materials handled at the site, prompted the Town of Epping to initiate legal
proceedings against KES in May of 1979. At roughly the same time, the New
Hampshire Bureau of Solid Waste Management and the Division of Public Health
Services ordered KES to correct problems with leaking storage tanks, ruptured
drums, and improperly disposed latex waste. The State issued a second cleanup
order after a preliminary investigation of the site indicated that conditions
at the site presented an imminent human health hazard.
News media coverage of problems at the site during this period was
extensive. Local, State, and Federal officials became actively involved in
seeking to end site operations and speed site cleanup. As more attention was
called to the site, Epping citizens voiced their growing concerns about soil
and groundwater contamination, while in the towns of Brentwood and Exeter,
there was fear that nearby drinking water supplies might be contaminated by
the site.
In 1981, after suffering financial difficulties, KES ceased operations
and declared bankruptcy. Between 1981 and 1984 EPA and the State of New
Hampshire addressed imminent public health and safety hazards posed by the
site. These emergency actions included reducing the level of the waste lagoon
on several occasions to control the threat of overflow. EPA and the New
Hampshire Water Supply and Pollution Control Commission (NHWSPCC) also removed
more than 4,000 drums, four 5,000-gallon above-ground storage tanks and four
10,000-gallon above-ground tanks of hazardous waste.
After these emergency actions were complete, active citizen involvement
at the site waned. EPA reported sparse attendence at a public meeting held in
August 1983 to digfaiag EPA plans to remove the contents of the waste lagoon
for off-site disposal. The residents present at the meeting supported EPA's
proposed remedy for lagoon cleanup.
Between 1983 and 1986, EPA and the State of New Hampshire conducted a
joint RI/FS at the site. This two-phased study defined the nature and extent
of contamination at the Keefe site and identified and evaluated alternatives
to address site contamination. Since the release of the RI/FS in January
1988, the principal citizen concerns expressed about the site have been
related to the effect of site contamination and remediation on wetlands .in the
area, and the impact of groundwater contamination and EPA's remedial action on
plans to develop r.sw drinking water supplies in the future.
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HI. SO9AFY OF GQMHEttFS RECEIVED DURING THE HJHLIC CCfMNT PERIOD AND EPA
RESPONSES TO
EPA and NHEES conducted a formal public concent period on the remedial
alternatives and EPA's Proposed Plan between January 6 and Feburary 17. The
public coonent period was originally scheduled to end on February 3, but was
extended until February 17 at the request of one of the ooranenters. Four
parties submitted concents to EPA during the public ccranent period. Three of
these parties, Interex Corporation, the Keefe Negotiating Committee, and
Continental Recovery Systems, submitted written concents. The New Hampshire
Toxic Hazards Campaign offered oral uaiueiit at the informal public hearing
held on January 20, 1988. A transcript of the public hearing is available to
the public at the information repositories in the public library and Town
Offices in Epping, New Hampshire, and also at EPA Region I headquarters in
Boston, Massachusetts.
This section of the Responsiveness Summary presents a summary of all of
the public Garments offered during the public comment period, and EPA
responses to these concents. Part I of this section contains responses to
oral concents received at the public hearing, and Part II contains responses
to caments received from the Keefe Site Negotiating Concuttee and Interex on
behalf of the potentially responsible parties at the site.
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PART I - COMMENTS FROM THE PUBLIC HEARING
The public hearing for the Keefe site vas held in the Epping Town Hall in
Epping, Nev Hampshire on January 20, 1988. At this hearing, the only
comments submitted for the record were from Martha Bailey, Chairman of the
Nev Hampshire Toxic Hazards Campaign. Belov is a summary of her comments.
Comment 1;
Vacuum extraction is unfeasible for source control because the depth of the
vater table is too close to the surface and because limited clean water is
available to cool the condenser. Therefore, low temperature thermal
stripping is recommended for all contaminated soils. This would permit
treatment of distressed "wetland soils.
EPA.Response;
Although the swampy areas of the sites have a relatively shallow water
table, most of the contaminated areas can feasibly be treated with vacuum
extraction. Vacuum extraction is effective for the contaminants present at
the site, and is significantly less expensive than low temperature thermal
stripping which would require excavation and handling of the contaminated
soils on site. In areas where there is a shallow depth to groundwater it
may be necessary to place vacuum extraction piping horizontally instead of
vertically. This will make the process effective in such shallow areas.
The need for clean water for the condenser does not pose a problem. The
vacuum extraction pilot study will determine whether or not a condenser is
needed for the process, and if needed it can be designed such that the lack
of clean vater will not adversely affect the process.
Although low temperature thermal stripping vould be more suitable for
treating distressed vetlands soils, the volume of such soils is so small
compared to the overall site that it vould not justify incurring the
itional expense of treating all soils with thermal stripping.
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Distressed wetlands soils can be remediated by moving such soils to upland
areas to dry out, applying vacuum extraction and restoring the wetland.
Comment 2;
Air stripping and carbon treatment will not remove all contaminants with
one pass through. We do not approve of discharging partially cleaned water
through the aquifer under the wetlands.
EPA Response:
The selected treatment alternative of air stripping and carbon adsorption
has been proven to be effective in many applications. This treatment
system is ideally suited for the removal of VOC contaminants of concern at
the Keefe site. The degree of treatment required will be determined during
the pilot studies. The volume of carbon may be readily increased to
amounts necessary to provide the required degree of treatment. The water
discharged from the treatment system will meet drinking water standards and
will impose no adverse affects to the aquffer or the wetlands upon
discharge.
Comment 3;
Treated groundwater should be returned up gradient to help flush the VOCs
out of the water table.
EPA Response;
The surficial soils at the Keefe site consist of low permeability tills
with visual evidence of leachate breakout along the slopes. Vertical flow
of treated groundwater into the groundwater cannot be assured. Soil
leaching would require hydraulic heads which may not be possible with
shallow concrete leaching chauffers. Using a mounding model, only 5-6
inches of head could be attainable, given the maximum expected treatment
flows of 5 to 7 jyal. per min. The slow percolation rates associated with
the types Oi. soils found at che Neefe site typically require a large
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leaching area constructed of shallow concrete chambers. Locating a large
enough area on this relatively small site would not be possible given the
areas of contaminated soils, groundvater collection trenches and other
required facilities which must be accommodated.
Although soil flushing would require a minimal capital cost, the duration
of operations would be controlled by the ability of the soils to assimilate
and disperse the treated groundwater. Vith low permeability soils, and
limited site area, the time required for leaching could be considerably
longer than the time required to complete other source control
alternatives.
Comment A:
The wetland usually diminishes in size during the summer months due to
evaporation. This would be the time to treat the stressed soil.
EPA Response;
Based on the response to Comment 1, above, distressed wetland soils can be
remediated in an upland area. This does not need to be done during the
summer (i.e., a period of lov groundvater).
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PART II - COMMENTS FROM POTENTIALLT RESPONSIBLE PARTIES
The comments from PRPs were submitted from the Keefe Site Negotiating
Committee ("Committee") and from Interex Corporation ("Interex"). Since
the nature of the comments from both sets of PRPs were similar, they are
combined in the following section. It is noted, however, which PRP made
each comment in the text of the comment.
A. RISK ASSESSMENT COMMENTS
Comment 5;
(Interex] The risk assessment (RI) was inadequate based on the analysis
performed. In assessing future risks, no fate analysis of contaminants
present were performed; only present contaminant levels were analyzed. Use
of an additivity model for combining risks was not adequately justified and
may not be appropriate. The risk analysis performed by Camp Dresser and
McKee (COM), Contractor to EPA, is unrelated to the development of remedial
alternatives.
EPA Response:
The procedures used by COM are consistent vith EPA guidelines for
performing risk assessments at Superfund sites (EPA PHE manual, October, .
1986). EPA's recommended approach, which was used by COM, is to calculate
and present both best estimates (i.e. "most-probable case") and
conservative upper-bound estimates (i.e. "worst-case") for all exposure
point concentrations. According to EPA's guidelines, fate and transport
analysis is performed, where appropriate, depending upon future site use,
and the potential exposure pathways and receptors that are identified. If
future use of site groundwater is unlikely, yet potential receptors exist
offsite, then modeled or predicted contaminant levels found offsite or at
the site boundary may be more appropriate to use in estimating risks.
However, if future use of site groundwater is possible, as in the* case of
the KES site, then present on-site contaminant le"2.1.s give the most
probable and upper bound estimate of risk. At present, EPA believes that
-------
there is no definitive information concerning future site development in
the administrative record. EPA believes, therefore, that it must
conservatively assume that future development is possible. Because
groundvater contaminant levels onsite may either increase or decrease in
the future, the present contaminant levels provide an accurate estimate of
the future risk to human health.
No single approach has been recommended for multiple chemical exposures.
However, EPA guidelines (Federal Register 51:34014) suggest that in the
absence of available data on chemical mixtures the additivity model is
adequate.
CDM's development of remedial alternatives took into account the baseline
risks developed in the Remedial Investigation (RI) and Applicable or
Relevant and Appropriate Requirements (ARAR's).
B. VALIDITY OF DATA
Comment 6:
[Interex] The RI contains no discussion indicating that the consultant of
the government performed proper Quality Assurance/Quality Control (QA/QC)
procedures either in the field or in the lab. Therefore, the sampling
results are of questionable validity.
EPA Response;
The field sampling program was implemented using proper QA/QC procedures in
that 20X of all samples collected were duplicate samples, field blanks and
trip blank samples. Sampling procedures vere followed as outlined in the
Project Operations Plan for KES site (December, 1985), which included
proper documentation in field log books and chain-of-custody paperwork for
all samples collected.
The laboratory analysis program •.•/.•«.s i;^1 ;.-.: •. sceoruaric* -yith EPA
methods, which includes a standard QA/QC data package of blanks, duplicates
10
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and matrix spikes. Volatile and AB/N organics were analyzed using EPA
Methods 624 and 625, respectively (40 CFR 136, Appendix A; Methods for
Organic Chemical Analysis of Municipal and Industrial Vastevater, October,
1984).
Prior to final reporting of the analytical results, the laboratory data was
subjected to a rigorous validation process by COM. The process involved a
QA/QC review of the data for the following criteria: representativeness,
completeness, accuracy and precision, and correctness. The review by COM
indicated that the analytical data were of good quality. The results
provide a basis for conducting further sampling in the pre-design phase of
this project.
Strict QA/QC requirements for the field screening data have yet to be
established. Accuracy requirements were satisfied since the analytical
instruments were calibrated to known gas standards prior to the field work
by an independent technician.
C. GROUNDUATER CONTAMINATION AND PROPOSED GROUNDUATER TREATMENT
ALTERNATIVE
Comment 7;
[Committee] Grounduater extraction and treatment at the site is
• . . •
appropriate in accordance with the National Contingency Plan (NCP) and the
Superfund Amendments and Reauthorization Act (SARA).
EPA Response;
Comment noted.
Comment 8:
[Committee] It does not appear that the preferred groundwater extraction
technology will significantly reduce concentrations of VOCs detected in
groundwater at CU-5B in the deeper portion of the overburden aquifers. It
11
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is likely that the presently proposed groundvater extraction system vill
have to be modified to complete groundvater cleanup to the required target
levels at CV-5B.
EPA Response;
The design included in the feasibility study is a preliminary design. It
is possible that this design vill be modified during the detailed design
phase to include pumping of certain on-site wells such as well CW-5B. The
trench design has been included to intercept contaminated groundvater in
the upper strata of surficial layer prior to its leaching into the vetland
areas.
Comment 9; • •
(Interex] Evidence of groundvater contamination is confined to the shallov
aquifer and indicates no threat to offsite receptors. It is likely that
bedrock contamination is due to the drilling and installation of bedrock
aquifer monitoring veils.
Action should be taken immediately to close any conduits of contaminants to
the bedrock aquifer, including veil CV-C3. To the extent that any
groundvater remediation is deemed necessary, it should be implemented only
in the overburden aquifer.
EPA Response;
Although the overburden or bedrock aquifer does not currently pose a threat
to any off-site receptors, CERCLA Section 121 requires EPA to consider
"short and long-term potential for adverse health effects from human
exposure." Since there is potential for future human exposure to
groundvater, to comply vith ARARs, the overburden and bedrock aquifers must
be treated although there are no current receptors.
*
While it is possible that the contaminants vhich are present in '•• V. C'T "3
are due to the well installation process, since the veils have been
12
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completed there should no longer be a current conduit of contaminants to
the bedrock. However, since this localized area is contaminated, this veil
vill be pumped and the vater sent to the treatment system. The pumping
flow rate of this veil vill be carefully determined such that a large
dravdovn does not occur further contaminating the bedrock aquifer.
