United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R01 -88/025
June1988
Superfund
Record of Decision
Laurel Park, CT
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30277-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-88/025
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Laurel Park, CT
Remedial Action - Final
Authors)
3. Recipient's Aectsiion No.
5. Re
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
u.
15. Supplementary Note*
1C. Abstract (Umlt: 200 words)
The Laurel Park site is located in the town of Naugatuck, New Haven County,
Connecticut. The landfill, occupying about 19-acres of the 35-acre site, lies entirely
within the drainage basin of the Naugatuck River. Additionally, the landfill is located
on a hill in close proximity to fractured bedrock and bedrock aquifer. It is assumed
that waste disposal actions began in the late 1940s. It was common practice to burn
some of the waste brought to the site. Operational problems at the landfill were
in the early 1960s. Complaints included chemical spills on roads leading to
landfill, large quantities of black acid smoke, odors, and blowing litter. In 1961,
a lawsuit was filed and, in 1964, the owner was ordered to cease burning certain waste
types. Between 1965 and 1966, the Connecticut State Department of Health investigated
reports of contaminated surface water. Construction of a leachate collection system was
completed in 1984. The operators of Laurel Park were ordered in January 1981 to stop
landfilling in an unapproved excavation area. By April 1987, the landfill ceased
receiving wastes. The primary contaminants of concern affecting ground water, soil,
surface water, and sediments include: VOCs, organics, and metals.
The selected remedial action for this site includes: installation of a RCRA cap over
all waste disposal areas; rehabilitation of existing leachate collection system,
(See Attached Sheet)
17. Document Analysis a. Descriptor*
Record of Decision
Laurel Park, CT
First Remedial Action - Final
Contaminated Media: gw, sediments, soil, sw
VOCS
c. COSATI Reid/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
126
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (*-771
(Formerly NTIS-35)
Department of Commerce
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EPVROD/R01-88/025
Laurel Park, CT
First Remedial Action - Final
16. ABSTRACT (continued)
supplemented by a shallow ground water extraction system consisting of a French drain
and/or ground water extraction wells, with discharge and offsite treatment at the
Naugatuck Water Pollution Control Facility (NWPCF); and monitoring of all media. The
estimated present worth cost for this remedial action is $21,706,300 without
pretreatment, or £23,078,200 including pretreatment, if necessary.
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RECORD OF DECISION
Laurel Park, Inc.
Naugatuck, Connecticut
STATEMENT OF PURPOSE
This Decision Document represents the selected remedial action for
the Laurel Park, Inc. Site in the Borough of Naugatuck, CT.
developed in accordance with the Comprehensive 'Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Contingency
Plan, 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 Connecticut has concurred on the selected remedy and
determined, through a detailed evaluation, that the selected
remedy is consistent with Connecticut laws and regulations.
STATEMENT OF BASIS
This decision is based on the administrative record which was
developed in accordance with Section 113(k) of CERCLA and which is
available for public review at the Howard Whittemore Memorial
Library in Naugatuck and the EPA Region I Waste Management
Division Records Center in Boston. The attached index identifies
the items which comprise the administrative record upon which the
selection of the remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Laurel Park, Inc. Site includes both
source control and management of migration (or ground water
control) components to obtain a comprehensive approach for site
remediation.
1. Cap
The objective of the cap (cover) is to reduce infiltration into
the landfill so that 1) the generation of leachate is reduced, and
2) the water table is lowered such that it is below landfill
material. An additional objective is to eliminate direct human
exposure to wastes, contaminated soil, and leachate.
These objectives are expected to be achieved by designing a cap
that complies with the Resource Conservation and Recovery Act
(RCRA) landfill closure regulations.
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Detailed design criteria for the cap will be developed during
remedial design to allow for the use of the most current materials^
and procedures appropriate for the specific conditions at the site
The proposed conceptual cover design, as presented in the FS, will
be a multimedia cap and will include provisions for gas collection
and venting. In addition, a security fence will be erected around
the perimeter of the landfill.
2. Existing Leachate Collection System
A perimeter leachate collection system exists at the landfill.
This system will remain in operation; however, it will be
rehabilitated and may require upgrading during remedial design.
3. Leachate Collection/Ground Water Extraction System
The objectives of the leachate collection/ground water extraction
system are to:
extract leachate not intercepted by the existing
leachate collection system,
extract highly contaminated shallow ground water to the
bottom of the shallow bedrock in the immediate vicinity
of the landfill, and
supplement the cap in depressing the water table.
These objectives are expected to be achieved given the following
design criteria:
installing a French drain and/or extraction wells to the
bottom of the shallow bedrock zone, and
developing the depth and location specifics for the
system during remedial design.
The proposed method for extracting leachate and contaminated
ground water to the bottom of the shallow bedrock will be a
combination of a French drain and ground water extraction wells
where the installation of the French drain is not possible. The
benefits of each of these technologies will be considered in
greater detail during the remedial design, and the actual design
details will be determined and specified at that time.
Leachate collection and ground water extraction are the most
effective means of capturing ground water flow in the highly
fractured shallow bedrock. While contaminant migration is not
limited to this upper, fractured zone, the complex hydrogeology of
the site makes it impossible to ensure complete capture of all
contaminated ground water and leachate migrating from the site or
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to extract contaminated ground water in deep bedrock. It is
therefore impossible to remediate the entire bedrock aquifer.
The mechanism for determining when the ground water extraction
system will be shut off will be determined during design and
implementation. The point at which the system will be shut off
will depend upon when the site specific objectives of the system
are accomplished.
4. Treatment of Leachate and Contaminated Ground Water at the
NWPCF
Leachate and extracted ground water will be discharged into the
municipal sanitary sewer for treatment at the Naugatuck Water
Pollution Control Facility (NWPCF). Discharge of leachate and
contaminated ground water to the sewer will require compliance
with applicable pretreatment regulations mandated in the
pretreatment permit issued by the state.
Leachate and extracted ground water will traverse three distinct
segments: Andrew Avenue, the Rubber Avenue Interceptor, and the
Westside Interceptor. A new sewer line, dedicated to leachate and
extracted ground water, will be constructed along Andrew Avenue
from the landfill to the Rubber Avenue Interceptor. The existing
interceptors will be used to convey the leachate ^ror '..here to the
NWPCF.
The estimated daily leachate and ground water flow from the
landfill is approximately 20,000'gallons. The NWPCF is designed
to treat 10.5 million gallons/day, while the current flow is 5.5
million gallons/day. The NWPCF is required to have an NPDES
permit to discharge to the Naugatuck River and has a history of
compliance with its permit.
Although not required by the State at this time, if required at
any time in the future, pretreatment to a level acceptable for
discharge to the NWPCF will be implemented.
5. Monitoring
Monitoring of environmental media will be conducted for thirty
years to monitor the effectiveness of the remedy, to monitor the
bedrock aquifer relative to the ground water and hydraulic
standards and institutional controls, and to idpntify further
impacts to human health and the environment. Additionally, as
required by CERCLA at sites where any hazardous substances,
pollutants or contaminants remain, a review of the site will occur
every five (5) years.
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DECLARATION
The selected remedy is protective of human health and the
environment, attains federal and state requirements that are
applicable or relevant and appropriate to the remedial action, and
is cost-effective. This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable for this site. However, because the various treatment
technologies for the source material are either impracticable,
involve unacceptable risks to workers and others, are not cost-
effective, or are insufficiently protective, this remedy does not
satisfy the statutory preference for treatment as a principal
element. Treatment of leachate and contaminated ground water will
occur at the NWPCF, and will be the maximum extent to which
treatment is practicable.
Date Michael R. Deland
Regional Administrator
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RECORD OF DECISION SUMMARY
LAUREL PARK, INC. SITE
NAUGATUCK, CT
JUNE 30, 1988
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LAUREL PARK, INC.
TABLE OF CONTENTS
Chapter
I.
II.
III.
IV.
V.
VI.
VII.
VIII,
IX.
X.
XI.
XII.
A.
B.
A.
B.
C.
D.
i
A.
B.
A.
B.
C.
D.
A.
B.
C.
D.
E.
Page Number
SITE NAME, LOCATION, AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Remedial History
Federal Enforcement History ...
COMMUNITY RELATIONS
SCOPE AND ROLE OF RESPONSE ACTION
SITE CHARACTERISTICS
Hydrogeology
Surface Water and Sediment
Landfill
SUMMARY OF SITE RISKS
DOCUMENTATION OF SIGNIFICANT CHANGES
DEVELOPMENT AND SCREENING OF ALTERNATIVES
Statutory Requirements/Response Objectives
Technology and Alternative Development and Screening
DESCRIPTION/SUMMARY OF THE ANALYSIS OF ALTERNATIVES
THE SELECTED REMEDY
Description of the Selected Remedy
Estimated Remedial Schedule
Institutional Controls
Rationale for Selection
STATUTORY DETERMINATIONS
The Selected Remedy is Protective of Human Health
and the Environment
The Selected Remedy Attains ARARs
The Selected Remedy is Cost Effective
The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable ....
The Selected Remedy Does Not Satisfy the Preference
for Treatment as a Principal Element . .
STATE ROLE
1
1
1
3
4
5
6
6
7
7
8
9
10
10
10
11
13
19
19
23
23
24
29
29
29
32
32
33
33
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Laurel Park, Inc.
Record of Decision Summary
ATTACHMENTS
Site Location Map Attachment 1
Endangerment Assessment - Table 2-3 Attachment 2
APPENDICES
Responsiveness Summary Appendix A
Administrative Record Index Appendix B
State Concurrence Letter Appendix C
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ROD DECISION SUMMARY page 1
Laurel Park. Inc.
I. SITE NAME, LOCATION, AND DESCRIPTION
The Laurel Park, Inc. landfill (previously known both as Murtha
Dump and Laurel Park Landfill) is located in the Town of
Naugatuck, a borough of New Haven County, Connecticut. The
landfill is about one mile west of the Naugatuck River and
Connecticut Route 8, and about one mile southwest of downtown
Naugatuck. Naugatuck has an estimated current population of
26,500. (See Attachment 1 - Site Location Map.)
The landfill occupies about 19 acres of the 35 acre site, and is
located prominently on the upper north and west slopes of
Huntington Hill (also known as Hunter's Mountain). Most of the
area immediately bordering the site is forested. About 50 homes
are located within a one-half mile radius of the site, primarily
to the north, east and southeast of the landfill, with the closest
residents located approximately 1,000 feet to the north and
southeast of the site.
Topographic surface features in the Naugatuck area occur in the
form of elongated northwest/southeast trending hills and ridges.