Comment 10;
[Interex] The preferred alternative does not satisfy the requirements of
the Superfund Amendments Reauthorization Act of 1986 (SARA) vith respect to
choice of remedial action. Section 121 requires that the proposed remedy
be based on an analysis of the risks actually presented to human health and
the environment by any contamination at a site. Analysis of the RI/FS
demonstrates that choice of a soil remedy on the basis of the RI would be
arbitrary and capricious.
EPA Response;
t
Section 121 of CERCLA does not require analysis of "the risks actually
presented to human health and the environment." In fact, Section 121
requires EPA to take into account "short and long-term potential for
adverse health effects from human exposure," and "the potential threat to
human health and the environment" associated vith certain remedial action.
Although EPA agrees that additional soil sampling and analysis is required
to verify the extent of contaminated soil, the RI contains sufficient data
on which to conclude that the selected soil remedy is consistent vith
CERCLA and the NCP.
Comment 11i
[Interex] Two groundvater treatment alternatives, MOM-GV3A and MOM-GV3B,
are identical except that MOM-GV3A proposes discharge to the Unnamed
Tributary rather than to the groundvater. MOM-GV3A was rejected fo,r one
reason only, that discharge to the stream vould require a permit,
presumably a NPDES permit. Hovever, CERCLA, the NCP, and EPA Guidance are
13
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clear that on-site remedial activities do not require permits. Therefore,
rejection of this alternative vas incorrect as a matter of lav. Moreover,
if a NPDES or state permit were required, this is not a basis for rejection
of this alternative where there is no indication that there would be any
problem obtaining such a permit.
EPA Response:
The screening out of Alternative MOM-GW3A, Air Stripping/Filtration/Carbon
Absorption (Discharge to Stream) was not based solely on the reason that a
discharge permit would be required. Technical, as well as permitting
considerations formed the basis of favoring Alternative MOM-GV3B (Discharge
to Groundwater) over MOM-GU3A (Discharge to Stream). From a technical
standpoint the pumping of groundvater from the surficial aquifer without
recharge may have adverse effects on wetlands on and adjacent to the site.
It is environmentally better to discharge back to groundwater to maintain
the wetlands as opposed to a direct discharge to the tributary.
Comment 12;
[Interex] The entire RI/FS process and selection of preferred alternatives
was driven by the assumption that residential development would occur on
site. However, that assumption is speculative and is not supported by the
record. On the contrary, the evidence suggests that residential
development is not likely to occur onsite. Since it is entirely
speculative that onsite groundwater will ever be used for drinking water
purposes, and since the RI/FS negates the risk from offsite migration of
contaminated groundwater, EPA should have exercised its discretion under
SARA, Section 121 (b)(l), to select other remedial alternatives that do not
provide for groundwater cleanup to drinking water standard, or should have
considered other, less stringent applicable or relevant and appropriate
groundwater standards.
-------
EPA Response;
The future development of the site for residential development, is
certainly a possibility. The comment from Interex included a letter from
real estate broker Paul Spidle, that states, "Future residential
development.of the Keefe Site cannot be absolutely ruled out ...". Zoning
changes, variances and granting of special permits, are all future
possibilities. Furthermore any type of nonresidential development, whether
commercial, institutional, or industrial will require some type of water
supply for consumption, waste disposal, or process use by the people
employed at or occupying the facilities. Cleanup to drinking water
standards will provide a permanent remedy and allow unrestricted future
development of the site and adjacent areas and comply with EPA's
Groundwater Protection Strategy.
D. SELECTION OF REMEDIAL ALTERNATIVE
Comment 13;
[Committee] The baseline risk assessment performed during the RI concluded
that "insignificant risk" was associated with human exposure to measured
levels of VOCs in soil. Therefore, no soil remediation would be needed for
human health and safety considerations based on analytical soil data
collected during the RI.
EPA Response;
Although the risk assessment indicates that there is no direct risk
associated with dermal contact or inhalation of the soil contaminants,
these contaminants will leach out, due to rainwater infiltration through
the soil, and further contaminate the groundwater. These soils then act as
a source of contamination which must be removed in order to have an
efficient and effective groundwater remediation program.
15
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Comment 14:
[Interex] Soil data collected during the RI indicted concentrations of
VOC's either belov detection limits or significantly lower than
concentrations found in on-site groundvater, and therefore do not show that
the soil is a current source of groundvater contamination. The potential
source control remedies considered have been based solely on the need to
protect potential onsite groundvater users. The five indicator compounds,
used as a surrogate for alleged health risks at the site, are either not
found in the soils, or are found at very lov levels. There is no basis
therefore, for source control remedies. The delineation of contaminated
soil is unsupported by hard analytical data.
EPA Response;
The lack of a large body of high quality soils data has been discussed in
the FS. This fact has necessitated the use of theoretical models as
discussed in the FS to estimate contaminant levels that could be present in
k
the soils at the site. The procedures used to estimate soil contamination
vas based upon established estimating procedures which yielded reasonable
results. (Refer to pages 4-24 through 4-26 of the FS.) Soil cleanup goals
are based on achieving cleanup goals in groundvater belov the site that are
protective of public health and the environment. As discussed in the FS,
additional soil sampling vill be performed during the pre-design stage.
Based on the results of this additional soil sampling, areas vhere
contaminant levels exceed any of the soil cleanup goals vill be subject to
remediation. In areas vhere contaminant concentrations are equal to or
less than all of the soil cleanup goals, no further action vill occur.
Comment 15;
[Committee] Additional soil quality data and re-evaluation of the screened
alternatives for source reduction are needed prior to finalizing the EPA
Record of Decision (ROD). The Keefe site PRPs should be given the
opportunity to reviev the additional data and re-evaluation prior to
finalizing the Record of Decision.
16
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Quantity of
Contaminated
Soils
21,000 c.y.
10,500 c.y.
5,250 c.y.
Duration of
Operations
5 yrs.
2.5 yrs.
15 (DOS.
Estimated Cost
$4,332,200
$2,917,600
$2., 078, 200
Duration of
Operations
2 yrs.
1 yr.
6 mos.
EPA Response;
There is no need for additional soils data prior to finalizing the ROD.
A sensitivity analysis comparing the costs of vacuum extraction vs. low
temperature thermal stripping remedial source control alternatives with
decreasing quantities of contaminated soils is presented below:
Vacuum Extraction Lov Temperature Thermal Stripping
Estimated Cost
$6,519,000
$5,273,700
$4,657,800
See Table 1 for background computations.
The estimated costs shown above have been developed on the premise that
completing clean-up of contaminated soils in as short a time.as possible is
the best and most logical approach to remediate the Keefe site. Equipment
for operations of a six month duration or longer would be of the same size
and require the same input of labor, power and other operations and
maintenance costs, but for shorter durations. If the quantity of soils at
the site requiring treatment were found to be substantially less than 25%
of the presently estimated quantity, vacuum extraction would again be the
preferred recommendation for source control remediation as it is more
conducive to scaling down because vacuum extraction equipment is more
readily available in a vide range of sizes off the shelf as opposed to low
temperature thermal stripping equipment. Regardless of the quantity of
soils requiring treatment, fewer adverse environmental impacts are
associated vith in-situ treatment technologies such as vacuum extraction as
opposed to those technologies requiring excavation, handling, and transport
of contaminated soils.
17
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As indicated in the FS, additional soil sampling will be performed during
the pre-design phase to better define the extent of current soil
contamination. If minimal soil contamination is found, the vacuum
extraction alternative will be scaled dovn to the appropriate level. This
ability to scale dovn is an advantage of vacuum extraction over other
remedial technologies involving significant equipment mobilization and
set-up on site.
E. EFFECTIVENESS OF SELECTED ALTERNATIVE AND OTHER ALTERNATIVES
Comment 16;
[Committee] The technical feasibility of soil vacuum extraction at the
site is questionable. Submergence of the vapor extraction-veils due to
shallov groundvater conditions could minimize the effectiveness of soil
vacuum extraction in two of the four areas proposed for application of this
technology. Moreover, previous field applications of this technology have
not demonstrated the capability for soil cleanup to required target levels
during the proposed period of application.
EPA Response:
Vacuum extraction is a vadose zone treatment process and therefore the
extraction veils cannot be extended into the vater table. Hovever, these
veils would be placed as close as functionally possible to the saturated
zone, if soil target levels are found to be exceeded during further on site
soil sampling activities. There is concern that due to the close proximity
of the vater table, large amounts of vater may be removed by the applied
suction. To avoid this problem, an adequately sized air/vater separator
vill be located betveen the veils and the pump. The extracted vater vill
be "trapped" and either added to the groundvater treatment system or
discharged to an appropriate location. Data obtained by CDH vhile under
contract vith EPA to prepare the report entitled "Field Evaluation of Terra
Vac Corrective Action Technology at a Florida LUST Site" (December 1987)
h?s c-V-"~ »KJS ^v»-ar*o^ —i-tsr to be contaminant free since it has already
been subjected to a form of air stripping. Field sampling and testing of
18
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any extracted groundvater vill be employed to test this assumption. (CDH
is presently involved in operating 3 vapor extraction sites in New York,
Nev Jersey, and California further testing this assumption.) In locations
where there is a shallow vadose zone of approximately two feet or less, it
will be necessary to place vacuum extraction pipes horizontally instead of
vertically. In addition, a temporary impermeable cap over the area of
concern may be justified if wells are placed horizontally. The cap would
serve to minimize the amount of clean ambient air being drawn into the
system. These issues would be addressed in the pre-design phase and pilot
studies. A minimum vadose zone thickness could then be established for
vacuum extraction. Below this minimum thickness the remediation would
become a saturated soil issue which will be treated by the proposed
groundwater extraction and treatment system.
A high water table produces operational problems with any type of soil
treatment system, especially those which require the soils to be heated, as
the heating of water requires input of large amounts energy. In addition,
the excavation and handling of wet, nearly saturated soils is'difficult as
these soils tend to become somewhat fluidic.
In one case conducted by Midwest Water Resources, Inc. of Charlotte,
TM
Michigan, developers of the Vaportech process, the vacuum extraction
technology has demonstrated the capability to remove volatile organics to
below 40 ppb or non-detectable levels.
Comment 17;
[Committee] The cost-effectiveness of soil vacuum extraction at the site
is questionable. Uncertainties regarding the required time for application
and the corresponding uncertainties relative to the present worth of annual
operation and maintenance costs were not addressed in the FS cost
evaluation.
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EPA Response:
If the operation and maintenance (O&M) of this system exceeds the five year
estimated time of implementation then another alternative such as low
temperature thermal stripping or soil flushing may be more cost effective,
therefore, the five year estimate for cleanup is the main focus of this
response. There is always some degree of uncertainty associated vith any
in-situ remedial action. The estimated cleanup time was based upon case
studies and the vacuum extraction experiences of COM.
One particular case study involved the removal of leaked gasoline from a
sand clay soil matrix in central Florida. At the Florida site, after nine
months of operation, soil contaminant levels decreased from thousands of
ppm's to non-detectable levels (<100 ppb). At a site in Nev Jersey, over
500 Ibs of TCE, methylene chloride, vinyl chloride, and Trans 1,2-
Dichloroethane vere removed from two different glacial till stratas in five
weeks of operation. The data from this site indicated that 18,000 yd3 of
contaminated soi'l was decontaminated to less than 40 ppb. Over 400,000 yd3
of soils contaminated vith paint solvents and ketones were successfully
remediated at another site in Ohio. At the Ohio site, over 3700 Ibs of
waste was removed from the soil in 11 weeks of operation.
Comment 18:
[Committee] Natural source reduction and groundwater treatment for a
30-year period would attain both federal and state applicable or relevant
and appropriate public health and environment requirements, and is 2.9
million dollars less than the present worth cost for the EPA-selected
alternative including vacuum extraction.
EPA Response;
Section 121(b) states that "Remedial actions in which treatment which
permanently and significantly reduces the volume, toxicity or mobility of
the hazardous substances, pollutants, ?.nd cr-it?r:ir>ants is a principal
element, are to be preferred over remedial actions not involving such
20
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treatment". In accordance vith OSVER Directive 9355.0-19 costs may be used
to discriminate among treatment alternatives, but not between treatment and
non-treatment alternatives.
Comment 19;
(Committee and Interex] Selection of soil vacuum extraction as the most
cost-effective alternative did not appear to adequately consider the
significant uncertainties regarding the required time for application. If
the required time for application of soil vacuum extraction extends to more
than five years, an alternative source reduction method, such as lov
temperature volatilization or soil flushing, could be more cost-effective.
Cost-effective combination remedies such as soil flushing were ignored
because the analysis of preferred alternatives generally treats so.urce
control and management of migration separately.
EPA Response;
Typical treatment times range from 3 to 6 months based on the cases noted
in EPA response to Comment 15 and the five-year estimate is considered to
be very conservative. Five years was used since there is some uncertainty
associated vith the exact location and volume of soils which need to be
treated. Treatment duration may be close to the five year conservative
estimate if most of the contaminated soils are found to be in the low lying
areas which will most probably be very wet and highly organic. On the
other hand, if most of the contamination is in the sandy till, upgradient
of Veil CV-3A, the treatment times are expected to be less than the five
year estimate. At present there is no reason to believe that vacuum
extraction vill require more than 5 years of operation. Pilot plant
studies during the pre-design stage will help verify the estimated
treatment periods.
21
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In general, the surficial soils at the Keefe site are low permeability
tills. Soils of this type are not conducive to soil flushing. The high
vater table at the Keefe site requires a large portion of the remediation
to be groundvater extraction and treatment.
Refer to the response to Comment 3 on page 7 addressing the soil flushing
alternative.
22
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TAS21
asrrrvnr AWJSIS BKTOCUC) CNHLAHONS
Vacuin Retraction
Annual OSfl Present Worth Total P.V. of Capital Total Present
Quantity Time Costs Cost Factor OSM Costs Costs Worth Costs
21,000 c.y. 5yrs. $842,500 2.791 $3,193,900 $1,138,270 $4,332,170
10,500 c.y. 2.5 yrs. $842,500 2.112 $1,779,360 $1,138,270 $2,917,630
5,250 c.y. 1.25 yrs. $842,500 1.116 $ 939,977 $1,138,270 $2,078,247
Lev Temperature Thermal Stripping
Annual OSfl Present Vorth Total P.V. of Capital Total Present
Quantity Time Costs Cost Factor 05/1 Costs Costs Worth Costs
21,000 c.y. 2 yrs. $1,505,550 1.736 $2,614,000 $3,905,000 $6,519,000
10,500 c.y. 1 yr. $1,505,550 .9091 $1,368,696 $3,905,000 $5,273,696
5,250 c.y. 6mos. $1,505,550 .500 $ 752,775 $3,905,000 $4,657,775
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IV. FDAINDC ONCERS
During the public eminent period, and at the public informational meeting
en the FS held by EPA in Epping en January 6, 1988, local officials and
representatives of the PRPs suggested issues that may continue to be of
concern during the design and implementation of EPA's selected remedy for the
site. These issues and concerns include the following:
(A) Ayftilflft'iTitv of Remprii*i Design Information
Potentially Responsible Parties at the site have asked to have access to
new information about site characteristics and contamination that are gathered
during the pilot study and design of EPA's selected remedial alternative. The
potentially responsible parties would like to review and uunuejil on any new
data collected before EPA implements the remedy.
(B) Oontirpj'vnct Ooord'i nation between the Town of Eppinq and T^PA and/or the New
Deartment of EnvirmmBii*-*^ Serving
Residents and Town officials present at the January 6, 1988 informational
public meeting agvfarf a number of questions about how site remediation will
affect plans for future development in Epping. Town officials in particular
wanted to know whether developing new water supplies concurrently with the
pumping and treating of site groundwater could result in accelerated migration
of contaminants into the water supply. NHEES suggested that the Town of
Epping refer any development plans to the State to address the potential
inpacts of site remediation en proposed development on a case-by-case basis.
Testing of Diii'HJ-tic Wells
Citizens present at the informational meeting on January 6 asked that
residential wells continue, to be tested during the remedial design and
remedial action. NHEES said domestic wells would be sairpled twice annually
throughout the site remediation process.
24
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xrra
Community relations activities conducted at the Keefe Etr/ircnnental Services
Superfund site to data have included:
o Jaruazy 4, 1983 - The Haw Hampshire Water Supply and Pollution
Oontxol Commission (NH6FCC) and EPA held a public BMting to
dlsnnis on-going removal actions and off-site dismal of the lagoon
contents*
o July 29, 1983 - MWSPCC and EPA issued a public notice inviting
public review and cuuamt on the fast-track feasibility study for
remediation of the site lagoon.
o . August 11, 1983 - NWJSPOC and EPA ocnducted a public meeting to
d1sn«s the FS alternatives for lagoon cleanup.
o Decenber 1983 - HWSPCC and EPA released a Carnality Relations Plan
outlining citizen concerns about the site and a program to addiess
those concerns and to keep citizens informed about and involved in
• site activities.
o August 6, 1985 - NHWSPOC and EPA issued a public notice announcing
the availability of the Keefe site Remedial Investigation report.
o August 28, 1985 - NHWSPOC and EPA held a public meeting to present
the results of the draft Rpmprilal Investigation and answer questions
from the public.
o October 28, 1985 - EPA initiated a 30-day public cement period on
the 5.7 million dollar settlement negotiated with the potentially
responsible parties at the site.
o January 6, 1985 - The Hew Hampshire Denial Una it of Environmental
Services (NHCES) and EPA conducted a public meeting to discuss the
draft Feasibility Study for the site, and issued a public notice
announcing the 30-day public uumeut period on the remedial
alternatives in the FS and EPA's Proposed Plan. EPA and NHEES also
issued a fact sheet summarizing the FS alternatives, the Proposed
Plan, and the public oumail
o January 20, 1988 - NHEES and EPA conducted an informal public
hearing on the remedial alternatives evaluated in the FS.
EPA reports, documents, and public information fact sheets related to the site
are available to the public at the information repositories located at the
Epping Town Offices and Epping Public Library.
25
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
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Keefe Environmental Services
NPL Site Administrative Record
Index
As of March 21, 1988
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
«
AMERICAN MANAGEMENT SYSTEMS, INC.
One Kendall Square, Suite 2200 • Cambridge, Massachusetts 02139 • (617)577-9915
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Introduction
This document is the Index to the Administrative Record for the Keefe Environmental
Services National Priorities List (NPL) site. Section I of the Index cites site-specific documents,
and Section n cites guidance documents used by EPA staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region I's Office in Boston,
Massachusetts, and at The Epping Library in Epping, New Hampshire. Questions concerning the
Administrative Record should be addressed to the EPA Region I site manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
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Section I
Site Specific Documents
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Pagel
ADMINISTRATIVE RECORD INDEX
for the
Keefe Environmental Services NPL Site
1.0 Pre-Remedial
1.3 Site Inspection
1. 2 "Potential Hazardous Waste Site - Site Inspection Report" Forms, EPA
Region I (January 29, 1980; January 31,1980).
1.12 Hazard Ranking Package
1. "Mitre Model Scoring of Keefe Environmental Service New Hampshire,"
Ecology and Environment, Inc. (October 23,1981).
1.13 FIT Related Correspondence
1. Letter from EPA Region I to Member of the Public (December 8,1981).
1.18 FIT Technical Direction Documents (TDDs) and Associated Records
1. "Hazardous Waste Site Investigation Section 311 Applicability Study Lagoon,"
Ecology and Environment, Inc. (March 8, 1981).
2. Set of Sampling Results for Cm-Site Monitoring Wells, Off-Site Residential
Wells and Surface Water, Ecology and Environment, Inc. (1979 through 1981 -
2 Copies).
3. "Site Inspection and Proposed Work Plan for Keefe Environmental Services,"
Ecology and Environment, Inc. (March 24, 1982).
2.0 Removal Response
2.1 Correspondence
1. Letter from EPA Region I to Fowler, N. (January 20, 1982).
2. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (March 8, 1982).
3. Letter from EPA Region I to Member of the Public (March 8,1982).
4. Letter from Member of the Public to EPA Region I (March 18,1982).
5. 2 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All March 24, 1982).
6. 7 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All March 31, 1982).
7. Letter from New Hampshire Water Supply and Pollution Control Commission
to Member of the Public (April 13,1982).
8. 3 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All June 28, 1982).
9. Letter from New Hampshire Water Supply and Pollution Control Commission
to Member of the Public (July 30, 1982).
10. Letter from Camp Dresser & McKee Inc. to New Hampshire Department of
Health and Welfare, Bureau of Hazardous Waste Management (October 28,
1982).
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Page 2
11. Letter from New Hampshire Department of Health and Welfare, Bureau of
Hazardous Waste Management to Camp Dresser & McKee Inc. (November 5,
1982).
12. 7 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All February 22,1983).
13. Letter from New Hampshire Water Supply and Pollution Control Commission
to Member of the Public (April 14,1983).
14. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Headquarters (May 27,1983).
15. Letter from New Hampshire Water Supply and Pollution Control Commission
to Resource Technology Services, Inc. (June 29,1983).
16. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (July 21,1983).
17. Letter from New Hampshire Water Supply and Pollution Control Commission
to Resource Technology Services, Inc. (August 4,1983).
18. Letter from New Hampshire Water Supply and Pollution Control Commission
to NUS Corporation (February 3,1986).
19. Letter from NUS Corporation to EPA Region I (March 11,1986).
20. Internal EPA Region I Letter (April 25,1986).
21. Letter from Mini Warehousing, Inc. to EPA Region I (May 15, 1986).
22. Letter from NUS Corporation to EPA Region I (June 30,1986).
23. Letter from NUS Corporation to EPA Region I (March 26,1987).
24. 27 Sets of Material Safety Data Sheets Pates Not Available).
25. Set of EPA Region I Meeting Notes, Meeting with the Generators (September
1982).
26. Letter from CECOS International, Inc. to EPA Region I (October 15,1982).
2.2 Removal Action Decision Documents
1. "Field Reports," Recra Research, Inc. (October 8,1979).
2. "Waste Characterization of the Samples Taken from Keefe Environmental
Services," Recra Research, Inc. (October 8, 1979).
3. 2 Sets of Data Summaries, Recra Research Inc. (October 8,1979; October 11.
1979).
4. Emergency Action Plan, EPA Region I (June 1981).
5. "Assessment of Alternatives for Temporary Stabilization of a Lagoon
Containing Hazardous Wastes Located Near Epping, New Hampshire,"
Ecology and Environment, Inc. (January 13,1982).
6. "Justification Document for Lagoon Contents Removal and Decommissioning."
Tighc & Bond (July 29,1983).
7. "Justification Document for Lagoon Contents Removal and Decommissioning,'
Tighe & Bond (Revised August 31,1983).
8. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (September 8,1983).
9. Internal EPA Region I Letter (November 4,1983).
10. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (June 6,1985).
11. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (June 20,1985).
12. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (August 6, 1985).
13. Trip Report, NUS Corporation (December 6,1985).
14. "Keefe Hazardous Waste Site Safety Plan," EPA Region I (July 1,1982).
15. "Site Specific Annex for Keefe Environmental Services," EPA Region I (July
1982).
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Page 3
2.3 Sampling and Analysis Data
In addition to the entries cited below, there is sampling and analysis data pertaining to
the Removal Response phase which may be viewed, by appointment only, at EPA
Region I, Boston, Massachusetts.
1. Set of Lagoon Sampling Data, New Hampshire Water Supply and Pollution
Control Commission (November 26,1979).
2. Set of Data Report Sheets, EPA Region I (March 5,1981 through April 8,
1981).
3. "Field Observations During Lagoon Sampling at Keefe Environmental
Services," Ecological Analysts, Inc. (July 18,1983 through July 26, 1983).
4. "Results of Analysis of Samples Collected from Keefe Environmental
Services," Ecological Analysts, Inc. (July 25, 1983 through July 26, 1983).
5. "Task 3 Sample Inventory," GCA Corporation (October 21, 1983).
6. "Keefe Environmental Services: Trailer Decontamination Results," NUS
Corporation (July 24, 1986).
7. 2 Sets of Organics Analysis Data Sheets, Ecology and Environment, Inc. (Dates
Not Available).
8. 1 Set of Lab Packing Slips, EPA Region I (Date Not Available).
9. 1 Set of Data Report Sheets, EPA Region I (March 1981).
10. 1 Set of Purgeable Organics Analysis Data, EPA Region I (May 17,1982).
11. "Analytical Results Keefe Environmental Services," CECOS International, Inc.
(November 24, 1982).
2.4 Pollution Reports (POLREPs)
1. 25 Sets of POLREPs, EPA Region I (February 27,1981 through September
24,1982)!
2.6 Work Plans and Progress Reports
1. "Operations Plan," EPA Region I (July 1, 1982).
2. 2 Sets of Environmental Response Team Field Project Reports, EPA
Environmental Response Team (November 2-7,1981; March 29-April 2,
1982).
2.9 Action Memoranda
1. "Procurement Request Rationale," EPA Region I (Date Not Available).
3.0 Remedial Investigation (RI)
3.1 Correspondence
1. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (January 13,1983).
2. Letter from State of New Hampshire Attorney General to EPA Region I (April
4,1983).
3. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (June 30, 1983).
4. Letter from Leggette, Brashears & Graham, Inc. to EPA Regional (November
17,1983).
5. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (February 6, 1984).
6. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (February 27, 1984).