Huntington Hill, upon which the Laurel Park landfill is .located,
is a bedrock supported hill covered by till. Till depths range
from seventy feet on the western flank of Huntington Hill, to zero
on the eastern flank. The landfill is therefore in direct contact
with both till and bedrock.
The landfill lies entirely within the drainage basin of the
Naugatuck River, which flows toward Long Island Sound,
about 23 miles to the south. Surface runoff from the landfill
flows to two tributaries of the Naugatuck River - Spruce Brook and
Long Meadow Pond Brook. Spruce Brook is one-half mile west and
Long Meadow Pond Brook is one mile north of the landfill. Long
Meadow Pond Brook is fed by an unnamed stream which begins at the
base of the landfill.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Remedial History
A more detailed description of the site history and past response
actions are presented in the Remedial Action Master Plan (RAMP)
and the Remedial Investigation (RI) Report.
The date when waste disposal actions began at the site is not
known; however, it is most likely to have occurred in the late
1940's.
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ROD DECISION SUMMARY page 2
Laurel Park. Inc.
During the early years of operation, the common practice was to
burn some of the waste brought to the site. Operational problems
were reported at the landfill in the early 1960's. Problems
complained of included spills of chemicals on roads leading to the
landfill, large quantities of black acrid smoke, odors, and
blowing litter. In 1961 a lawsuit was filed, Lanonette et al. v.
Harold Murtha et al. which alleged in part that the operation of
the waste dumps created a nuisance. Judgment in the case was
handed down in 1964 and the owner was ordered to cease open
burning of certain wastes, except at certain times, and to pay
several thousand dollars in damages. In 1966 Laurel Park, Inc.
was incorporated.
Between 1965 and 1966 the State Department of Health investigated
reports of leachate contaminating surface water, determined that
contamination was occurring, and recommended steps to be taken to
eliminate pollution.
In 1978, the Connecticut Department of Environmental Protection
(CT DEP) issued a vertical expansion permit (No. 088-1) for an
additional 250,000 cubic yards of waste.
On January 28, 1981, CT DEP issued a Cease and Ddsist Order,
ordering the operators of Laurel Park, Inc. to stop landfilling in
an unapproved excavation area.
In February 1981, a preliminary site assessment of the landfill
was submitted to EPA by Ecology and Environment, Inc.
On March 5, 1981, DEP issued Order No. 3003 to Laurel Park, Inc.,
which required that an engineering study be conducted *: determine
the nature and extent of surface and ground water contamination
resulting from the disposal of refuse and waste material at the
Laurel Park landfill, and that such contamination be minimized.
Sullivan and Waldo, Consulting Environmental Engineers, submitted
an engineering report on October 29, 1981 in compliance with that
order. (Fuss & O'Neill, Consulting Engineers, performed the
hydrogeologic studies.)
On October 23, 1981, when EPA published the Interim Priorities
List (IPL) of candidates for response action under CERCLA, Laurel
Park, Inc. was included on that list. In Decetnber 1982, Laurel
Park, Inc. was proposed for the National Priorities List (NPL) (47
FR 58476, December 30, 1982). In September 1983 the site was
listed on the NPL (48 FR 40658, September 8, 1983).
In November 1982, Fred C. Hart Associates, Inc. was retained by
Laurel Park, Inc. to conduct geologic and hydrogeologic studies of.
the landfill. These studies were released in February 1983.
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ROD DECISION SUMMARY page 3
Laurel Park.Inc.
On February 1, 1983, the Connecticut Superior Court in Hartford
issued a judgment ordering Laurel Park, Inc. to take the following
steps as conditions for allowing it to continue disposing of solid
waste:
1. Immediately prepare a proposal for ground water
monitoring and implement the proposal upon approval by
DEP.
2. Install and maintain a leachate collection and treatment
system, upon approval of plans by DEP, by October 31,
1983.
3. Submit to DEP a performance bond covering the cost of
installing and maintaining the leachate system for
five years.
4. Supply potable (i.e., bottled) water to certain
specifically identified neighboring residents.
5. Provide a municipal water system to those residents if
Laurel Park, Inc. applies for and receives permission
for horizontal expansion of the landfill.
On October 13, 1983, DEP issued a Cease and Desist order
prohibiting operation of the landfill based, on the detection of
2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) in samples
collected by the DEP. Further extensive sampling by CT DEP did
not confirm the presence of 2,3,7,8-TCDD. An appeal to the
Superior Court by Laurel Park, Inc. resulted in a temporary
injunction of the state order, which allowed reopening of the
landfill.
Construction of the leachate collection system, which was required
in the February 1983 judgment, was completed in 1984.
CT DEP proposed a monitoring program in April 1984 to be conducted
by Laurel Park, Inc. utilizing the services of Fred C. Hart
Associates. That program consisted of installing and sampling new
monitoring wells, as well as sampling surface water, soils, and
sediments.
On April 16, 1987, Laurel Park, Inc. notified the CT DEP they had
ceased accepting wastes.
B. Federal Enforcement History
In May 1985, Uniroyal, Inc. (now Uniroyal Chemical Company, Inc.)
entered into an administrative consent order with EPA whereby it
agreed to conduct the Remedial Investigation/Feasibility Study
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ROD DECISION SUMMARY page 4
Laurel Park. Inc.
("RI/FS") for the Laurel Park site. Laurel Park, Inc. was also a
party to this order for the sole purpose of providing access
during the RI/FS. The consent order required Uniroyal to perform
all work in conjunction with the RI/FS at the site. The RI and
the Endangenaent Assessment (EA) were prepared by Malcolm Pirnie,
Inc., a consultant for Uniroyal, and released to the public in
February 1987. The Draft FS was released to the public on May 3,
1988 and was also prepared by Malcolm Pirnie.
Two additional orders have been issued regarding the site. First,
on June 16, 1986, EPA issued a unilateral order to Uniroyal and
Laurel Park, Inc. Under this order Uniroyal constructed a fence
around an overflowing manhole connected to the leachate collection
system and the upper 200 feet of the unnamed stream to which
leachate was flowing.
Second, on May 27, 1987, EPA issued an Administrative Consent
Order for construction of a waterline. About 50 residences within
a half mile radius of the landfill have individual water supply
wells. These residents have been provided with bottled water since
1983, initially by the landfill owner as a condition for allowing
it to continue to operate, and since April 1987 by the state. A
permanent alternative water supply is being installed under an
agreement reached by the state, the borough of Naugatuck, and
Uniroyal. The May 1987 Consent Order for the waterline between the
three parties and EPA incorporates that agreement. The waterline
is scheduled to be completed in 1988.
On May 19, 1988, EPA notified approximately 36 parties who either
owned or operated the facility, generated wastes that were shipped
to the facility, arranged for the disposal of wastes at the
facility, or transported wastes to the facility of their potential
liability with respect to the Site. EPA met with these
potentially responsible parties (PRPs) on June 2, 1988, as a
preliminary step toward settlement of the PRPs1 liability at the
Site.
Special notice will not be issued in this case until the remedy
selection process is complete.
III. COMMUNITY RELATIONS
The local community has had an active presence throughout the
history of the site. Two citizens' groups have been involved in
attempts to close and cleanup the landfill. The Pollution
Extermination Group, Inc. (PEG) has been active since 1981,
originally to oppose expansion of the landfill. The Andrew Avenue
Homeowners Association was formed in 1983 over concerns with the i
leachate collection system and methods of leachate disposal.
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ROD DECISION SUMMARY page 5
Laurel Park. Inc.
EPA has kept the community and other interested parties advised of
the Site activities through informational meetings, fact sheets,
press releases and public meetings.
In the summer of 1984 a roundtable meeting was held with EPA, CT
DEP, PEG, Laurel Park, Inc., and Uniroyal.
In June 1985, EPA released the community relations plan for the
Site which outlined a program to address community concerns and
keep citizens informed about and involved in activities during
reir.adial activities. (The community relations plan will be revised
after the ROD is signed.)
On June 6, 1985, EPA held an informational meeting in the town to
describe the plans for the Remedial Investigation and Feasibility
Study.
On November 13, 1985, EPA held an informational public meeting to
discuss the RI progress to date.
On February 26, 1987, EPA held an informational public meeting to
discuss and respond to questions concerning the results of the
Remedial Investigation and the Endangerment Assessment. On May 11,
1988, EPA held an informational public meeting to discuss the
cleanup alternatives presented iri the Feasibility Study and to
present the Agency's Proposed Plan. The Agency also answered
questions from the public during this meeting. From May 12 to
June 9, the Agency held a four week public comment period to
accept comment on the alternatives presented in the Feasibility
Study, the Proposed Plan, and all other documents previously
released to the public. During that comment period, on May 25,
1988, the Agency held a public hearing to accept oral comments. A
transcript of this meeting together with the written comments
received and the Agency's response to these comments, are included
in the Administrative Record. After the ROD is signed EPA will
publish notice of its decision in a local paper.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy was developed by combining components of
different source control technologies and management of migration
(or ground water) technologies to obtain a comprehensive approach
for site remediation. The remedy provides for source control and
management of migration by combining the following components:
capping the landfill in accordance with RCRA; leachate collection;
shallow ground water extraction to the bottom of the
weathered/highly fractured bedrock zone; conveyance of leachate
and extracted ground water by the municipal sewer system for
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ROD DECISION SUMMARY page 6
Inc.
treatment at the Naugatuck Water Pollution Control Facility; and
long-term monitoring.
V. SITE CHARACTERISTICS
Chapter one of the Feasibility Study, and chapter two of the
Endangerment Assessment, contain an overview of the Remedial
Investigation. The significant findings of the Remedial
Investigation are summarized below.
A. Hydrogeology
Hydrogeologic investigations were conducted at the landfill under
the DEP mandated program and during the RI to characterize ground
water flow and contaminant transport. Additionally, an evaluation
of the existing leachate collection system was conducted during the
FS, and completed in January 1988. These studies show that the
landfill is directly underlain by fractured bedrock with the depth
to bedrock varying from zero (0) to approximately seventy (70) feet
below the land surface, around the perimeter of the landfill. In
general, the upper surface of the bedrock is fairly weathered and
fractured, with the depth of this upper fractured zono varying from
approximately one (1) to thirty (30) feet into bedrock. On averag^
the fractured zone is approximately twenty (20) feet. (Throughout^
this document this upper fractured bedrock zone is referred to as
"shallow bedrock".) This zone is underlain by denser bedrock
intermittently fractured by two fracture sets.