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Page 4
7. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (June 4,1984).
8. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (June 21,1984).
9. Letter from Tighe & Bond to New Hampshire Water Supply and Pollution
Control Commission (July 12,1984).
10. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (October 29,1985).
11. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (January 7,1986).
12. Letter from Camp Dresser & McKee Inc. to EPA Region I (May 21,1986).
13. Letter from Camp Dresser & McKee Inc. to EPA Region I (September 17,
1986).
14. Letter from New Hampshire Water Supply and Pollution Control Commission
to Camp Dresser & McKee Inc. (January 20,1987).
3.2 Sampling and Analysis Data
1. Set of Well Logs, Leggette, Brashears & Graham, Inc. (April 11,1984).
2. Set of Organic Chemical Analyses, New Hampshire Water Supply and Pollution
Control Commission (April 20, 1984).
3. Set of Well Sampling Data, New Hampshire Water Supply and Pollution
Control Commission (September 19,1984 through September 28,1984).
4. Set of Organic Chemical Analyses, New Hampshire Water Supply and Pollution
Control Commission (August 12,1985).
3.4 Interim Deliverables
1. "Remedial Action Master Plan," Camp Dresser & McKee Inc. (October 1,
1982).
2. "Safety Plan for Conducting Field Activities," Ecological Analysts, Inc.
(September 2, 1983).
3. Set of Comments from EPA Region I on the September 2,1983 "Safety Plan
for Conducting Field Activities," (Date of Comments Not Available).
4. "Summary of Existing Data," Camp Dresser & McKee Inc. (October 4, 1985).
5. "Project Operation Plan," Camp Dresser & McKee Inc. (December 6,1985).
6. "Summary of Existing Data," Camp Dresser & McKee Inc. (January 13,1986).
3.6 Remedial Investigation (RI) Reports
1. "Remedial Investigation Report - Volume I," Tighe & Bond (Revised April
1985).
2. "Remedial Investigation Report - Volume II," Tighe & Bond (Revised April
1985).
3. Set of Comments from EPA Region I on the Revised April 1985 "Remedial
Investigation Report" (Date of Comments Not Available).
4. "Draft Supplemental Remedial Investigation Report," Camp Dresser & McKee
Inc. (December 1987).
5. "Draft Appendices (RI)," Camp Dresser & McKee Inc. (December 1987).
6. Set of Comments from Continental Recovery Systems Inc. on the December
1987 "Draft Supplemental Remedial Investigation Report and Draft Feasibility
Study" (Set of Comments Dated January 19,1988).
7. Set of Comments from the PRP Negotiating Committee on the December 1987
"Draft Supplemental Remedial Investigation Report and Draft Feasibility Study"
(Set of Comments Dated February 2,1988).
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8. Set of Comments from Interex Corporation on the December 1987 "Draft
Supplemental Remedial Investigation Report and Draft Feasibility Study" (Set of
Comments Dated February 3,1988).
9. Set of Comments from Interex Corporation on the December 1987 "Draft
Supplemental Remedial Investigation Report and Draft Feasibility Study" (Set of
Comments Dated February 17,1988).
4.0 Feasibility Study (FS)
4.1 Correspondence
1. 4 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All January 29,1986).
2. Letter from New Hampshire Water Supply and Pollution Control Commission
to Member of the Public (March 10,1986).
3. Letter from New Hampshire Water Supply and Pollution Control Commission
to Member of the Public (April 3,1986).
4. 8 Letters from New Hampshire Water Supply and Pollution Control
Commission to Members of the Public (All October 21,1987).
4.2 Sampling and Analysis Data
1. 2 Sets of Sampling Data, New Hampshire Water Supply and Pollution Control
Commission (June 1986 through July 1986; July 1987).
4.6 Feasibility Study (FS) Reports
1. "Draft Feasibility Study," Camp Dresser & McKee Inc. (December 1987).
2. "Draft Appendices (FS)," Camp Dresser & McKee Inc. (December 1987).
4.9 Proposed Plan for Selected Remedial Action
1. "Proposed Plan Keefe Environmental Services," EPA Region I (December 22,
1987).
9.0 State Coordination
9:1 Correspondence
1. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (October 13, 1982).
2. Letter from Camp Dresser & McKee Inc. to EPA Region I (October 22, 1982).
3. Letter from New Hampshire Water Supply and Pollution Control Commission
to Camp Dresser & McKee Inc. (October 29,1982).
4. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (November 8, 1982).
5. Letter from Resource Technology Services, Inc. to New Hampshire Water
Supply and Pollution Control Commission (December 3,1982).
6. Letter from New Hampshire Water Supply and Pollution Control Commission
to Resource Technology Services, Inc. (December 6, 1982).
7. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (December 9, 1982).
8. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (February 9, 1983).
9. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (March 30,1983).
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10. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (May 5,1983).
11. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (May 12,1983).
12. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (May 17,1983).
13. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (May 27,1983).
14. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (August 15,1983).
15. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (September 16,1983).
16. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (October 6,1983).
17. 2 Letters from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (Both October 18,1983).
18. Letter from New Hampshire Water Supply and Pollution Control Commission
to D'Appolonia Waste Management Services (October 21,1983).
19. Letter from New Hampshire Water Supply and Pollution Control Commission
to Resource Technology Services, Inc. (October 21,1983).
20. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (October 25,1983).
21. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (December 1,1983).
22. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (January 24,1984).
23. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (January 30, 1984).
24. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (March 6,1984).
25. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (June 29, 1984).
26. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (July 5, 1984).
27. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (July 9, 1984).
28. Set of EPA Region I Meeting Notes, Meeting with State of New Hampshire
(January 8, 1982).
9.2 Cooperative Agreements
1. "Quality Assurance & Control Program," New Hampshire Water Supply and
Pollution Control Commission (December 7,1981).
9.5 Quarterly Progress Reports
1. 15 Quarterly Progress Reports, New Hampshire Water Supply and Pollution
Control Commission (March 31,1983; June 30, 1983; September 30,1983;
December 31, 1983; March 31, 1984; June 30,1984; September 30,1984;
December 31, 1984; March 31, 1985; June 30, 1985; September 30,1985;
December 31, 1985; March 31, 1986; June 30, 1986; September 30, 1986).
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10.0 Enforcement
10.3 Historical Enforcement Actions
1. Affidavit of Stanczyk, T. (October 12, 1979).
2. Affidavit of Kurz, S., Ph.D. (October 12,1979).
3. Affidavit of Spik, W. (October 12,1979).
4. Petition for Injunctive and Other Relief, Town of Epping vs. Paul A. Keefe,
Keefe Environmental Services, Inc. and Amex, Inc. (December 7,1979).
5. Motion for Temporary Injunction, State of New Hampshire v. Paul A. Keefe,
Keefe Environmental Services, Inc. and Amex, Inc. (February 26, 1980).
6. Master's Report, Town of Epping vs. Paul A. Keefe et al. (April 23,1980).
7. Master's Report, Town of Epping and the State of New Hampshire vs. Paul A.
Keefe, Keefe Environmental Services, Inc., and Amex, Inc. (September 9,
1980).
8. Writ of Attachment and Trustee Process, State of New Hampshire vs. Paul A.
Keefe, Keefe Environmental Services, Inc., and Amex, Inc. (June 5, 1981).
9. Petition for Emergency Relief, Town of Epping v. Paul A. Keefe, K.E.S., Inc.
and Amex, Inc. (March 18, 1981 - 4 Copies).
10. Order on the Motion for Clarification, Town of Epping, et al. vs. Keefe, et al.
(May 25, 1981).
11. Writ of Attachment and Trustee Process, Town of Epping vs. Paul A. Keefe,
K.E.S., Inc, and Amex, Inc. (May 19, 1981).
12. Agreement between the State of New Hampshire and the Davidson Rubber
Division of Ex-Cell-O Corporation (June 11,1981).
13. Letter from Keefe Environmental Services, Inc. to New Hampshire Department
of Health and Welfare, Bureau of Solid Waste Management (April 30, 1980).
14. Internal New Hampshire Department of Health and Welfare, Bureau of Solid
Waste Management Letter (May 22,1980).
15. Letter from New Hampshire Department of Health and Welfare, Bureau of Solid
Waste Management to Keefe Environmental Services, Inc. (June 12, 1980).
16. Internal New Hampshire Water Supply and Pollution Control Commission
Letter (September 9,1980).
17. Letter from State of New Hampshire Attorney General to Robertson, B., Esq.
(December 2, 1980).
18. Letter from New Hampshire Department of Health and Welfare, Bureau of Solid
Waste Management to Rooney, J. (December 18, 1980).
19. Letter from State of New Hampshire Attorney General to Analog Devices, et al.
(Date Not Available).
10.8 Consent Decrees
1. Consent Decree, United States v. Data General Corp., et al. (October 10, 1985).
2. Consent Decree - Appendix C, United States v. Data General Corp., et al.
(October 28,1985).
3. Motion to Stay with Concurrence, Davidson Rubber Company (November 11,
1985).
4. Letter from U.S. Department of Justice, Environmental Enforcement Section to
Settling Parties in United States v. Data General Corp., et al. (November 13,
1985).
5. Notice for Comment Period on Consent Decree, United States v. Data General
Corp., et al. (December 23, 1985).
6. Motion to Amend Complaint, United States v. Data General Corp., et al.
(January 15, 1986).
7. Judgement Entered in Accordance with the Approval of the Parties Consent
Decree, United States v. Data General Corp., et al. (March 19, 1986).
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8. Letter from U.S. Department of Justice, Environmental Enforcement Section to
Counsel for Settling Parties (March 21,1986).
10.9 Pleadings - Directly Related to Trial
1. Complaint, United States of America v. Data General, et al. Pate Not
Available).
11.0 Potentially Responsible Party (PRP)
11.7 PRP Steering Committee Documents
The record cited below may be reviewed, by appointment only, at EPA Region I,
Boston, Massachusetts.
1. "Drum Removal and Disposal from the Keefe Environmental Services Site in
Epping, New Hampshire - Prepared for Keefe Generators Committee,"
Chemical Waste Management, Inc. (November 4,1982).
11.9 PRP-Specific Correspondence
1. Master Notice Letter from EPA Region I '(March 5,1982).
2. Master Notice Letter from EPA Region I (August 24,1982).
3. Master Notice Letter from EPA Region I (November 9,1982).
4. Notice Letter from EPA Region I to A.B. Dick Company (October 8,1982).
5. Notice Letter from EPA Region I to Abbot Machine (October 8,1982).
6. Notice Letter from EPA Region I to Allied Resin Corporation (August 24,
1982).
7. Notice Letter from EPA Region I to Aluminum Processing Corporation (January
16,1985).
8. Notice Letter from EPA Region I to American Hoist Crosby - Laughlin
(November 9, 1982).
9. Notice Letter from EPA Region I to Amstar Corporation (August 24,1982).
10. Notice Letter from EPA Region I to Analog Devices (October 8,1982).
11. Notice Letter from EPA Region I to Applied Circuits (September 2,1982).
12. Notice Letter from EPA Region I to ATC Petroleum, Inc. (October 8,1982).
13. Notice Letter from EPA Region I to Atkins and Merrill, Luminescent Systems,
Inc. (August 24,1982).
14. Notice Letter from EPA Region I to Atlantic Laminates, Oak Materials Group,
Inc. (August 24, 1982).
15. Notice Letter from EPA Region I to Bacon Inc. (November 9,1982).
16. Notice Letter from EPA Region I to Bay Head Products Corp. (October 8,
1982).
17. Notice Letter from EPA Region I to Beede Waste Oil Corporation (August 24,
1982).
18. Notice Letter from EPA Region I to Ben-Mont Corporation (November 9,
1982).
19. Notice Letter from EPA Region I to Bendix Corp. (October 8,1982).
20. Notice Letter from EPA Region I to Bergen-Paterson Corporation (November 9,
1982).
21. Notice Letter from EPA Region I to Bixby, J. (October 8, 1982).
22. Notice Letter from EPA Region I to Blue Ribbon Sports (August 24, 1982).
23. Notice Letter from EPA Region I to Borden Chemical (October 8,1'982).
24. Notice Letter from EPA Region I to Brian Construction (October 8,1982).
25. Notice Letter from EPA Region I to Brown, D. (November 9, 1982).
26. Notice Letter from EPA Region I to Brown (Young) (November 9,1982).
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27. Notice Letter from EPA Region I to Brunswick Naval Air Station (November 9,
1982).
28. Notice Letter from EPA Region I to C.L. Hauthaway & Sons Corporation
(January 19, 1985).
29. Notice Letter from EPA Region I to Cado Fabrication Inc. (September 2,1982).
30. Notice Letter from EPA Region I to Cannons Engineering (August 24,1982).
31. Notice Letter from EPA Region I to Central Screw (August 24, 1982).
32. Notice Letter from EPA Region I to Bonan Footwear (October 8,1982).
33. Notice Letter from EPA Region I to Chelsea School Systems (October 8,1982).
34. Notice Letter from EPA Region I to Chem Lab (August 24,1982).
35. Notice Letter from EPA Region I to Chemclean (November 9,1982).
36. Notice Letter from EPA Region I to Chemical Pollution Control (November 9,
1982).
37. Notice Letter from EPA Region I to Clarostat Manufacturing Co., Inc. (August
24, 1982).
38. Notice Letter from EPA Region I to Clemson Automotive Fabrics (October 8,
1982).
39. Notice Letter from EPA Region I to Chapman Manufacturing Company
(January 16, 1985).
40. Notice Letter from EPA Region I to Coastal Metal Finishing, Inc. (August 24,
1982).
41. Notice Letter from EPA Region I to Concord Litho Company (November 9,
1982).
42. Notice Letter from EPA Region I to Courier Citizen Company (August 24,
1982).
43. Notice Letter from EPA Region I to Data General (August 24,1982).
44. Notice Letter from EPA Region \ to Davidson Rubber Division (August 24,
1982).
45. Notice Letter from EPA Region I to D.F. Harris Company (November 9,
1982).
46. Notice Letter from EPA Region I to Disogrin Industries Corporation (August
24, 1982).
47. Notice Letter from EPA Region I to Donnelly Manufacturing Company (August
24, 1982).
48. Notice Letter from EPA Region I to Dynamics Research Corp. (October 8,
1982).
49. Notice Letter from EPA Region I to E.P.E. Corp. (October 8, 1982).
50. . Notice Letter from EPA Region I to Electronic Products (October 8,1982).
51. Notice Letter from EPA Region I to Elektrisola Inc. (November 9,1982).
52. Notice Letter from EPA Region I to Environmental Waste Removal, Inc.
(August 24,1982).
53. Notice Letter from EPA Region I to Essex International (August 24,1982).
54. Notice Letter from EPA Region I to Ethan Allen, Inc. (October 8,1982).
55. Notice Letter from EPA Region I to Town of Exeter, NH (November 9, 1982).
56. Notice Letter from EPA Region I to Fowler, S. (March 5, 1982).
57. Notice Letter from EPA Region I to Franklin Pumping Service, Inc. (August
24, 1982).
58. Notice Letter from EPA Region I to G.T.E. Sylvania (September 2,1982).
59. Notice Letter from EPA Region I to Gar Doc, Inc. (August 24, 1982).
60. Notice Letter from EPA Region I to General Electric (October 8, 1982).
61. Notice Letter from EPA Region I to General Tire and Rubber Company (August
24, 1982). ' '
62. Notice Letter from EPA Region I to Geonautics, Inc. (October 8, 1982).
63. Notice Letter from EPA Region I to George B. Bent Company (November 9,
1982).
64. Notice Letter from EPA Region I to Glines & Rhodes, Inc. (January 16, 1985).
65. Notice Letter from EPA Region I to Globe Union, Inc. (August 24, 1982).
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66. Notice Letter from EPA Region I to Great Bay Disposal Services (August 24,
1982).
67. Notice Letter from EPA Region I to Great Falls Products Co. (October 8,
1982).
68. Notice Letter from EPA Region I to Guilford Industries, Inc. (October 8,1982).
69. Notice Letter from EPA Region I to Hadco Printed Circuits (October 8,1982).
70. Notice Letter from EPA Region I to Halcon Research and Development
Corporation (January 16,1985).
71. Notice Letter from EPA Region I to The Hale Company (August 24,1982).
72. Notice Letter from EPA Region I to Halliburton Services (October 8,1982).
73. Notice Letter from EPA Region I to Hart Engineering Company (October 8,
1982).
74. Notice Letter from EPA Region I to Haveg Industries (October 8,1982).
75. Notice Letter from EPA Region I to Hendrix Electronics (October 8,1982).
76. Notice Letter from EPA Region I to Herbertsons, Inc. (October 8,1982).
77. Notice Letter from EPA Region I to Hero Coatings, Inc. (October 8,1982).
78. Notice Letter from EPA Region I to Hitchner Manufacturing Co. (August 24,
1982).
79. Notice Letter from EPA Region I to Industrial Reproductions, Inc. (November
9,1982).
80. Notice Letter from EPA Region I to ITT Semiconductors (September 2,1982).
81. Notice Letter from EPA Region I to Jarvis Cutting Tools (September 2,1982).
82. Notice Letter from EPA Region I to Jewell Electrical Instruments (September 2,
1982).
83. Notice Letter from EPA Region I to The John lafolla Company (October 8,
1982).
84. Notice Letter from EPA Region I to Keefe, P. (March 5,1982).
85. Notice Letter from EPA Region I to Keefe, Mrs. P. (March 5,1982).
86. Notice Letter from EPA Region I to Keefe Environmental Services, Inc. (March
9,1982).
87. Notice Letter from EPA Region I to Keefe Environmental Services, Inc. (March
9, 1982).
88. Notice Letter from EPA Region I to Kingston Steel Drum (August 24,1982).
89. Notice Letter from EPA Region I to Kingston-Warren Corporation (August 24,
1982).
90. Notice Letter from EPA Region I to Labelcraft, Inc. (October 8,1982).
91. Notice Letter from EPA Region I to LePage's Inc. (August 24,1982).
92. Notice Letter from EPA Region I to LePage's Inc. (August 24,1982).
93. Notice Letter from EPA Region I to Lewcott Chemicals and Plastics (August 24,
1982).
94. Notice Letter from EPA Region I to Lewis Chemical Corporation (August 24,
1982).
95. Notice Letter from EPA Region I to Liege Company (October 8,1982).
96. Notice Letter from EPA Region I to Liquid Waste Specialists, Inc. (January 16,
1985).
97. Notice Letter from EPA Region I to Liqwacon Corporation (August 24,1982).
98. Notice Letter from EPA Region I to McCord Division (October 8,1982).
99. Notice Letter from EPA Region I to MacDonald & Watson Waste Oil Co., Inc.
(August 24,1982).
100. Notice Letter from EPA Region I to Maine Coastal Services (August 24,1982).
101. Notice Letter from EPA Region I to Merrimack Coatings (November 9,1982).
102. Notice Letter from EPA Region I to Microfab, Inc. (August 24,«1982).
103. Notice Letter from EPA Region I to Miller Shoe Co. (October 8,1982).
104. Notice Letter from EPA Region I to MMT United Organics (October 8,1982).
105. Notice Letter from EPA Region I to Modem Tool & Die Co., Inc. (October 8,
1982).
106. Notice Letter from EPA Region I to Modutec, Inc. (October 8,1982).
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107. Notice Letter from EPA Region I to Moore Business Forms (October 8,1982).
108. Notice Letter from EPA Region I to Nashua Brass (October 8,1982).
109. Notice Letter from EPA Region I to Nashua Corporation (August 24,1982).
110. Notice Letter from EPA Region I to Nashua Corporation (August 24,1982).
111. Notice Letter from EPA Region I to Nashua Corporation (August 24,1982).
112. Notice Letter from EPA Region I to Northeast Electronics (August 24, 1982).
113. Notice Letter from EPA Region I to Northeast Solvents (October 8,1982).
114. Notice Letter from EPA Region I to Omni Spectra (August 24,1982).
115. Notice Letter from EPA Region I to Onyx Chemical Company (January 16,
1985).
116. Notice Letter from EPA Region I to Oxford Chemical Inc. (November 9,1982).
117. Notice Letter from EPA Region I to Page Belting Company (August 24,1982).
118. Notice Letter from EPA Region I to Palmer Chenard Industries, Inc. (November
9,1982).
119. Notice Letter from EPA Region I to Pease Air Force Base (October 8,1982).
120. Notice Letter from EPA Region I to PTI (August 24, 1982).
121. Notice Letter from EPA Region I to Pine Tree Castings (November 9,1982).
122. Notice Letter from EPA Region I to Polyclad Laminates (August 24,1982).
123. Notice Letter from EPA Region I to Port Poly Company (October 8,1982).
124. Notice Letter from EPA Region I to Portsmouth Naval Shipyard (October 8,
1982).
125. Notice Letter from EPA Region I to Prevue Products (August 24,1982).
126. Notice Letter from EPA Region I to Process Engineering, Inc. (August 24,
1982). . .
127. Notice Letter from EPA Region I to R&R Education (November 9,1982).
128. Notice Letter from EPA Region I to Rapid Processing Co., Inc. (October 8,
-1982).
129. Notice Letter from EPA Region I to Raybestos (August 24,1982).
130. Notice Letter from EPA Region I to RCL Electronics Company (August 24,
1982).
131. Notice Letter from EPA Region I to Resolve (November 9,1982).
132. Notice Letter from EPA Region I to Roymal Coatings (October 8,1982).
133. Notice Letter from EPA Region I to Rumford National Graphics, Inc. (August
24,1982).
134. Notice Letter from EPA Region I to S. & W. Waste (August 24, 1982).
135. Notice Letter from EPA Region I to St. Regis Paper Co. (August 24,1982).
136. Notice Letter from EPA Region I to Sanders Associates, Inc. (August 24,
1982).
137. Notice Letter from EPA Region I to Scott & Williams (September 2, 1982).
138. Notice Letter from EPA Region I to Scott & Williams (September 2,1982).
139. Notice Letter from EPA Region I to Security Heel Corporation (October 8,
1982).
140. Notice Letter from EPA Region I to Seth Thomas (October 8, 1982).
141. Notice Letter from EPA Region I to Shawsheen Rubber Co., Inc. (October 8,
1982).
142. Notice Letter from EPA Region I to Simmonds Precision Products (October 8,
1982).
143. Notice Letter from EPA Region I to Sofarelli Associates (August 24,1982).
144. Notice Letter from EPA Region I to S.R.S. (August 24, 1982).
145. Notice Letter from EPA Region I to Spaulding Fiber Co., Inc. (August 24,
1982).
146. Notice Letter from EPA Region I to Sprague Electric Company (October 8,
1982).
147. Notice Letter from EPA Region I to Spray Maine, Inc. (August 24,1982).
148. Notice Letter from EPA Region I to Strem Chemicals, Inc. (September 2,
1982).
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149. Notice Letter from EPA Region I to Sturm Ruger Company Inc. (October 8,
1982).
150. Notice Letter from EPA Region I to Suffolk Services (August 24,1982).
151. Notice Letter from EPA Region I to Tamposi, S. (October 8,1982).
152. Notice Letter from EPA Region I to Tansitor Electronics, Inc. (October 8,
1982).
153. Notice Letter from EPA Region I to Teradyne Components (August 24,1982).
154. Notice Letter from EPA Region I to Tiara Footwear (August 24,1982).
155. Notice Letter from EPA Region I to TME Corporation (October 8,1982).
156. Notice Letter from EPA Region I to TYCO Laboratories (November 9,1982).
157. Notice Letter from EPA Region I to Union Camp Plastics Corp. (August 24,
1982).
158. Notice Letter from EPA Region I to U.S. Samica Corporation (August 24,
1982).
159. Notice Letter from EPA Region I to Unitrode Corporation (August 24, 1982).
160. Notice Letter from EPA Region I to Varian Associates, Inc. (August 24,1982).
161. Notice Letter from EPA Region I to Velcro USA, Inc. (August 24,1982).
162. Notice Letter from EPA Region I to Vermont Agency of Transportation (October
8, 1982).
163. Notice Letter from EPA Region I to Vermont Research Corporation (November
9,1982).
164. Notice Letter from EPA Region I to W.R. Grace (October 8,1982).
165. Notice Letter from EPA Region I to Western Electric Company, Inc. (August
24,1982).
166. Notice Letter from EPA Region I to Western Electric Company, Inc. (August
24,1982).
167. Notice Letter from EPA Region I to Western Electric Company, Inc. (August
24,1982).
168. Notice Letter from EPA Region I to Weyerhauser Company (August 24,1982).
169. Notice Letter from EPA Region I to Wrentham Steel Products (January 16,
1985).
170. Letter from EPA Region I to Unitrode Corporation (December 31,1987).
171. Letter from EPA Region I to Varian Associates (December 31,1987).
172. Letter from EPA Region I to Jarvis Cutting Tools (December 31,1987).
173. Letter from EPA Region I to DiversiTech General, Inc. (December 31, 1987).
174. Letter from EPA Region I to Process Engineering (December 31,1987).
175. Letter from EPA Region I to Sturm Ruger Company Inc. (December 31,1987).
176. Letter from EPA Region I to Essex Group, Inc. (December 31,1987).
177. Letter from EPA Region I to Abbott Machine Co., Inc. (December 31,1987).
178. Letter from EPA Region I to Bacon Industries, Inc. (December 31,1987).
179. Letter from EPA Region I to Browning-Ferris Industries (December 31,1987).
180. Letter from EPA Region I to Hart Engineering Company (December 31,1987).
181. Letter from EPA Region I to Simmonds Precision Products (December 31,
1987).