Ground water flow through bedrock at the Laurel Park site is
controlled by the orientation and density of fractures. Given
this, the shallow bedrock has been identified as the primary
migration pathway, with the deeper bedrock as the secondary
migration pathway. Ground water flow at the site has been
identified toward the northwest, northeast, and the southeast
In order to quantify and delineate the vertical and horizontal
extent of ground water contamination, monitoring wells were
installed. Wells were installed in the till, the bedrock, and the
fill. In addition, private supply wells located in the bedrock
were also monitored. Contaminants have been detected in both on-
site and off-site wells. Beyond the boundary of the landfill
contaminants are found in the ground water in both the till and
bedrock formations. Contamination is consistently detected in the
shallow fractured bedrock. At greater depth the presence of
contamination is sporadic and does not allow for delineation. This
situation is common for fractured bedrock systems in New England.
Information on contaminant migration to the northwest, northeast,
and southeast is presented in the RI. Contamination migration is
apparent from the landfill in a north-northwesterly direction in
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ROD DECISION SUMMARY page 7
Laurel Park. Inc.
association with the unnamed stream. Contaminant transport to the
northeast is presumed to be along the secondary joint sets.
Contaminants have been found to the southeast and are presumed to
have been transported along the primary fracture set.
Contaminants present included organic and inorganic compounds.
Table 2-3 from the Endangerment Assessment (Attachment 2) lists
the chemicals detected in all media, including ground water. The
frequency of detection versus the total number of samples analyzed
is reported as well as the minimum, maximum and representative
concentrations.
B. Surface Hater and Sediment
The Laurel Park landfill straddles the surface water divide
between the watersheds of Long Meadow Pond Brook and Spruce Brook,
which both flow to the Naugatuck River. Most of the surface
drainage from the landfill flows into the Long Meadow Pond Brook
watershed via the unnamed stream.
Samples of surface water and sediments were collected from the
unnamed stream, Long Meadow Pond Brook, and Spruce Brook.
Surface water contamination is evident near the Laurel Park, Inc.
landfill. The unnamed stream is a receptor of leachate and
surface water runoff from the landfill. Volatile organic
compounds (VOCs) were found in high levels at the site near the
overflowing manhole, as evidenced by benzene concentrations in
excess of 800 ppb. VOCs generally decrease in concentration
downstream from the site due to dilution and volatilization.
Migration of N-nitrosodiphenyl and diethylphthalate in the unnamed
stream can be linked to this site; these compounds are ound in
leachate samples at higher concentrations than detected in surface
water samples downstream. Whether site contaminants are migrating
to Spruce Brook is unclear from the RI data.
C. Leachate and Soils
Leachate, generated by precipitation percolating into the landfill
and contacting wastes, currently enters both the ground water and
surface water flow regimes. Leachate dynamics are somewhat
affected by an existing leachate collection system which Laurel
Park, Inc. constructed in 1984.
The leachate collection has not been connected to the municipal
sewer system, as intended, pending authorization to discharge to
the system. As a result, leachate overflows from one manhole and
enters the unnamed stream.
Leachate is contaminated with a number of organic compounds,
including benzene, toluene, acetone, 2-butanone, N-
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ROD DECISION SUMMARY page 8
Laurel Park. Inc.
Leachate is contaminated with a number of organic compounds,
including benzene, toluene, acetone, 2-butanone, N-
nitrosodiphenylamine, diethylphthalate and phenolic compounds.
Inorganics include the following heavy metals: aluminum, barium,
calcium, cadmium, chromium, copper, iron, lead, magnesium,
manganese, nickel, sodium, and zinc.
Soil investigations were limited to on-site leachate seep areas
and to areas which received runoff from the landfill or runoff
from leachate seeps. Soil contamination from leachate is
evident. Volatile organic compounds such as benzene, toluene and
xylenes, as well as the semi-volatile N-nitrosodiphenylamine are
present at levels consistent with those found in leachate, while
acetone and 2-butanone were detected in one sample at
concentrations an order of magnitude higher than those found in
leachate. Metals detected in on-site soil were generally higher
than those detected in leachate, indicative of the tendency
of metals to adsorb to soils.
D. Landfill
The landfill has an areal extent of approximately 19 acres. The
volume of fill material and contaminated soils is estimated to be
1.3 million cubic yards, with a maximum depth of 120 feet.
Although the landfill was actively receiving waste during the RI,
it is presently covered by a soil cap.
Portions of the landfill are within the water table. The
existing leachate collection system is only partially effective
in capturing leachate.
Preliminary air monitoring indicated the presence of methane in
significant quantities throughout the landfill. Except in the
vicinity of leachate seeps, preliminary monitoring failed to
detect volatilized organics at greater than background levels.
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ROD DECISION SUMMARY page 9
Laurel Park. Inc.
VI. SUMMARY OF SITE RISKS
An Endangerment Assessment (EA) was performed to estimate the
probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated
with the site. The following twelve contaminants of concern were
selected for evaluation in the EA:
Potential Carcinogens Noncarcinoaens
Arsenic Lead
Benzene Toluene
Benzo(a)pyrene
Bis-2-ethylhexyl phthalate
Chloroform
Chromium
1,2-Dichloroethane
Nickel
N-nitrosodiphenylamine
Tetrachloroethylene
These contaminants constitute a representative subset of the more
than fifty contaminants identified at the Site during the Remedial
Investigation. The twelve contaminants were selected to represent
potential onsite hazards based on toxicity, level of
contamination, mobility and persistence in the environment.
Potential human health effects associated with the contaminants of
concern in ground water, surface water, soils, and sediment were
estimated quantitatively through the development of several
hypothetical exposure scenarios. Incremental lifetime cancer
risks and a measure of the potential for noncarcinogenic adverse
health effects were estimated for the various exposure scenarios.
Exposure scenarios were developed to reflect the potential for
exposure to hazardous substances based on the characteristic uses
and location of the site.
A comparison of the estimated risk level for drinking water use to
that associated with showering and bathing indicates that the use
of the ground water as a source of drinking water has the greater
potential for presenting a hazard to health. It should also be
noted that the risk levels developed included conservative
assumptions which tend to overstate the risk, and that risk levels
are of limited value in predicting absolute levels of risk.
Contact with surface water and sediment was determined to
constitute a relatively minor exposure pathway, based upon
containment concentrations and frequency of use.
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Laurel Park. Inc. .
Soil ingestion was also evaluated, specifically habitual soil
consumption by small children. Conservative assumptions were also
incorporated in this evaluation, including five years of daily
access to soil on the property and daily ingestion of 5 grams of
soil. The estimated risk level was determined to be low relative
to that obtained from the analysis of drinking water use of the
ground water.
In conclusion, the consumption of ground water from monitoring.
wells on the property and residential wells in the vicinity of the
site holds the greatest potential for human health hazard and must
be considered in the development of site remediation alternatives.
An endangerment to the environment is the potential degradation of
the bedrock aquifer. The environmental consequences on two
tributaries of the Naugatuck River, Long Meadow Pond Brook and
Spruce Brook, which may be influenced either directly or via the
unnamed stream were evaluated. At this time, water quality
downstream of the landfill appears not to be significantly
affected relative to established water quality criteria.
VII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA published a proposed plan (preferred alternative) for
remediation of the site on May 3, 1988. Since that time, no
significant changes have been made to the selected alternative.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance with
the revised National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300, dated November 20, 1985.
Until the NCP is revised to reflect SARA, the procedures and
standards for responding to releases of hazardous substances,
pollutants and contaminants shall be in accordance with Section
121 of CERCLA and to the maximum extent practicable, the current
NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
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Laurel Park. Inc.
relevant and appropriate environmental standards established under
federal and state environmental laws unless a statutory waiver is
granted; a requirement that EPA select a remedial action that is
cost-effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and a 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. Response
alternatives were developed to be consistent with these
Congressional mandates.
A number of potential exposure pathways were analyzed for risk and
threats to public health and the environment in the Endangerment
Assessment. Guidelines in the Superfund Public Health Evaluation
Manual (EPA, 1986) regarding development of design goals and risk
analyses for remedial alternatives were used to assist EPA in the
development of response actions. As a result of these assessments,
remedial response objectives were developed to mitigate existing
and future threats to public health and the environment. These
response objectives are:
Source Control Measures
1. Preventing or minimizing the further release of contaminants
from the landfill to ground water, surface water, sediments,
soils and air.
2. Eliminating the threats posed to human health and the
environment from the source area itself.
Management of Migration Measures
1. Preventing or minimizing further migration of contaminants in
ground water, surface water, sediments, soils and air.
2. Eliminating or minimizing the threats posed to human health
and the environment from the current extent of contamination.
B. Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents including, "Guidance
on Feasibility Studies Under CERCLA11 dated June 1985, and the
"Interim Guidance on Superfund Selection of Remedy" [EPA Office of
Solid Waste and Emergency Response (OSWER)], Directive No.
9355.0-19 (December 24, 1986), set forth the process by which
remedial actions are evaluated and selected. In accordance with
these requirements and guidance documents, treatment alternatives
were developed for the site ranging from an alternative that, to
the degree possible, would eliminate the need for long-term
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Laurel Park. Inc.
management (including monitoring) at the site to alternatives
involving treatment that would reduce the mobility, toxicity, or
volume of the hazardous substances as their principal element. In
addition to the range of treatment alternatives, a containment
option involving little or no treatment and a no-action
alternative were developed in accordance with Section 121 of
CERCLA.
Section 121(b)(1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other
statutory directives of Section 121, the evaluation and selection
process was guided by the EPA document "Additional Interim
Guidance for FY '87 Records of Decision" dated July 24, 1987.
This document provides direction on the consideration of SARA
cleanup standards and sets forth nine factors that EPA should
consider in its evaluation and selection of remedial actions. The
nine factors are:
1. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2. Long-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume.
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
9. Overall Protection of Human Health and the Environment.
Chapter 2 of the Feasibility Study identified, assessed and
screened technologies based on site and waste-limiting
characteristics, as well as technical reliability and
effectiveness. These technologies were combined to encompass both
source control and management of migration remedial response
objectives. Chapter 2 (Section 2.4) in the Feasibility Study
presented the remedial alternatives, developed by combining the
technologies identified in the previous screening process, in the
categories required by OSWER Directive No. 9355.0-19. The purpose
of the initial screening was to narrow the number of potential
remedial actions for further detailed analysis while preserving a m
range of options. Each alternative was then evaluated and screenecP
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Laurel Park. Inc.
in Chapter 3 of the Feasibility Study based on its effectiveness in
protecting public health. In summary, of the eleven alternatives
screened in Chapter 3, seven were retained for detailed analysis.