182. Letter from EPA Region I to Port Poly Company (December 31,1987).
183. Letter from EPA Region I to Bixby International Group (December 31,1987).
184. Letter from EPA Region I to Northeast Solvents Reclamation Corp. (December
31,1987).
185. Letter from EPA Region I to E.P.E. Corp. (December 31,1987).
186. Letter from EPA Region I to Amstar Corporation (December 31,1987).
187. Letter from EPA Region I to Teradyne Connection Systems, Inc. (December 31,
1987).
188. Letter from EPA Region I to Town of Exeter, NH (December 31,1987).
189. Letter from EPA Region I to Hadco Printed Circuits (December 31,1987).
190. Letter from EPA Region I to Strem Chemicals, Inc. (December 31, 1987).
191. Letter from EPA Region I to Hale Company (December 31,1987).
192. Letter from EPA Region I to ITT Semiconductors (December 31,1987).
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193. Letter from EPA Region I to United Federal Savings and Loan Association
(December 31,1987).
194. Letter from EPA Region I to Northern Telecom (December 31,1987).
195. Letter from EPA Region I to American Hoist Crosby Group (December 31,
1987).
196. Letter from EPA Region I to Raymark Industries (December 31,1987).
197. Letter from EPA Region I to Coastal Metal Finishing, Inc. (December 31,
1987).
198. Letter from EPA Region I to Cado Fabrications Inc. (December 31,1987).
199. Letter from EPA Region I to Larsen, R., Esq. (December 31,1987).
200. Letter from EPA Region I to Glines & Rhodes, Inc. (December 31,1987).
201. Letter from EPA Region I to Beebe Rubber Company (December 31,1987).
202. Letter from EPA Region I to ISOREG Corp. (December 31,1987).
203. Letter from EPA Region I to Rath, T., Esq. (December 31,1987).
204. Letter from EPA Region I to Lewcott Chemicals and Plastics (December 31,
1987).
205. Letter from EPA Region I to Herman, K., Esq. (December 31,1987).
206. Letter from EPA Region I to Clemson Automotive Fabrics (December 31,
1987).
207. Letter from EPA Region I to Univex Corporation (December 31,1987).
208. Letter from EPA Region I to Oxford Chemical Inc. (December 31,1987).
209. Letter from EPA Region I to Chemical Pollution Control (December 31,1987).
210. Letter from EPA Region I to Wrentham Steel Products, Inc. (December 31,
1987).
211. Letter from EPA Region I to Kewanee Industries, Inc. (December 31,1987).
212. Letter from EPA Region I to CMC Liquidating Company, Inc. (December 31,
1987).
213. Letter from EPA Region I to S. & W. Waste (December 31, 1987).
214. Letter from EPA Region I to C.L. Hauthaway & Sons Corporation (December
31,1987).
215. Letter from EPA Region I to Hart Engineering Company (December 31,1987).
216. Letter from EPA Region I to Aluminum Processing Corporation (December 31,
1987).
217. Letter from EPA Region I to Graf, J., Esq. (December 31,1987).
218. Letter from EPA Region I to Nelson, R., Esq. (December 31, 1987).
219. Letter from EPA Region I to Dunn, C., Esq. (December 31,1987).
220. Letter from EPA Region I to Vermont Agency of Transportation (December 31,
1987).
221. Letter from EPA Region I to Johnson Controls, Inc. (December 31,1987).
222. Letter from EPA Region I to U.S. Samica (December 31, 1987).
223. Letter from EPA Region I to New Hampshire Ball Bearings, Inc. (December
31,1987).
224. Letter from EPA Region I to Electronic Products, Inc. (December 31,1987).
225. Letter from EPA Region I to General Electric (December 31,1987).
226. Letter from EPA Region I to Vermont Research Corporation (December 31,
1987).
227. Letter from EPA Region I to Ex-Cell-O (December 31,1987).
228. Letter from EPA Region I to Nashua Corporation (December 31,1987).
229. Letter from EPA Region I to Courier Corporation (December 31,1987).
230. Letter from EPA Region I to AT&T Technologies, Inc. (December 31, 1987).
231. Letter from EPA Region I to Microdot Inc. (December 31,1987).
232. Letter from EPA Region I to Melville Corporation (December 31,1987).
233. Letter from EPA Region I to Bath Iron Works Corporation (December 31,
1987).
234. Letter from EPA Region I to Chelsea School Systems (December 31,1987).
235. Letter from EPA Region I to U.S. Air Force (January 5, 1988).
236. Letter from EPA Region I to U.S. Navy (January 5,1988).
-------
Page 14
13.0 Community Relations
13.1 Correspondence
1. Letter from New Hampshire Water Supply and Pollution Control Commission
to EPA Region I (February 7,1984).
2. Letter from EPA Region I to New Hampshire Water Supply and Pollution
Control Commission (February 8,1984).
13.3 News Clippings/Press Releases
1. 92 News Dippings from the Following Newspapers:
Atlantic News & Advertiser - Hampton, NH
Boston Sunday Globe - Boston, MA
Brattleboro Reformer - Brattleboro, VT
Burlington Free Press - Burlington, VT
Caledonian Record - St Johnsbury, VT
Carroll County Independent - Center Ossippee, NH
Concord Monitor - Concord, NH
Daily News - Newburyport, NH
The Evening Bulletin - Providence, RI
Exeter Newsletter - Exeter, NH
Foster's Daily Democrat - Dover, NH
Haverhill Gazette - Haverhill, MA
Journal Bulletin - Providence, RI
Keenc Sentinel - Keene, NH
Nashua Telegraph - Nashua, NH
New Britain Herald - New Britain, CT
New Hampshire Sunday News - Manchester, NH
New Hampshire Times - Concord, NH
Newport Daily Express - Newport, VT
Portland Press Herald - Portland, ME
Portsmouth Herald - Portsmouth, NH
The Providence Sunday Journal - Providence, RI
Raymond Times - Exeter, NH
Transcript - Dover, NH
The Union Leader - Manchester, NH
2. Press Release Issued by EPA Region I (February 14,1984 - 2 Copies).
3. Press Release Issued by EPA Region I (July 15,1985).
4. Press Release Issued by EPA Region I (October 28,1985).
5. Press Release Issued by State of New Hampshire, Department of Environmental
Services (December 28,1987).
6. Press Release Issued by EPA Region I (Date Not Available).
13.4 Public Meetings
1. Set of Meeting Notes, Public Meeting (August 11,1983).
2. Attendance List, Public Meeting (August 11,1983).
3. Meeting Agenda, Public Meeting (August 28,1985).
4. Attendance List, Public Meeting (August 28,1985).
5. Meeting Agenda, Town Meeting (June 10,1982).
-------
Page 15
13.5 Fact Sheets
1. 3 New Hampshire Water Supply and Pollution Control Commission Fact Sheets
(April 22,1982; January 16, 1984 - 2 Copies).
14.0 Congressional Inquiries/Hearings
14.1 Correspondence
1. Letter from a Member of the U.S. Senate to EPA. Headquarters (February 26,
1981).
2. Letter from the State of New Hampshire, Office of the Governor to EPA
Region I (March 5,1981).
3. Letter from a Member of the U.S. Senate to EPA Region I (November 9, 1981).
4. 2 Letters from EPA Region I to a Member of the U.S. Senate (December 29,
1981; September 29, 1982).
5. Letter from a Member of the U.S. House of Representatives to EPA Region I
(May 6, 1985).
6. Letter from EPA Region I to a Member of the U.S. House of Representatives
(September 6, 1985).
15.0 Freedom of Information Act (FOIA) Management
15.1 Correspondence
1. Letter from New Hampshire Water Supply and Pollution Control Commission
to International Paper Box Machine Company (October 27,1986).
152 Requests
1. Letter from Curtis Mallet-Prevost, Colt & Mosle to EPA Region I (September
14, 1982).
2. Letter from The General Tire & Rubber Company to EPA Region I (October 5,
1982).
3. Letter from Testa, Hurwitz & Thibeault to EPA Region I (January 17, 1983).
4. Letter from Devine, Millimet, Stahl & Branch to EPA Region I (January 28,
1983).
5. Letter from Moran, J., Esq. to EPA Region I (February 3, 1983 - 3 Copies).
6. Letter from Pretzel & Stouffer to EPA Region I (September 29,1986).
15.3 Responses
1. Letter from EPA Region I to Curtis, Mallet-Prevost, Colt & Mosle (October 8,
1982).
2. 2 Letters from EPA Region I to Moran, J., Esq. (February 25, 1983; March 1,
1983).
3. 2 Letters from EPA Region I to Devine, Millimet, Stahl & Branch (March 14,
1983; March 22, 1983).
4. Letter from EPA Region I to General Electric Company (October 18,1983).
5. Letter from EPA Region I to Davis, Polk and Wardwell (December 17,1985).
6. Letter from EPA Region I to Warren, Goldberg, Berman & Lubitz (December
17, 1985).
7. Letter from EPA Region I to Montgomery, McCracken, Walker & Rhoads
(December 17, 1985).
8. Letter from EPA Region I to McCoy & Associates (January 27,1986).
9. Letter from EPA Region I to Hotchkiss, Robert A. (March 19,1986).
10. Letter from EPA Region I to American Petroleum Institute (April 21,1986).
-------
Page 16
11. Letter from EPA Region I to Gaston Snow & Ely Bartlett (July 24,1986).
12. Letter from EPA Region I to Pretzel & Stouffer (October 8,1986).
13. Letter from EPA Region I to International Technology Corporation (December
8,1986).
14. Letter from EPA Region I to Aetna Insurance Company (August 18,1987).
16.0 Natural Resource Trustee
16.1 Correspondence
1. Letter from EPA Region I to U.S. Department of the Interior (December 17,
1982).
2. 2 Letters from U.S. Department of the Interior to EPA Region I (January 18,
1983; July 21,1987).
16.4 Trustee Notification Form and Selection Guide
1. Letter from EPA Region I to U.S. Department of the Interior (April 16, 1987).
2. "Trustee Notification Form and Selection Guide," EPA Region I (April 16,
1987).
17.0 Site Management Records
17.1 Correspondence
1. Letter from Town of Epping, NH to EPA Region I (March 15,1982).
17.4 Site Photographs/Maps
1. 10 Photographs of the Keefe Environmental Services Site (Dates Not
Available).
17.7 Reference Documents
1. "Compatibility Field Testing Procedures for Unidentified Hazardous Wastes,"
EPA Environmental Response Team (Date Not Available).
-------
Section II
Guidance Documents
-------
Page 17
GUIDANCE DOCUMENTS
General EPA Guidance Documents
1. Memorandum from Gene Lucero to EPA (August 28,1985) (discussing community relations
at Superfund Enforcement sites).'
2. Memorandum from J. Winston Porter to Addressees ("Regional Administrators, Regions I-X;
Regional Counsel, Regions I-X; Director, Waste Management Division, Regions I, IV, V, Vn,
and VUJ; Director, Emergency and Remedial Response Division, Region II; Director,
Hazardous Waste Management Division, Regions in and VI; director, Toxics and Waste
Management Division, Region DC; Director, Hazardous Waste Division, Region X;
Environmental Services Division Directors, Region I, VI, and VTI") (July 9,1987) (discussing
interim guidance on compliance with applicable or relevant and appropriate requirements).
3. Guidance on Remedial Investigations Under CERCLA. June 1985.
4. Guidance on Feasibility Studies Under CERCLA. June 1985.
5. Community Relations in Superfund: A Handbook (interim version), September 1983.
6. Interim f|in'd/"pe on Superfund Selection of Remedy. December 24,1986, OSWER Directive
Number 9355.0-19, J. Winston Porter AA/OSWER.
7. Additional Interim Guidance for Fiscal Year 1987 Record of Decisions. July 24,1987, J.
Winston Porter AA/OSWER.
8. J^raft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites.
October 1986, OSWER Directive Number 9283.1-2.
9. Groundwater Protection Strategy. August 1984, Office of Groundwater Protection, EPA
Washington D.C.
10. Superfund Public Health Evaluation Manual. October 1986, OSWER Directive Number
9285.4-1.
11. Letter from Lee M. Thomas to James J. Florio, Chairman, Subcommittee on Consumer
Protection and Competitiveness, Committee on Energy and Commerce, House of
Representatives (May 21,1987) (discussing EPA's implementation of the Superfund
Amendments and Reauthorization Act of 1986).
12. Comprehensive Environmental Response. Compensation, and Liability Act of 1980. amended
October 17,1986.