IX. DESCRIPTION/SUMMARY OF THE ANALYSIS OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
above. A thorough description and evaluation of each alternative
can be found in Chapter 4 of the Feasibility Study.
Alternative 1
No Action with Monitoring
Estimated Present Worth Cost: $1,712,500
The National Contingency Plan requires that a no action
alternative be developed as a baseline for comparison with other
remedial alternatives. Although no source or ground water
controls will be implemented under this alternative, monitoring
will be conducted for thirty years to track contaminant migration
and to identify further impacts to public health and the
environment. Additionally, as required by CERCLA at sites where
any hazardous substances, pollutants or contaminants remain, a
review of the site will occur every five (5) years.
Potential human health threats are identified in the Endangerment
Assessment and include contact with wastes, contaminated soil and
leachate on site, and contact or ingestion of contaminated water
in the unnamed stream. Environmental threats include further
degradation of the bedrock aquifer, continued degradation of the
unnamed stream and Long Meadow Pond Brook, and volatilization of
contaminants into the air. This alternative will not reduce any
of these risks, and therefore may not be protective of human
health and the environment. Additionally, this alternative does
not comply with most ARARs.
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Laurel Park. Inc.
Alternative 2
Cap, Leachate Collection/Groundwater Extraction, On-Site Treatment
Estimated Present Worth Cost: $24,182,550
This alternative provides for source control by capping according
to the Resource Conservation and Recovery Act (RCRA) regulations,
and for ground water control by collecting leachate and extracting
shallow ground water to the shallow bedrock aquifer. This
alternative also includes on-site treatment of leachate and
contaminated ground water, discharge of the treated water to the-
Naugatuck River, and monitoring.
A cap will be constructed to cover all waste disposal areas. The
existing leachate collection system will be upgraded and remain in
operation, and will be supplemented by a shallow ground water
extraction system consisting of a French drain and/or ground water
extraction wells to the bottom of shallow bedrock.
On-site treatment of leachate and ground water will include the
construction of a treatment plant at the site, and discharge of
the treated water to the Naugatuck River via a dedicated pipe
which would run directly from the site to the river, approximately
one mile. A National Pollutant Discharge Elimination System
(NPDES) permit, which is issued by the state, is required for the.
discharge to the river.
Monitoring will be conducted to track contaminant migration and to
identify further impacts to public health and the environment.
Additionally, as required by CERCLA at sites where any hazardous
substances, pollutants or contaminants remain, a review of the
site will occur every five (5) years.
The cap will cover all waste disposal areas, thereby eliminating
any potential for exposure from contact with wastes, or from
contact or accidental ingestion of leachate or contaminated soil.
Capping provides the best short-term effectiveness as it
eliminates direct human exposure to the wastes, leachate and
contaminated soil in a relatively short time (two to three years).
Capping the landfill will also reduce infiltration of water into
the landfill, thereby reducing leaching of contaminants into ground
water.
Leachate collection and ground water extraction will supplement
the cap in reducing the migration of contaminants into ground
water. This will be effective in the long term in minimizing
further degradation of the bedrock aquifer. Leachate collection
and ground water extraction are the most effective means of
capturing ground water flow in the highly fractured shallow
bedrock aquifer, although the complex hydrogeology makes it
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Laurel Park, Inc.
impossible to ensure complete capture of all contaminated ground
water and leachate migrating from the site. Leachate collection
and ground water extraction are the best available technologies
for complying with the 1) RCRA Ground Water Protection Standard,
2) the EPA Ground Water Strategy, and the 3) CT Ground Water
Classification Program. Leachate collection and ground water
extraction also reduce the toxicity, mobility, and volume of
contamination affecting the groundwater, and use treatment to the
maximum extent practicable at this site in achieving these goals.
Because leachate and contaminated ground water will be treated and
discharged to the Naugatuck River under this alternative,
improvement in the quality of the unnamed stream and Long Meadow
Pond Brook would be expected soon after closure.
This alternative is similar to Alternative 3 in many respects, the
principal difference is on-site treatment of leachate and
extracted ground water. Implementation of this alternative
involves construction of both a complete treatment system and a
discharge pipe, whereas Alternative 3 requires construction of
only a discharge pipe to the sewer system (and, if required, a
pretreatment system). The complexity of the on-site treatment
system creates a potential for operational mishaps. Operation and
maintenance requirements for the system would be high due to its
complexity. An operator would be required twenty-four hours per
day. Potential risks to treatment plant operators are higher than
in Alternative 3 because of the higher concentrations of
contaminants in the water being treated. The treatment plant
would produce up to 1,000 gallons per day of sludge that would
require disposal off-site. If the sludge is determined to be
hazardous waste it would require disposal at a RCRA facility.
Alternative 3
Cap, Leachate Collection/Groundwater Extraction, Off-site
Treatment at the NWPCF
Estimated Present Worth Cost: $21,706,300, without pretreatment;
$23,078,200, including pretreatment
The components of this alternative are the same as Alternative 2
(RCRA cap, existing leachate collection system, and shallow ground
water extraction) except that leachate and contaminated ground
water will be conveyed by the municipal sewer for treatment off-
site at the Naugatuck Water Pollution Control Facility (NWPCF). To
accomplish this a new sewer line would be constructed from the site
to the Rubber Avenue interceptor. Treatment of leachate and ground
water at the NWPCF will require complying with applicable
pretreatment regulations and obtaining a pretreatment permit from
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Laur ei Park. Inc.
the state. Pretreatment on site (if required by the pretreatment
permit) will conform to those requirements.
Alternative 3 is the selected remedy. The rationale for selection
is discussed in Chapter X.D below.
Alternative 4
Cap, Leachate Collection, and On-Site Treatment
Estimated Present Worth Cost: $19,108,000
Like Alternatives 2 and 3, this alternative provides for source
control by capping according to RCRA regulations and leachate
collection. However, this alternative does not include a ground
water extraction system. Migration of contaminants from the
landfill will continue in that portion of the aquifer not
influenced by the existing leachate collection system.
On-site treatment differs from that in Alternative 2 only in the
decreased size of the components as flow rates are expected to be
less without a ground water extraction system.
Because migration of contaminants from the landfill will continue
in that portion of the aquifer not influenced by the leachate
collection system, this alternative is not. as protective of human
health and the environment as Alternatives 2 and 3; involves less
reduction of toxicity, mobility, and volume; is not as effective
in the long term; and does not use treatment to the maximum extent
practicable.
Alternative 5
Cap, Leachate Collection, and Off-site Treatment at the NWPCF
Estimated Present Worth Cost: $18,867,000
Like Alternative 4, this alternative provides for capping
according to RCRA regulations and leachate collection. However,
it does not include a ground water extraction system and,
therefore, migration of contaminants from the landfill will
continue in that portion of the aquifer not influenced by the
leachate collection system. Like Alternative 4, this alternative
is not as protective as Alternatives 2 and 3; involves less
reduction of toxicity, mobility, and volume; is not as effective
in the long term; and does not use treatment to the maximum extent
practicable. Leachate is conveyed in the municipal sewer for
treatment off-site at the NWPCF. Human health and environmental
impacts from off-site treatment at the NWPCF are similar to those
presented for Alternative 3.
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Laurel Park. Inc.
Alternative 6
Excavation, On-Site Incineration, Ground Water Extraction, On-
Site Treatment
Estimated Present Worth Cost: $347,444,000
This alternative involves the excavation of all wastes and
contaminated soils and sediments from the Laurel Park landfill,
followed by on-site incineration of the excavated material, and
the disposal of ash and other residuals in a newly constructed on-
site RCRA landfill. Ground water extraction and on-site treatment
of contaminated ground water will also be provided with this
alternative.
This alternative reduces toxicity, mobility, and volume to the
greatest extent of all the alternatives, offers the most permanent
solution, and involves the greatest use of treatment. However, the
cost is exorbitant. In addition, this alternative will not be
effective in the short term, as it is estimated that it will take
twelve years to excavate and incinerate all the waste. The varying
characteristics of the waste at the site limit the efficiency of
the incinerator.
In addition, during the period of excavation and transportation of
wastes for incineration, there is significant risk to on-site
workers and nearby residents from exposure to contaminated soils,
contaminated dust, volatilized organics, and incinerator ash being
transported for disposal. Also, during the long excavation
process, when wastes are relatively exposed to the environment,
storm events may result in further releases. In addition, the
incinerator will rely heavily upon emission control dev :es to
prevent releases to the atmosphere. Releases may occur if these
devices were to fail.
Excavation, incineration and construction of a new landfill
require compliance with several parts of RCRA. Ground water
extraction and treatment requirements will be the same as stated
for Alternative 2.
[Alternatives 7 Through 10 were screened out in the FS]
Alternative 11
Cap, In-situ Biodegradation, Leachate Collection/Groundwater
Extraction, and On-Site Treatment
Estimated Present Worth Cost: $28,482,000
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Laurel Park. Inc.
This alternative would involve capping of the landfill as
described in Alternative 2, leachate collection and shallow ground
water extraction to the shallow bedrock aquifer, treatment of
leachate and extracted water on-site, oxygen and microbial
enrichment of the treated water, and finally reinjection of the
enriched water back into the landfill.
Capping, leachate collection, ground water extraction, and on-
site treatment offer the same environmental and human health
protection as Alternative 2. The addition of in-situ
biodegradation offers potentially greater environmental protection
by increasing the rate of waste decomposition. However, extensive
testing would be required to design the biodegradation process, and
the effectiveness is unknown because results have not been
demonstrated with diverse mixed wastes as are present here. In
addition, reinfiltration of the treated water will increase the
hydraulic head on the landfill, which could result in increased
contaminant flow into the bedrock aquifer. This alternative does
involve treatment of the source, but beneficial results of the
biodegradation process are not expected to be seen for more than
five years after implementation.
The following alternatives were screened out in Chapter 3 of the
FS.
Alternative 7 Excavation, Incineration Off-site, Disposal of
Residuals Off-site, Restoration of the Site
Alternative 8 Excavation, Disposal in On-site Landfill, Leachate
Collection and Treatment, Restoration of the Site
Alternative 9 Excavation, Disposal in an Off-site RCRA Landfill,
Restoration of the Site
Alternative 10 Soil Flushing, Leachate Collection, Ground Water
Pumping, On-site Treatment
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Laurel Park, Inc. ,
X. THE SELECTED REMEDY
The selected remedy, Alternative 3, is a comprehensive approach
for site remediation which addresses the source and associated
contaminant migration.
A. Description of the Selected Remedy
1. Cap
The objective of the cap (cover) is to reduce infiltration into
the landfill so that 1) the generation of leachate is reduced, and
2) the water table is lowered such that it is below landfill
material. An additional objective is to eliminate direct human
exposure to wastes, contaminated soil, and leachate.
These objectives are expected to be achieved by designing a cap
that complies with the Resource Conservation and Recovery Act
(RCRA) landfill closure regulations. Detailed design criteria for
the cap will be developed during remedial design to allow for the
use of the most current materials and procedures appropriate for
the specific conditions at the site. Capping will entail
regrading to a maximum grade of 3:1 by filling with clean fill.
The proposed conceptual cover design, as presented in the FS, will
be a multimedia cap and will include provisions for gas collection
and venting. In addition, a security fence will be erected around
the perimeter of the landfill.
Maintenance of the cap so that there is no infiltration is
critical to ensuring a reduction of leachate generation and to
ensuring the dewatering of the landfill.
2. Existing Leachate Collection System
A perimeter leachate collection system exists at the landfill.
This system was designed and constructed in 1983-1984 by Fred C.
Hart Associates for Laurel Park, Inc. The existing leachate
collection system will remain in operation; however, it will be
rehabilitated and further evaluated during remedial design to
determine if upgrading is required to improve its effectiveness.
3. Leachate Collection/Ground Water Extraction System
The objectives of the leachate collection/ground water extraction
system are to:
- extract leachate not intercepted by the existing
leachate collection system,
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Laurel Park. Inc.
extract highly contaminated shallow ground water to the
bottom of the shallow bedrock in the immediate vicinity
of the landfill, and
supplement the cap in depressing the water table.
These objectives are expected to be achieved by means of the
following design criteria:
installing French drain and/or extraction wells to the
bottom of the shallow bedrock zone (upper bedrock
fractured zone), and
developing depth and location specifics for the French
drain and/or extraction wells during remedial design.
The proposed method for extracting leachate and contaminated
ground water to the bottom of the shallow bedrock will be a
combination of a French drain, and ground water extraction wells
where the installation of the French drain is not possible. The
benefits of each of these technologies will be considered in
greater detail during the remedial design, and the actual design
details, with regard to location and depth, will be. determined
and specified at that time. As conceptually proposed in the FS,
the French drain system could consist of perforated pipe in a
gravel envelope with the remainder of the trench backfilled with
sand and gravel with a liner on the down gradient side of the
trench. Water collected in the pipe will flow by gravity to
sumps where it will be pumped to the surface. Extraction wells
are presently proposed for use around the western side of the
landfill where there is substantial overburden.
Leachate collection and ground water extraction are the most
effective means of capturing ground water flow in the highly
fractured shallow bedrock. While contaminant migration is not
limited to this upper, fractured zone, the complex hydrogeology
of the site makes it impossible to ensure complete capture of all
contaminated ground water and leachate migrating from the site or
to extract contaminated ground water in deep bedrock. It is
therefore impossible to remediate the entire bedrock aquifer.
The objectives of the leachate collection/groundwater extraction
system will be accomplished when all three of the following
standards are achieved:
1. the RCRA Ground Water Protection Standard (GWPS) is met
at the point of compliance;
2. the concentration standard, which is satisfied when the
concentration of contaminants in the ground water has stabilized
due to the -reduced generation of leachate; and
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Laure 1 Park. Inc. _^____
3. the hydraulic standard, which is satisfied when the
water table has been lowered below the waste and the generation
of leachate has ceased or been reduced to a minimum due to
dewatering of the landfill.
If during implementation of the remedy the hydraulic standard and
concentration standard are achieved for a period of three years
without achievement of the RCRA GWPS, then EPA will determine
whether to modify the system to achieve the GWPS or take other
appropriate action.
EPA cannot at this time predict when the leachate collection/-
ground water extraction system will fully accomplish its
objectives until additional field work and design and
implementation of the remedial action are accomplished. An
estimate of the time that the system will be in operation will be
made during design, and' the determination whether the system has
fully accomplished its goals will be made as specified in the
previous paragraph. Quarterly monitoring will be necessary to
determine whether the goals of the system have been achieved.
This data may also be used as the basis for modification of the
system or the time of its operation, or other appr prjate action.
It is also expected that to determine the hydraulic standard
installation of one or more monitoring wells within the landfill
may be required.
4. Treatment of Leachate and Contaminated Groundwater
at the NWPCF
a. Conveyance Facilities
Leachate and extracted ground water will be discharged into the
municipal sanitary sewer for treatment at the Naugatuck Water
Pollution Control Facility (NWPCF). The Domestic Sewage
Exclusion provides that a hazardous waste, when mixed with
domestic sewage, is no longer a solid waste. Therefore,
hazardous waste may be mixed with domestic sewage and sent to a
publicly owned treatment work (POTW) which does not have a RCRA
treatment, storage and disposal facility permit. Discharge of
leachate and extracted ground water to the sanitary sewer will
require compliance with applicable pretreatment regulations
mandated in the pretreatment permit issued by tao state.
Leachate and extracted ground water will be conveyed to the NWPCF
in three distinct segments; Andrew Avenue (approximately 2,000
feet); the Rubber Avenue Interceptor (approximately 3,000 feet);
and the Westside Interceptor (approximately 6,000 feet). A new
sewer line will be constructed along Andrew Avenue from the
landfill to the Rubber Avenue Interceptor and will be dedicated
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Laurel Park. Inc.
exclusively to leachate and extracted ground water from the
landfill. There the leachate and extracted ground water will mix
with sewage. The existing interceptors will be used to convey the
leachate, diluted in the sewage, from there to the NWPCF.
b. Treatment at the NWPCF
Treatment processes at the NWPCF consist of screening, flow
equalization, flocculation, sedimentation, disinfection, activated
sludge treatment, sludge dewatering, and sludge incineration.
The estimated daily leachate and ground water flow from the
landfill is approximately 20,000 gallons. The NWPCF is designed
to treat 10.5 million gallons/ day, while the current flow is 5.5
million gallons/day. The NWPCF is required to have an NPDES
permit to discharge to the Naugatuck River and has a history of
compliance with 'its permit. NPDES permits may be amended in the
future to require effluent toxicity testing. In January 1988 the
NWPCF had a bioassay analysis performed on its effluent, with
results of 100% survival in 100% effluent concentration.
c. Pretreatment (If required)
CT DEP has informed EPA that both it and the Naugatuck Water
Pollution Control Board have determined that pretreatment is not
required before treatment of leachate and extracted ground water
at the NWPCF. If required at some future point, pretreatment of
the leachate and extracted ground water to a level acceptable for
discharge to the NWPCF will be implemented at the landfill site.
5 . Monitoring
The objectives of monitoring are:
to monitor the effectiveness of the remedy - hydraulic
and water quality end points,
to monitor the bedrock aquifer relative to ground water
standards and institutional controls. (At some point the
bedrock aquifer is expected to be remediated due to
natural degradation and dilution processes.)/
to identify further impacts to public health and the
environment .
The monitoring plan will be finalized during the remedial design
and will address ground water, surface water/sediment, leachate,
and air.
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Laurel Park, Inc.
Additionally, as required by CERCLA at sites where any hazardous
substances, pollutants or contaminants remain after completion of
the remedy, a review of the site will occur every five (5) years.
B. Estimated Remedial Schedule
Record of Decision June 1988
Negotiation with PRPs August - December 1988
Remedial Design January 1989 - July 1990
(1 to 1 1/2 years)
Construction of Cap &
Ground Water Extraction July 1990 - July 1993
System ("3 years)
Cap 2-3 yrs
French drain 3 yrs
Ext. Wells 1 yr
Complete Remedial Action
Construction July 1993
Perimeter fencing and construction and operation of the Andrew
Avenue sewer line are independent design and construction
activities and may occur on an independent schedule.
C. Institutional Controls
EPA recommends to the State and the Borough that they implement or
require institutional controls (e.g., regulations, ordinances,
deed and land restrictions, or other effective forms of land use
control) to prevent the use of the bedrock aquifer to supply
private wells for any water purposes in the vicinity of the site
in order to protect human health.
The use of ground water should be restricted for an indeterminate
period of time, until it is determined conclusively that the
ground water protection standards have been met. Restrictions on
the use of ground water are a necessary public health precaution
for two reasons: 1) existing contaminated ground water
downgradient of the proposed extraction network will not be
captured by the extraction system, and 2) because of the complex
hydrogeology ot cne site, and the limitation of the ground water
extraction system, capture of contaminated ground water migrating
from the landfill will not be complete.
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Laurel Park. Inc. _____
D. Rationale for Selection
The rationale for choosing the selected alternative is based on
the assessment of each criterion listed in the evaluation of
alternatives section of this document. In accordance with Section
121 of CERCLA, to be considered as a candidate for selection in the
Record of Decision (ROD), the alternative must have been found to
be protective of human health and the environment and able to
attain ARARs, unless a waiver is granted. In assessing the
alternatives that met these statutory requirements, EPA focused on
the other evaluation criteria, namely: implementability, short term
effectiveness, long term effectiveness, use of treatment to
permanently reduce the mobility, toxicity and volume, and the cost.
EPA also considered nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance. In addition, a number of site specific conditions at
Laurel Park played a critical role in defining an appropriate
remedy. These included:
the location of the landfill on a hill,
the close proximity of the waste to fractured bedrock,
and
the presence of a fractured bedrock aquifer with upper
and lower zones.
Based on this assessment, and taking into account the statutory
preferences of CERCLA, EPA selected the remedial approach for the
site.
1. Cap
Capping, runoff collection and control, and gas collection and
treatment are implementable remedies for the site. They are
widely practiced methods for landfill closures and protection of
ground water. Most materials necessary for closure should be
readily available. Placement of cap layers is a fairly common
practice, although care must be taken to ensure no damage to the
synthetic liner occurs.
Proper implementation will require reducing side slopes where they
are excessive, as well as protecting the cap from damage due to
subsidence. Side slopes will be expanded using locally derived
soil to meet the 3:1 slope guidelines of RCRA. Subsidence damage
will be minimized by proper cap construction.
-------
ROD DECISION SUMMARY page 25
Laurel Park. Inc.
Capping is estimated to take between two to three yeats to
implement. Capping eliminates direct human exposure to the wastes
and contaminated soil in a relatively short time. Proper safety
precautions, the relatively short duration of construction
activities, and the minimal handling of landfill materials
necessary during construction will minimize any risks from
exposure to dust, volatile emissions, or contact with waste or
leachate.