13. National Oil and HazardftMs Substances Pollution Contingency Plan. 40 C.F.R. Part 300,
(1985).
14. Superfund Federal-Lead Remedial Project Management Handbook. December 1986,
EPA/540/G-87/001.
-------
APPENDIX C
STATE CONCURRENCE LETTER
-------
State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
WATER SUPPLY & POLLUTION CONTROL DIVISION
6 Hazen Drive, P.O. Box 95, Concord, NH 03301
603-271-3504
ALDEN H. HOWARD
COMMISSIONER
RUSSELL A. NYLANDER. RE.
CHIEF ENGINEER
COUNCIL
JOHN F. BRIDGES. Chuman
MICHAEL G LITTLE. VKC Churnuifc
JOHN C COLLINS P.E.
ALLEN F CRABTREE III
JOHNE DABtLIEWICZ
Fl'SSELL Dl'MAIS
RICHARD M.FLVNX
WILBUR F UPAGE
JAMES J. PAGE
WAYNE L PATENAl DE
JAMES VAROTSIS
WILLIAM T WALLACE. M.U.. M.P.H.
March 18, 1988
Mr. Merrill Hohman
Waste Management Division
U.S. Environmental Protection Agency
J.F.K. Federal Building
Boston, MA 02203
Re: Record of Decision
Keefe Environmental Services Site
Epping, NH
Dear Mr. Hohman:
This office has reviewed the above referenced Record of Decision (ROD) and
concurs with the USEPA that the recommended alternative is consistent with the
rules and regulations of applicable or relevant and appropriate state
standards. Furthermore, if the project utilizes the trust fund, the state
will provide a 10 percent match and operational support for the project if
state funds are available.
Very truly yours,
John A. Minichiello, Acting Director
Department of Environmental Services,
Waste Management Division
Alden H. Howard, Commissioner
Department of Environmenatl Services
JAM/AHH/CWB/jw/17388
cc: Michael A. Sills, Ph.D,
Robert Cheney, AGO
P.E.
-------
APPENDIX D
STATE ARARS
-------
I. CONTAMINANT AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Applicable 2
Relevant & Appropriate 2
A. GROUNDWATER:
RSA 149:8,111; X
11.H. Admin. VJs
Ch. 410 -
Protection of
.Groundwater.
Ns 410.05(a) X
Discharges to
Groundwater.
Ms 410.09 X
Groundwater
Discharge
Criteria,
incorporating
by reference
Ws Part 302
(Maximum
Contaminant
Levels [MCL's]
and Suggested
No Adverse
Response
Levels
[SNARLS])
See Appendix A for synopsis of each requirement and discussion of action necessary to
attain ARAR's.
The absence of any symbol in the columns designated "Applicable" or "Relevant and
Appropriate" indicates that, in the circumstances present at this site, the requirement is
>t applicable or relevant and appropriate
-------
I. CONTAMINANT AND^BcATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPE ENVIRONMENTAL SERVICES SITE/ EPPING, NEW HAMPSHIRE1
Applicable Relevant & Appropriate
c. Ws 410.10,
Additional
Groundwater
Criteria.
d. Vis 410.05(e)
Groundwater
Quality
Criteria;
Health-based
qroundw^ter
protection
standards.
e. Ws 410.05(g)
Groundwater
Quality
Criteria;
Nondegradation
of Surface
Water.
-2-
-------
I. CONTAMINANT AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE •
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Applicable Relevant ft Appropriate
B. SURFACE WATER
1. PSA 149:8,1 X
2. Ws Ch. 400, X
P=»rt 437 -
Water Quality
Standards -
Fish Life
3. ws Ch. 400, X
Part 439 -
Antidegradation
Policy.
C. WETLANDS IMPACT
1. RS* 149:8-a, X
Dreding and
Control of
Run-Off; Ws
Ch. 400 Part
415, Dredging
Rules.
2. Fill and X
Dredge in
Wetlands, RSA
Ch. 483-A and
Wt. Ch. 300,
Criteria and
Conditions.
-3-
-------
I. CONTAMINANT AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS. KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Applicable Relevant & Appropriate
D. AIR EMISSIONS
1. RSA Ch. 125-C, X
Air Pollution
Control; N.H.
Adnin. Code
Air Ch. 100
Parts 604 and
605.
7. M.H. »idmin. X
Code Air Parts
604 and 605.
3. Fuqitive Dust X
Eroi ssion
Control N.H.
Admin. Code
Air Part 1002.
E. HISTORIC
PRESERVATION
1. New Hampshire
Historic
Preservation
Act, RSA 227-C.
2. Local Historic
Districts, RSA
31:89-a-31:89-k.
-4-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT ANPTPPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING. NEW HAMPSHIRE1
Requirement
No
Action
SC-1
Capping
SC-2
Vacuum
Extract.
SC-3
Aeration
SC-4A
Soil
Hashing
SC-4B
Off-Site
RCRA
Landfill
SC-7
No Action
HOH-GH1
Removal
w/Onaite
Treatment
MOM-GH3B
Removal
w/Off-Site
Treatment
MOM-GW4
A. HAZARDOUS WASTE
REQUIREMENTS
1* RSA Ch « 147—A» vvvv vvv v v
New Hampshire x X X X XXX XX
Hazardous
Waste
Management
Act; N.H.
Admin. Code
He-P Ch. 1905.
a. Hazardous YYVY vvv v v
Waste Facility A x x x xxx xx
Security
requirements, •
He-P
1905.08(4),
incorporating
by reference
40 C.F.R.
S264.14.
b. General vvvv vvv v v
Inspection x x x x XXX XX
Requirements,
He-P
1905.08(d)(4)(d)
KEY; X - Applicable
Y - Relevant and Appropriate
The absence of any symbol in the column below a designated alternative indicates that the requirement
is not applicable* or relevant and appropriate, with regard to the alternative.
-5-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Off-SiteRemovalRemova1
No Vacuum Soil RCRA w/Onsite w/Off-Site
Requirement Action Capping Extract. Aeration Washing Landfill No Action Treatment Treatment
SC-1 SC-2 SC-3 SC-4A SC-4B SC-7 MOM-GW1 MOM-GW3B MOM-GW4
Personnel
Training, He-P
1905.08(d)(4)(e)
incorporating
by reference
40 C.P.R.
S264.16.
Location
standards,
He-P
1905.08(d)(4)(g)
incorporating
by reference
40 C.F.R.
$264.18 and
He-P
I905.08(2)j.
Preparedness
and Prevention
Requirements,
He-P 1905.08
incorporating
by reference
40 C.F.R.
52*64, Subpart
C.
X
-6-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND~APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
~~~~ "". Off-Site Removal Removal
No Vacuum Soil RCRA w/Onsite w/Off-Site
Requirement Action Capping Extract. Aeration Washing Landfill No Action Treatment Treatment
SC-1 SC-2 SC-3 SC-4A SC-4B SC-7 HOM-GH1 MOM-GW3B MOM-GW4
f. Contingency XXXXXXX XX
Plan, He-P
1905.08(d)(4)(i)
incorporating
by reference
40 C.F.R. 264,
Subpart D.
g. Groundwater XXXXXXX XX
Protection,
He-P 1905.08
incorporating
by reference
40 C.F.R. 264,
Subpart F.
h. Closure and XXXXXXX XX
Post-Closure,
He-P
1905.08(d)(4)(k)
incorporating
by reference
40 C.F.R.
S264, Subpart
G.
i. Transfer of XXXXXXX XX
facility, He-P
1905.08(d)(5).
-7-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Requirement
No Vacuum Soil
Action Capping Extract. Aeration Washing
SC-1 SC-2 SC-3 SC-4A SC-4B
Off-Site Removal Removal
RCRA w/Onsite w/Off-Site
Landfill No Action Treatment Treatment
SC-7 MOM-GW 1 MOM-GW3B MOM-GW4
j. Monitoring,
He-P
1905.08(d)(6),
k. Public
Notification
Plan, He-P
1905.08
-------
_
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Requirement
NO
Action
SC-1
Capping
SC-2
Vacuum
Extract.
SC-3
Aeration
SC-4A
Soil
Washing
SC-4B
Off-Site
RCRA
Landfill
SC-7
No Action
MOM-GW1
Removal
w/Onsite
Treatment
MOM-GW3B
Removal
w/off-Site
Treatment
MOM-GW4
o. Additional
Technical
Standards for
Treatment He-P
1905.08(f)(2)
(a).
p. He-P
1905.08(f)(2)(C)
Storage
Standards.
q. Technical
Standards for
Waste Piles,
He-P
1905.08(f MlHd)
incorporating
by reference
40 C.F.R. 264
Subpart L.
r. Technical
Standards for
Use and
Management of
Containers,
He-P
1905.08U )(l)(a)
incorporating
by reference
-9-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Off-SiteRemovalRemoval
No Vacuum Soil RCRA w/Onsite w/Off-Site
Requirement Action Capping Extract. Aeration Washing Landfill No Action Treatment Treatment
SC-1 SC-2 SC-3 SC-4A SC-4B SC-7 MOM-GWl MOM-GW3B MOM-GW4
s. Technical X X XX
Standards for
Tanks, He-P
1905.08(f)(l)(b)
incorporating
by reference
40 C.F.R. 264,
Subpart J.
t. Standards for X X X X XX
Generators,
He-P 1905.06.
u. Manifesting X X XX X X
Requirements
He-P 1905.04.
v. Packaging and X x' X - X XX
Labelling
Requirements,
He-P 1905.05,
incorporating
by reference
N.H. Admin.
Code Saf-C-600
and 40 C.P.R.
SS 172, 173,
17*, and 179.
-10-
-------
II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE1
Requirement
No
Action
SC-1
Capping
SC-2
Vacuum
Extract.
SC-3
Aeration
SC-4A
Soil
Washing
SC-4B
Off-Site
RCRA
Landfill
SC-7
No Action
MOM-GWl
Removal
w/Onsite
Treatment
MOM-GW3B
Removal
w/Off-Site
Treatment
MOM-GW4
B. SOLID WASTE
REQUIREMENTS
1. RSA Ch. 149-M,
New Hampshire
Solid waste
Management
Act; N.H.
Admin. Code
He-P Ch. 1901.
C. ACTION-SPECIFIC
AIR EMISSION
LIMITS
1. N.H. Admin.
Code Air Parts
604 and 605.
2. Fugitive Dust
Emission
Control, N.H.
Admin. Code
Air Part 1002.
x
-11-
-------
" APPENDIX A
I. CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
A. GROUNDWATER:
1. RSA 149:8,111; N.H,
Admin. Code Ws Ch. 410 •
Protection of Ground-
water.
These provisions regulate dis-
charges to groundwater and
provide for groundwater protec-
tion. No substance designated
in Ws Ch. 410, or presenting
a potential threat to health or
the environment pursuant to
Ws 410.05, may be discharged to
groundwater so as to exceed water
quality criteria at or beyond any
compliance boundary, as defined by
Ws 410.04(c) and Ws 410.13(a)(3 ) .
Corrective action may also be
required if groundwater degradation
occurs at any point within an inter-
vention zone, as defined under
Ws 410.13. See Ws 410.14(b)(2 ) .
Site must be remediated to prevent
release of contaminants in violation of
these provisions. See below for dis-
cussion of specific water quality cri-
teria pursuant to Ws Ch. 410.
Ws 410.05(a)
Discharges to
Groundwater
Ws 410.05(a) prohibits discharge
of hazardous waste to ground-
water
Remedial action to eliminate the uncon-
trolled discharge of hazardous waste
constituents, volatile organic
compounds (VOC's), and inorganic
contaminants to the groundwater
acquifer below the site.
-------
CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPE FNVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
A. GROUNDWATER; (Continued)
b.
c.
Ws 410.09 Ground-
water Discharge
Criteria,
incorporating by
reference Ws Part
302 (Maximum
Contaminant Levels
[MCL's] and
Suggested No
Adverse Response
Levels [SNARLS])
V?s 410.10,
Additional Ground-
water Criteria
Ws 410.09 establishes groundwater
discharge criteria which
include the MCLs and
SNARLS adopted by the Water
Supply and Pollution Control
Division and codified at
Ws Part 302, Drinking Water
Regulations. Standards appli-
cable to contaminants found at
at the KES Site include SNARLS for
lifetime exposure to toxic con-
taminants, Ws 302.08(a);
SNARLS for contaminants associated
with cancer risk, Ws 302.08(b); and
MCL's, Ws 302.02, Ws 302.04, and
Ws 302.11.
Remedial action to eliminate discharge
of contaminants, including VOC's and
inorganic contaminants, resulting in
groundwater contamination above State
MCL and SNARL levels.