The major purpose of the impermeable cap is to dewater waste and
reduce leachate generation, thus reducing ground water
contamination. The cap is expected to be successful in achieving
these results given the topographic location of the landfill.
Improvements in ground water quality should be seen once the
initial soil layer is in place, as infiltration will be
significantly reduced. Materials chosen will have a life
expectancy of greater than thirty (30) years.
Proper installation of the multimedia cap will ensure its
effectiveness in preventing infiltration of surface water. Proper
installation of the clay layer and synthetic membrane are key to
ensuring the integrity of the system and promoting runoff away from
the fill. Proper grading and maintenance of the final cover will
minimize the amount of infiltration.
Periodic, routine monitoring will detect differential settling of
landfill materials. Although settlement cannot be controlled and
could impair the liner, settlement damage is repairable.
Establishing and maintaining cover and side slope vegetation will
prevent erosion that may lead to deterioration of the cap system.
Although the source will not be treated, and residual
contamination in the landfill will remain in place, natural
degradation processes will reduce the volume and toxicity of the
remaining wastes. However, these processes are slow and
contamination will persist in the landfill for an indefinite
period of time.
2. Existing Leachate Collection System
Rehabilitation of the existing leachate collection system should
improve its effectiveness, in capturing leachate and preventing
its infiltration to ground water. Currently it is only partially
effective in capturing leachate. After rehabilitation, and with
subsequent periodic cleaning, the useful life of the system is
expected to exceed thirty years.
-------
ROD DECISION SUMMARY page 26
Laurel Park. Inc.
3. Leachate Collection/Ground Water Extraction
The existing leachate collection system will be supplemented with a
shallow ground water extraction program. The method for
extracting contaminated ground water and leachate includes both a
French drain into bedrock and ground water extraction wells.
Details of implementation, location, and depth of the ground water
extraction system will be determined during remedial design.
The geometry and lithology of the site in conjunction with the
installation of the French drain and extraction wells will be
successful in extracting leachate and highly contaminated ground
water located in the vicinity of the landfill, and reducing
further degradation of the bedrock aquifer.
The proposed French drain system is the most effective means of
capturing leachate and contaminated ground water in the shallow
bedrock aquifer due to the low transmissivity of the aquifer and
the minimal recharge in the area. Lining the bottom of the trench
and placing a geotextile liner above the gravel layer will
increase effectiveness. Proper trenching procedures, including
dewatering, will improve the reliability of the sys^en. Periodic
cleaning and inspecting will maintain the performance of the
system.
The useful life of the French drain should exceed thirty years.
Replacement of sump pumps would be expected once within this time
period. With proper maintenance and inspection the system is
expected to be very reliable and effective over its useful life.
Completion of the system and achievement of beneficial results
should take approximately three years.
Installation of the French drain will involve fracture and
excavation of rock. Trenching into rock in certain locations may
prove difficult due to the depths of trenching required. Proper
lining of the downgradient trench wall will contain migration
resulting from increased permeability in the fractured zones
because of fracturing of bedrock.
Installation of ground water extraction wells in areas where
installation of the French drain is not possible is a common
practice using readily available materials. The wells can be
installed and achieve beneficial results in less than one year.
The performance of the extraction wells is dependent on the
information gained during predesign hydrogeological studies.
Based on the information available, the proposed wells will be
effective only in the limited area where they are screened. Thus,
they will limit contaminant migration only to a limited extent, and
-------
ROD DECISION SUMMARY page 27
Laurel Park. Inc. ;
complete capture is not possible. Therefore, use of extraction
wells will be confined to areas where installation of the French
drain is not possible.
Proper installation of the wells and regular maintenance of the
pumps and screens will insure the reliability of the wells. The
low yields expected in the majority of the wells necessitates the
use of pumps with water levels probes for on/off control and
routine cleaning of the wells to ensure the integrity of the
screens and insure continuous yield.
Use of stainless steel extraction wells and pumps should achieve a
useful life of at least thirty years. If pumping is intermittent
the useful life of pumps and screens will be shortened, possibly
requiring replacement once during the life of the project. Proper
maintenance of well pumps will ensure reliable operation.
4. Treatment of Leachate and Contaminated Ground Water at NWPCF
The NWPCF is designed to treat 10.5 million gallons per day of.
waste water and current average flows are 5.5 million gallons per
day, providing 5 million gallons per day of available capacity.
The NWPCF is in full operation. Implementation is
straightforward; it will consist of constructing the sewer line to
the Rubber Avenue Interceptor. Treatment of leachate and ground
water at the NWPCF will be effective in both the short and long
term. Studies show that the NWPCF treatment systems should
significantly reduce the concentration of contaminants conveyed by
the leachate and ground water. The NWPCF's continued compliance
with its NPDES permit will assure its continued reliabi"\ty and
effectiveness in treating leachate and ground water.
Based on recent bioassay test data on the plant's effluent, the
NWPCF is effective in treating the industrial and municipal waste
waters it receives. The addition of leachate and groundwater from
the Laurel Park site should not have a measurable effect on
treatment efficiencies at the NWPCF.
The sewer pipe that will convey leachate to the NWPCF will be
closed and residents' and transients' access to the pipe will be
restricted; therefore the discharge of leachate and contaminated
ground water to the sewer should not pose potential health risks
to those groups. Any risk to sewer maintenance personnel who may
enter the sewer are expected to be minimal when Occupational
Safety and Health Administration (OSHA) procedures for confined
space entry are followed.
There is some potential for volatilization of organic compounds at
the NWPCF. The amount of volatilization that could occur at the
-------
ROD DECISION SUMMARY page 28
Laurel Park. Inc.
plant depends on the concentrations of compounds present in the
waste stream, the degree of pretreatment (if any) occurring on
site, and the degree of volatilization en route to the plant.
Concentrations of volatile organic compounds at the plant should
be low due to the dilution of the leachate in the sewage.
Therefore, any risks to treatment plant workers from inhalation of
volatile organic compounds cannot easily be quantified, but are
expected to be minimal if the plant is in compliance with OSHA
ventilation standards. In contrast to Alternative 2, the risk to
workers at the NWPCF is expected to be lower than at the on-site
treatment plant, as a result of the dilution of contaminants in the
domestic sewage.
Ground water contamination resulting from leakage during
conveyance of leachate to the NWPCF, if any, should be
insignificant. The proposed 6-inch diameter Andrew Avenue
Interceptor will be new and should have virtually watertight
joints. The Rubber Avenue and Westside sewers are only ten years
old and are in good condition. When the leachate mixes with the
sanitary sewage flow in the Rubber Avenue and Westside
Interceptors, the relative concentrations of contamination will
decrease more than 75-fold, even in the worst case scenario (i.e.,
peak leachate flow and minimum sanitary sewage flow). Even if ^
there is exfiltration from the existing interceptors, the effect ofl
the ground water should be negligible.
Although not required by the State at this time, if required at
some future point, pretreatment will be easily implementable.
Implementation will require some construction; however, the
construction practices are straightforward. Since the units will
be rather small based on flow, some of the units may be purchased
directly from a manufacturer and installed instead of constructed
at the site. Time required for installation, including design,
construction and bench scale studies, is estimated to be one year.
Following construction, beneficial results would be achieved
immediately.
The reliability of the pretreatment system is expected to be good.
Operation and maintenance requirements are manageable, and the
useful life of these unit processes is estimated to be at least
twenty years based on experience with their use at industrial
wastewater treatment facilities.
-------
ROD DECISION SUMMARY page 29
Laurel Park. Inc.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Laurel
Park, Inc. Superfund Site is consistent with CERCLA and, to the
extent practicable, the NCP.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will permanently reduce the risks
presently posed to human health and the environment. Significant
public health and environmental benefits are provided by
constructing a multimedia cap on the Laurel Park landfill. The
cap will cover all waste disposal areas, thereby eliminating any
potential for exposure to humans from contact with wastes, or from
contact or accidental ingestion of leachate or contaminated soils.
Capping the landfill will also reduce infiltration of rainwater
into the landfill, thereby reducing leaching of contaminants into
ground water.
Leachate collection and ground water extraction will supplement
the cap in reducing migration of contaminants into ground water,
thereby minimizing further degradation of the bedrock aquifer.
Discharge of leachate and contaminated ground water to the sewer
will improve the quality of the unnamed stream and Long Meadow
Pond Brook.
Any potential risks from conveyance of leachate to and treatment
of leachate at the NWPCF should be minimal and are not expected to
pose a threat to human health and the environment.
B. The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the site.
Environmental laws which are - -plicable or relevant and
appropriate to the selected remedial action at the Laurel Park,
Inc. Superfund Site are:
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Clean Air Act (CAA)
A brief narrative summary of the ARARs follows.
Capping of the Laurel Park landfill will result in compliance with
-------
ROD DECISION SUMMARY page 30
Laurel Park. Inc. -
RCRA closure regulations (40 CFR Part 264, Subpart G and 40 CFR
Section 264.310).
Thickness of cap layers and materials proposed for use in
construction will meet or exceed RCRA guidelines. Post-closure
care and maintenance will also be instituted as required under 40
CFR, Section 264.117 and 40 CFR Section 264.310(b).
The proposed grading plan for closure will comply with the RCRA
regulations at 40 CFR Section 264.310 and 40 CFR Part 268 in that
no wastes will be moved in attaining the required 3:1 slopes of
.the landfill.
Capping will result in gas build-up and the need for gas
collection and/or venting. Testing of the emissions will be
required to determine if emissions are in compliance with the
Connecticut Air Standards. The CT DEP Hazardous Air Pollutant
Regulations are adopted pursuant to CT General Statutes Title
22A-174 (Title 22A-174-5 refers to test methods, and Title 22A-
174-29 presents the standards). If emissions do not meet the
above standards treatment will be required.
Since surface drainage will be from clean soil, there is no need
for a permit under the Clean Water Act, 33 U.S.C. 1151 et seq.
(Connecticut water quality standards are also satisfied in this
regard.) If required by the State, a water diversion permit must
be obtained to alter the drainage pattern at the unnamed stream's
head waters to compensate for the increased runoff expected to
result from capping.
The relevant and appropriate requirements for the ground water
extraction system (French drain and extraction wells) are the
RCRA ground water protection regulations in 40 CFR Part 264,
Subpart F. The RCRA regulations require attainment of a ground
water protection standard (GWPS) at the point of compliance,
which is the vertical surface located at the hydraulically
downgradient limit of the waste management area that extends down
into the uppermost aquifer underlying the unit. The GWPS under
current regulations is set at the Maximum Contaminant Levels
(MCLs), Alternate Concentration Limits (ACLs), or background. At
the Laurel Park site ground water at the point of compliance
currently exceeds levels that could be set as the GWPS. As a
result, EPA has determined that corrective action (ground water
extraction and source capping) is necessary in accordance with 40
CFR Section 264.100, which requires corrective action to ensure
that the GWPS is attained. Monitoring to determine the system's
effectiveness will be performed according to Section 264.100(d).
-------
ROD DECISION SUMMARY page 31
Park. Inc. _
The EPA Ground Water Protection Strategy (EPA Office of Ground
Water, August 1984) is a "to be considered" guidance. The
strategy establishes ground water classification guidelines based
on the policy that different ground waters merit different levels
of protection. The aquifer at the Laurel Park Site is classified
as a Class II ground water, ground water that is currently being
used or may be used as a drinking water source in the future. EPA
feels that the aquifer at the Laurel Park Site is a resource that
should be protected from further degradation. Given the site
conditions, the remedial action that is being selected will reduce
the introduction of additional contamination into the bedrock
aquifer and meet the intent of the ground water protection
strategy.
The State of Connecticut has adopted a State Ground Water
Classification Program under the CT Water Quality Standards
pursuant to CT General Statues Section 22A-426 which is relevant
and appropriate at the site. The state classifies the ground
water at the Laurel Park Site as GB/GA, ground water that is
currently known or presumed to be degraded, with a ground water
quality goal of being potable without the need for pretreatment.
The selected remedial action is in accordance wicl^ uhe state
ground water classification goal.
The Domestic Sewage Exclusion (40 CFR Section 261.4 (a) (1) )
provides that a hazardous waste, 'when mixed with domestic sewage,
is no longer considered a solid waste. Therefore, hazardous waste
may be mixed with domestic sewage and sent to a publicly owned
treatment works (POTW) which does not have a RCRA treatment,
storage and disposal facility permit.
Discharge of leachate and extracted ground water to the sewer
system will require compliance with all requirements of the
pretre. tment permit that will be issued by the Connecticut DEP and
of the Naugatuck sewer ordinance. If required by the pretreatment
permit once it is issued, as well as any time in the future, the
leachate must be pretreated on-site prior to discharge.
The NWPCF is required to have an NPDES permit to discharge to the
Naugatuck River, and has a history of compliance with its NPDES
permit.
Monitoring of environmental media for 30 years will comply with
RCRA ground water monitoring requirements under 40 CFR Part 264,
Subpart F.
All of the above are relevant and appropriate, except the
pretreatment permit, which is applicable, and the RCRA guidelines
and Ground Water Protection Strategy, which are "to be
considered. "
-------
ROD DECISION SUMMARY page 32
Laurel Park. Inc.
C. The Selected Remedy is Cost Effective
Once EPA has identified alternatives that are protective and
attain ARARs, unless a waiver is granted, EPA analyzes those
alternatives to determine a cost-efficient means of achieving the
cleanup.
Each of the alternatives underwent a detailed cost analysis to
develop costs to the accuracy of -30 to +50 percent. In that
analysis, capital and operation and maintenance costs were
estimated and then used to develop present worth costs. In the
present worth analysis, annual costs were calculated for thirty
years (estimated life of an alternative) using a ten percent
interest rate factor and were based on 1987 costs.
The preferred remedy is cost effective. The three alternatives
estimated to cost less than the preferred remedy are less
protective or otherwise unacceptable: the no action alternative
provides little protection and does not meet ARARs; and
alternatives 4 and 5 do not provide ground water extraction are
therefore not as protective.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Her very
Technologies to the Maximum Extent Practicable
This remedy utilizes permanent solutions and alternative treatment
or resource recovery technologies to the maximum extent
practicable for this site. For source control, complete and
partial removal or excavation were considered, as well s in-situ
biodegradation. Permanent solutions and resource recovery
technologies that would be applicable to the waste types found at
the Site require complete or partial excavation. Both were found
to be impracticable.
Complete excavation is outlined in Alternative 6. Besides being
cost prohibitive, it is also ineffective in the short term. The
large volume of waste that would require excavation, estimated at
1.3 million cubic yards, would require twelve years to excavate
and incinerate. During this period on-site workers and others
could have significant exposure from inhalation of volatilized
organics and contaminated dust, or from contact with wastes and
contaminated soils.
Excavation and removal or treatment of selected areas (or "hot
spots") of the landfill was also considered. During the FS a
survey of state records, aerial photographs, photographic slides,
and interviews with area residents and state officials indicate i
is very unlikely that discrete areas of contamination could be
-------
ROD DECISION SUMMARY page 33
Laurel Park. Inc.
distinguished. Historical records show that codisposal of
hazardous materials, whether in drums or from liquid tankers, with
municipal waste and construction debris occurred throughout the
operating life of the site. Pits which contained liquids were
normally reworked making it unlikely that discrete pockets of waste
remain.
In-situ biodegradation is outlined in Alternative 11. This was
the only alternative treatment technology that passed the
screening. It was found to be unacceptable because reinfiltration
of the treated water will increase the hydraulic head on the
landfill, which could result in increased leachate generation and
flow into the bedrock aquifer; extensive testing would be required
to design the biodegradation process; and the effectiveness is
unknown because results have not been demonstrated with diverse
mixed wastes as are present here.
E. The Selected Remedy Does Not Satisfy the Preference for
Treatment as a Principal Element
Treatment is not the primary element of this remedy, as the source
material will not be treated. As stated above, treatment of the
source material is either impracticable, involves unacceptable
risks to workers and others, is not cost-effective, or is
insufficiently protective. Treatment of leachate and contaminated
ground water will occur at the NWPCF, and represents the maximum
extent to which treatment is practicable.
XII. STATE ROLE
The Connecticut Department of Environmental Protection has
reviewed the various alternatives and has indicated its support
for the selected remedy. The State has also reviewed the Remedial
Investigation, Endangerment Assessment and 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 Connecticut concurs with the selected
remedy for the Laurel Park, Inc. Site. A copy of the declaration
of concurrence is attached as Appendix C.
-------
ROD DECISION SUMMARY
Attachment 1
-------
FIGURE 1-1
SCALE: 1* =. 2000*
PIRNIE
LAUREL PARK LANDFILL
NAUGATUCK, CONNECTICUT
LOCATION MAP
-------
ROD DECISION SUMMARY Attachment 2
Laural Park. Inc.
-------
TABLE 2^^
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL ,,i.DIA
Compound
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
^ Cadmium
^ Calcium
tn Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Se1 en i urn
Si 1 ver
Sodium
Thallium
Zinc
Cyanide
Total Phenols
Frequency
22/30
0/57
2/30
10/30
0/57
6/246
30/30
16/157
3/30
60/140
127/246
43/249
11/30
124/246
0/57
12/87
21/30
0/57
0/57
223/246
0/57
97/164
5/87
18/148
Groundwater
Range
(ug/L)
130-5,600
7-11
14-1,610
6-66
3,300-325,000
10-87
64-98
1-650
20-429,000
1-1,520
290-26,500
7-212,000
20-100
2,000-410,000
1,300-830,000
8-820
10-20
UO-3,410
Mean
(ug/L)
702
ND
0.6
95
ND
0.4
62,779
3
8
43
1,770
79
2,150
696
ND
6
43,481
ND
ND
49,948
ND
94
0.9
87
Frequency
3/5
0/4
1/4
2/5
0/4
0/16
5/5
4/21
5/8
15/21
2/21
3/5
17/21
0/4
3/4
3/5
0/4
0/4
17/21
0/4
10/17
0/4
9/10
Surface Water
Range
(ug/L)
170-327
6
17-19
14,000-40,600
10-34
20-90
40-23,000
780-820
2,150-12,200
20-4,290
20-60
2,800-22,100
4,000-605,000
10-549
180-1,200,000
Mean
(ug/L)
142
ND
2
7
ND
ND
21,512
4
ND
25
3,124
76
3,456
856
ND
28
5,760
ND
ND
92,321
ND
70
ND
191 ,682
Note: ND = not detected
-------
ro
I
i-"
en
Compound
Volatile Organ!cs
Acetone
Acrolein
Acrylonitriie
Benzene
Bis (chloromethyl) ether
Bromoforn
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Ch1orodi bromomethane
Chloroethane
2-Chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1,1-Dichloroethane
Oichlorodifluoromethane
1,2-Dichloroethane
1,1-Dichloroethylene
1,2-Dichloropropane
cis-1,3-Dichloropropylene
Ethyl benzene
Methyl bromide
Methyl chloride
TABLE 2-3
(Continued)
INDICATOR CHEMICAL
SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Frequency
8/30
0/57
0/56
41/244
0/56
0/56
5/30
1/30
0/37
6/204
0/57
2/87
0/57
11/87
0/57
6/192
1/162
3/192
1/87
1/214
0/57
12/243
0/57
0/109
Groundwater'
Range
(ug/L)
2-770
<1-8,700
<1-14
6
<3-32
<8-<15
<1-30
<1-8.8
11
21-9,680
6
29.2
<1-'J92
Mean
(ug/L)
84
NO
NO
59
ND
NO
0.8
0.2
ND
0.5
NO
0.3
ND
1
ND
0.2
0.1
76
0.07
0.1
ND
15
ND
ND
Surface Water
Range
Frequency (ug/L)
3/12 8-39
0/4
0/4
6/18 2-57.7
0/4
0/4
8/12 3-73
0/14
0/14
0/4
0/4
0/4
0/4
1/16 <2
1/16 5
0/18
0/4
4/18 8-16.7
0/4
1/10 10
Mean
(ug/L)
5
ND
ND
10
ND
ND
9
ND
ND
ND
ND
ND
ND
0.1
0.3
ND
ND
3
ND
1
-------
to
I
Compound
Volatile Organics (Cont'd)
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,2-Dichloroethane
trans-1,2-Dichloroethylene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
i/inyl chloride
trans-1,3-Dichloropropylene
Xylenes
4-Methyl-2-pentanone
Base Neutrals
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
TABLE
2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Frequency
5/243
0/57
3/214
22/243
2/214
2/214
0/214
0/214
0/214
2/243
0/57
10/30
2/30
0/91
0/91
0/91
0/91
0/91
1/121
Croundwater
Range
(ug/L)
3-3, 340
18.1-187
2-11,000
11-12
3-8.6
1-14
<2-63
8-11
<5
Mean
(ug/L)
10
ND
2
114
0.1
0.1
ND
ND
ND
0.1
ND
5
0.7,
|
ND
ND
ND
ND
ND
0.0't
Surface Water
Range
Frequency (ug/L)
7/28 8-39
OA
0/18
2/18 16-22.5
1/12 <3
0/16
1/18 3
OA
2/12 7-120
0/18
0/18
0/4
0/4
0/4
0/4
0/4
0/4
1/16 <6
Mean
(ug/L)
5
ND
ND
2
0.2
ND
0.2
ND
11
ND
ND
ND
ND
ND
ND
ND
ND
0.4
-------
K)
I
I
oo
Compound
Base Neutrals (Cont'd)
Benzo(b)fluoroanthene
Benzo(ghi)pery1ene
Benzo(k)f1uoroanthene
bis (2-Chloroethoxy) methane
bis (2-Chloroethyl) ether
bis (2-Chloroisopropyl) ether
bis (2-Ethylhexyl) phthalate
3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phathalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Frequency
0/91
0/91
0/91
0/91
<>/2
ND
ND
ND
ND
ND
ND
ND
ND
<1.6-19 0.2
ND
IK)
ND
ND
Surface Water
Range
Frequency (ug/L)
OA
OA
OA
OA
0/18
OA
2/22 <1-3
OA
OA
OA
OA
OA
OA
OA
OA
OA
6/30 <5.*-25
OA
OA
OA
OA
OA
Mean
(ug/L)
ND
ND
ND
ND
ND
NO
0.2
ND
ND
ND
ND
ND
ND
ND
ND
ND
3
ND
ND
ND
ND
NO
-------
NJ
I
Compound
Base Neutrals (Cont'd)
Di-n-octyl phthalate
1 ,2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutad i ene
Hexachlorocyclopentadiene
Hexachloroethane
ldeno(1,2,3-c,d)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodimethylami ne
N-nitrosodi-n-propylamine
N-nitrosodipheny1amine
Phenathrene
Pyrene
1,2,4-Trichlorobenzene
Acid Extractables
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethyl phenol
Frequency
0/91
0/91
0/91
0/91
0/91
0/91
0/91
0/91
0/91
11/121
4/192
0/162
0/91
0/91
10/247
3/143
2/91
0/91
0/57
1/133
2/133
TABLE 1-^^f
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Groundwater
Range Mean .