Ws 410.10 provides that ground-
water shall not be altered so as
to render it unsuitable for
drinking water. Drinking water
standards applicable to- the KES
site pursuant to Ws 410.10
include both state and federal
minimum requirements. See, eg.
federal MCLs for volatile
Remedial action to eliminate discharge
of contaminants rendering groundwater
unsuitable for drinking water.
-2-
-------
CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
A. GROUNDWATER: (Continued)
d.
e.
Ws 410.05(e)
Groundwater
Quality Criteria;
Health-based
groundwater
protection
standards.
Ws 410.05(g)
Groundwater
Quality Criteria;
Nondegradation
of Surface
Water.
organic contaminants, 52 Fed.
Reg. 25,716 (July 8, 1987)(to
be codified at 40 C.F.R.
S141.61U)).
Ws 410.05(e) provides
that groundwater shall
not contain any substance which
the Water Supply and Pollution
Control Division (WSPCD) deter-
mines may be harmful to human
health or the environment. In
determining applicable standards
under Ws 410.05(e), WSPCD refers
to health advisory limits
established by the New Hampshire
Division of Public Health
Services (DPHS).
Ws 410.05(g) provides that
groundwater quality shall not
be degraded such that it results
in a violation of surface water
standards in any surface water
body within or adjacent to the
site, and therefore incorporates
surface water standards set forth
at RSA 149:3 and Ws Ch. 400 Parts
Remedial action to eliminate discharge
of substances which may be harmful to
health or the environment, which may in-
clude substances exceeding the 10~6
cancer risk health advisory limits
established by DPHS.
Remedial action to eliminate any dis-
charge to groundwater resulting in a
violation of surface water quality at
adjacent surface waters, including the
Fresh and Piscassic Rivers. Class A
standards include dissolved
oxygen, coliform and pH limits, see
RSA 149:3,1 and Ws 432.02; limits
on potentially toxic concentrations or
-3-
-------
CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE,
, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
A. GROUNDWATER: (Continued)
431-439. Contaminants migrate
from the KES site to the Piscassic
River and it tributary, the
Fresh River; pursuant to Laws
1961, 40:1, par. Ill the Piscas-
sic River and its tributaries are
Class A surface waters. There-
fore, standards applicable to
the KES site include standards
for the preservation of Class
A waters set forth in RSA 149:3,1
and N.H. Admin. Code Ws 432.01 -
432.16.
combinations of substances, Ws 432.03;
and limits on the discharge cf phenols,
Ws 432.14. Discharge of wastes into
Class A surface waters is prohibited,
and Class A waters are to be maintained
as acceptable for bathing and
for use as water supplies. RSA 149:3,1
B. SURFACE WATER
1. RSA 149:8,1
RSA 149:8 prohibits the disposal
of wastes in such a manner as
will lower the quality of any
surface water below the minimum
requirements of the surface
water classification. Standards
applicable to the KES
site include standards for the
preservation of Class A waters.
See discussion at I,A,-l,e above.
Remedial action to eliminate any dis-
charge to surface waters in or adjacent
to the site which lowers the quality of
any surface water body below the appli-
cable classification requirements.
See discussion at I,A,l,e above.
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CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
B. SURFACE WATER: (Continued)
2. Ws Ch. 400,
Part 437 - Water
Quality Standards
- Fish Life
Ws Ch. 400, Part 437 provides
that state surface waters shall
be free from chemicals or con-
ditions inimical to fish life,
see Ws 437.02, and shall be pre-
potential cold water
Ws 437.01.
served as
fisheries,
Remedial action to eliminate dis-
charge of substances, including VOC's
and inorganic contaminants, which may
cause .conditions inimical to aquatic
life.
3. Ws Ch. 400,
Part 439 - Anti-
degradation
Policy.
C. WETLANDS IMPACT
1. RSA 149:8-a,
Dredging and
Control of
Run-Off; Ws Ch.
400 Part 415,
Dredging Rules.
Ws Ch. 400, Part 439 establishes
the state policy against
degradation of existing water
quality, and requires protec-
tion of in-stream beneficial uses
RSA 149:8-a and Ws. Ch. 400
Part 415 establish criteria
for conducting any activity
in or near state surface waters
which significantly alters ter-
rain or may otherwise adversely
affect water quality, impede
natural runoff or create
unnatural runoff. Activities
Remedial action to ensure that
surface water quality is not
degraded due to discharge of con-
taminants from the site.
Wetlands and surface waters are located
in and adjacent to the site. Remedial
activities on the site must comply with
these criteria for the protection of
state surface waters.
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CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
C. WETLANDS IMPACT: (Continued)
2. Fill and Dredge
in Wetlands, RSA
C'n. 4 8 3-A and
Wt. Ch. 300,
Criteria and
Conditions.
within the scope of these pro-
visions include excavation,
dredginq, and grading of topsoil
in or near wetland areas.
RSA 483-A and Ws Ch. 300 regulate
filling and other activities in
or adjacent to wetlands, and
establish criteria for the
protection of wetlands from
adverse impacts on fish, wild-
life, commerce and public
recreation.
Wetlands are located in and adjacent
the site. Remedial activities on the
site must comply with these wetlands
protection requirements.
AIR EMISSIONS
RS* Ch. 125-C, Air
Pollution Control;
N.H. Admin. Code
Air Ch. 100 Parts
604 and 605.
These provisions establish
standards for the release of
air emissions, including VOC's
and hazardous air pollutants.
Applicable standards include
the most stringent of the follow
ing requirements:
(1) New Source Performance
Standards, 40 C.P.R. (Part 60);
The potential for the release of ,
fugitive dust and the volatilization of
contaminants in soil will require
action to prevent unpermitted air
emissions from the site.
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CONTAMINANT- AND LOCATION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
D. AIR EMISSIONS: (Continued)
HISTORIC PRESERVATION
(2) National Emission Standards
for Hazardous Air Pollutants
(40 C.F.R. Part 161); and
(3) New Hampshire State Imple-
mentation Plan linits. Seo
RSA 125-C:6; Air 101.09 and
Air 606.01.
1. New Hampshire
Preservation Act,
RSA 227-C
2. Local Historic
Districts,
RSA 31:89-a-
31:89-k.
This provision
identification
state historic
properties.
governs the
and protection
resources and
of
This provision authorizes
municipalities to establish
historic districts and to regu-
late construction, alteration,
other activities affecting
historical properties and
districts.
Site activities which affect any
historic property must comply with
the provisions of this statute.
Site activities which affect historic
properties or districts should take
into consideration local historical
preservation provisions.
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
A. HAZARDOUS WASTE REQUIREMENTS
RSA Ch. 147-A,
New Hampshire
Hisardous Waste
Management Act;
M.H. Admin. Code
He-P Ch. 1905.
a. Hazardous Waste
Facility Security
requirements,
He-P 1905.08(d),
incorporating by
reference 40
C.F.R. S264.14.
b. General Inspection
Requirements,
He-P 1905.08(d)(4)
(d), incorpora-
ting by reference
40 C.F.R. S264.15.
c. Personnel Train-
ing, He-P 1905.08
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
d. Location standards,
He-P 1905.08(d)(4)
(g), incorporating
by reference
40 C.F.H. S2R4.18
and He-P 1905.08
(?) j.
e. , Preparedness and
Prevention
Requirements,
He-P 190S.08
(d)(4)(h)
incorporating by
reference 40 C.F.R.
§264, Subpart C.
f. Contingency Plan,
He-P 1905.08(d)(4)
(i), incorporating
by reference
40 C.F.R. 264,
Subpart D.
He-P 1905.08(d)(4)(g) restricts
the siting of hazardous waste
facilities near geological fault
areas and flood plains. He-P
1905.08(2)(j) sets forth the
State procedure for identifying
the boundaries of flood plains.
This provision incorporates
federal RCRA requirenent? for
prevention and response to
releases of hazardous waste.
This provision incorporates
federal RCRA requirements for
contingency plans and emergency
procedures.
The location and design of any hazardous
waste facility must meet the require-
ments of He-P 1905.08(d)(4)(g).
Facility construction and operation must
include provisions for internal communi-
cation, equipment, emergency response
capability, and arrangements with local
emergency response authorities in
accordance with his provision.
The facility would be required to
develop and maintain written contin-
gency plans and emergency procedures
in accordance with this provision.
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II, ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
h.
Groundwater
Protection,
He-P 1905.08
incorporating by
reference
4'i C.F.P. 264,
Subpart F.
Closure and
Post-Closure,
He-P 1905.08
incorporating
by reference
40 C.F.R. S264,
Subpart G.
This provision, which incorpor-
ates federal RCRA standards,
supplements N.H. Admin. Code
Ws Ch. 410 by establishing
additional standards for qround-
water monitoring and appropriate
r
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
i. Transfer of
facility,
He-P 1905.08
j. Monitoring,
He-P 1905.08
k. Public Notifi-
cation Plan,
He-P 1905.08
1. General
environmental
standards, He-P
This provision establishes
requirements for notifying the
Division and future owners or
operators when the facility
is transferred.
These provisions establish
groundwater monitoring require-
ments and authorize the Division
to require other appropriate
environmental monitoring.
This provision authorizes the
Division to require development
of a program to inform the
public of the status of facility
activities. A public notifica-
tion plan is appropriate to
ensure that the public will
receive on-going information as
to the implementation of the
selected remedy and the status
of site closure.
This provision requires
facilities to comply with
specified state and federal
Compliance with this provision would be
required prior to any transfer of
facility ownership or operation.
Operation of the facility would requir
groundwater monitoring; additional moni-
toring, including air emissions testing,
may be necessary to detect releases of
fugitive dust or VOC's during remedial
activities.
A program for regular notification of
the public as to the status of site
remediation should be developed.
Facility operation must comply with
environmental and occupational safety
requirements.
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEPS ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
1905.08(d)(l).
m,
General design
standards, He-P
1905.08(d)(2).
Technical
Standards for
Landfills, He-P
1905.08
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
o. Additional
Technical
Standards for
Treatment
HE-P 1905.08
p. He-P 1905.08(f)
. (2)(c), Storage
Standards.
He-P 1905.08(f)(?)(a)
requires a demonstration
that proposed treatment methods
will meet specified design and
construction requirements.
This provision sets forth
specified design and construction
requrements for facilities which
store hazardous wastes.
Technical
Standards for
Waste Piles,
He-P 1905.08(f)(l)
(d), incorporating
by reference
40 C.F.R. 264
Subpart L.
This provision incorporates
federal RCRA requirements for
waste piles.
A treatment facility must demonstrate
that the technology will be effective,
will include automatic controls to stop
inflow in any continuous flow process,
will control toxic gases or fumes, and
will meet other design requirements of
this provision.
The storage of hazardous wastes and c .-
taninated soils must minimize any danger
to human health or environment, must
include mechanisms to prevent and detect
releases to the environment, and must
otherwise comply with design standards
set forth in this provision.
Waste piles must be operated in
compliance with 40 C.F.R. Subpart L.
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II, ACTION-SPECIFIC
APPLICABLE OR RELEVANT AMD APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
s
t.
u.
Technical Stan-
dards for Use and
Management of
Containers, He-P
1905.08(f)
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ii. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS, KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
v. Packaging and
Labelling
Requirements,
He-P 1905.05,
incorporating by
reference N.H.
Admin. Code
Saf-C-600 and
49 C.F.R. S§
172, 173, 178,
and 179.
B. SOLID WASTE REQUIREMENTS
1. RSA Ch. 149-M, New
Hampshire Solid
Waste Management
Act; N.H. Admin.
Hazardous wastes transported
off-site must be packaged and
labelled in accordance with
New Hampshire Department
of Safety rules and federal
transportation requirements.
These provisions establish
standards applicable to the
treatment, storage, and disposal
of solid waste and the closure of
Code He-P Ch. 1901. solid waste facilities.
C. ACTION-SPECIFIC AIR EMISSION LIMITS
1. N.H. Admin.
Code Air Parts
604 and 605.
These provisions establish
limits for the emission of air
pollutants. See discussion at
Section I,D. above.
The packaging and handling of hazardous
waste must comply with this provision,
including the requirement that contain-
ers of hazardous waste must be clearly
marked, and transport vehicles placarded
prior to transport off-site.
Non-hazardous solid waste onsite must be
managed, stored, treated and disposed of
in accordance with the Solid Waste Man-
agement Act and the rules thereunder.
A hazardous waste facility must comply
with the standards set forth in these
provisions, including limits on the
release of volatile contaminants into
the environment.
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II. ACTION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREMENTS. KEEFE ENVIRONMENTAL SERVICES SITE, EPPING, NEW HAMPSHIRE
STATE REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
2. Puqitive Dust
Emission Control
N.H. Admin. Code
Air Part 1002.
This provision requires
precautions to prevent, abate
and control fugitive dust during
construction and excavation
activities.
Precautions to control fugitive dust
emission are required under this
provision.
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