(ug/L) (ug/L)
ND
NO
ND
NO
ND
ND
ND
ND
ND
<1-<8 0.4
<1-4.4 ' 0.1
ND
ND
ND
<1. 5-3, 400 35
5.6-10.7 0.2
5-5.1 0.1
ND
ND
13,900 10
-------
I
M
O
Compound
Acid Extractables (Cont'd)
4 ,6-DinHro-o-cresol
2,4-Dinitrophenol
2-Nftrophenol
4-Nitrophenol
p-Chloro-m-cresol
Pentachlorophenol
Phenol
2,4,6-TrIchlorophenol
Dioxin
2,3,7,8-TCDO (ng/1)
OCOD (ng/1)
Frequency
0/57
0/57
0/57
0/57
0/57
0/57
2/57
1/133
0/87
104/152
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Croundnater
Range Mean
(ug/L) (ug/L)
NO
NO
NO
NO
NO
NO
4-1,830 32
1 ,0
-------
NJ
I
K)
Compound
Metals
Aluminum
Antimony
Arsenic
Barium
Beryl 1ium
Cadmium
Calcium
Chromium
Cobalt
Copper
I ron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
S i1ver
Sodium
Thai 1ium
Vanadium
Zinc
Cyanide
Total Phenols
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Leachate
Frequency
7/7 «»
0/1
3/8
7/7
2/8
8/12
7/7 130
10/12
5/7
7/8
12/12 5
8/12
7/7
12/12
1/8
7/8
7/7
1/8
Range
(ug/L)
, 200-^79,000
8-390
HO -5, 850
5-21
5.6-217
,000-1,080,000
11-1,250
93-681
30-2,090
,<»«iO-1 ,530,000
23.5-
-------
to
I
K)
Compound
Volatile Organics
Acetone
Acrolein
Acrylonitri1e
Benzene
Uis (chlororoethyl) ether
Bromoform
2-Butanone
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-Chloroethylvinyl ether
Chloroform
Dich1orobromomethane
1,1-01Chloroethane
Dichlorodifluoromethane
1,2-Dichloroethane
1,1-Dichloroethylene
1,2-Dichloropropane
cis-1,3-Dlchloropropylene
Ethyl benzene
Methyl bromide
Methyl chloride
TABLE 2-3
(Continued)
INDICATOR
CONCENTRATIONS
CHEMICAL SELECTION
IN ENVIRONMENTAL MEDIA
Leachate
Frequency
7/7
0/1
0/1
10/12
0/1
0/1
4/7
0/5
5/12
0/1
2/8
0/1
1/1
0/1
5/12
0/5
2/8
1/8
0/5
0/1
7/12
0/1
1/1
Range
(ug/L)
100-6,400
<3-1,300
60-5,500
8-72
<14-50
14
12-260
12-1,300
5
<1-240
16
Mean
(ug/L)
2,729
NO
NO
390
NO
NO
116
NO
2)
ND
8
ND
1
-------
K)
I
ro
u>
Compound
Volatile Organics (Cont'd)
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,2-dichloroethane
1,2-dichloroethylene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Tri chloroethy1ene
Trichlorofluoromethane
Vinyl Chloride
Trans-1,3-dichloropropylene
Xylenes
Base Neutrals
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
INDICATOR
TAULE |^^
(Continu^^F
CHEMICAL SELECTION
CONCENTRATIONS IN ENVIRONMENTAL
*
MEDIA
Leachate
Frequency
2/5
0/1
0/5
10/12
1/5
1/5
0/1
0/5
1/5
1/5
0/1
1/7
2/8
0/1
0/1
0/1
0/1
3/8
Range
(ug/L)
120-*»200
. <1-520
6
9
6
20
2<»
i
<11-20
<66-160
Mean
(ug/L)
108
ND
NO
117
1
2
ND
ND
1
4
ND
3
it
ND
ND
ND
ND
.'i 8
-------
ro
I
ro
Compound
Base Neutrals (Cont'd)
Benzo(b)f1uoroanthene
Benzo(ghi Jperylene
Benzo(k)fluoroanthene
bis (2-Chloroethoxy) methane
bis (2-Chloroethyl) ether
bis(2-Ch1oroisopropy1) ether
bis (2-EthylhexyJ) phthai ate
4-Bromophenyl phenyl ether
Butyl benzyl phthai ate
2-Ch1oronaphtha1ene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Oich1orobenzidine
Diethyl phthai ate
Dimethyl phthai ate
Di-n-butyl phathai ate
2,4-Dinitrotoluene
2,6-Di n itrotoluene
INDICATOR
TABLE 2-3
(Continued)
CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL
MEDIA
Leachate
Frequency
0/1
0/1
0/1
0/1
1/5
1/1
2/12
0/1
0/1
0/1
0/1
0/1
0/1
1/7
1/1
0/1
0/1
0/1
4/12
1/8
1/8
0/1
0/1
flange
-------
KJ
I
Compound
Base Neutrals (Cont'd)
Di-n-octyl phthalate
1 ,2-Diphenylhydrazine
Fluoranthene
Fluorene
llexachlorobenzene
llexachl orobutad i ene
Hexachlorocyclopentadiene
Hexachloroethane
Idenofl,2,3-c,d)pyrene
Isophorone
2-Methyl naphthalene
Naphthalene
Nitrobenzene
N-nitrosodimethylamine
N-nitrosodi-n-propylamine
N-nitrosodiphenylamine
Phenathrene
Pyrene
1 ,2,*»-Trichlorobenzene
Acid Extractables
2-fhlorophenol
2,^-Dichlorophenol
2,<»-Dimethylphenol
TABLE 2-3
(Continued)'
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL
MEDIA
Leachate
Range
Frequency (ug/L)
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
1/7 <22
2/12 80-99
1/5 31
0/1
0/1
6/12 22-9,800
2/8 <22-«»0
0/1
0/1
0/1
0/5
0/5
Mean
(ug/L)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
3
15
6
ND
ND
1.3H
8
ND
ND
ND
ND
ND
-------
to
I
N)
cn
Compound
Acid Extractables (Cont'd)
4,6-Dinitr- >-cresol
2,<»-Dfnitr> . .tenol
4-Methyl phi jl
2-Nitrophenol
4-Nitrophenol
p-Chloro-m-cresol
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
Dioxln
2,3,7,8-TCDO (ng/1)
OCDD (ng/1)
INDICATOR
TABLE 2-3
(Continued)
CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL
MEDIA
Leachate
Frequency
0/1
0/t
5/17
0/1
0/1
0/1
0/1
5/8
0/5
0/1
1/1
Range
(ug/L)
<300-9,100
12-2,100
0.58
Mean
(ug/L)
NO
NO
950
ND
NO
ND
ND
221
NO
Hli
0.6
-------
K)
1
K)
-O
Compound
Metals
Aluminum
Arsenic
Barium
Beryl) ium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Thallium
Tin
Vanadium
Zinc
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Frequency
5/5
2/5
5/5
3/5
1/5
5/5
5/5
1/5
2/5
5/5
5/5
5/5
5/5
1/5
5/5
3/5
1/5
-
5/5
5/5
Soil
Range
(mg/kg)
*,500-*8,000
1.8-3.1
35-130
0.67-0.91
0.8
2, 000-'*, 900
8.9-30
8.*
35-*6
7,600-18,000
2.7-1*1
2,*00-6,*00
220-960
15
910-*, 300
'5*0-1 ,300
12
.
11-39
22-160
Mean
(mg/kg)
27,300
1
80
0.5
0.2
2,860
20
2
16
13,920
19
3 ,7*0
576
3
2,022
538
2
-
26
83
Frequency
11/11
8/11
10/11
1/11
6/11
10/11
11/11
2/11
10/11
11/11
10/11
11/11
11/11
6/11
9/11
7/11
-
1/11
9/11
11/11
Sediment
Range
(mg/kg)
3,900-16,000
1.36-2.8
18.7-156
0.*9
0.7-2.29
735-3,800
2.*-15
5.0-5.1
*-67.7
*, 900-1 6, 300
1.8-326
930-3,200
63-290
5.98-10.9
5*0-1 ,800
1*7-820
-
5.71
8.09-19
16-150
Mean
(mg/kg)
5,813
1
39
0.0*
0.9
1,*83
6
0.9
18
8,2*5
63
1 ,*99
1*7
*
783
216
-
0.5
10
57
-------
I
10
00
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Soil
Compound
Volatjle Organics
Acetone
Acrolein
Aerylonitrlle
Benzene
Bis (chloromethyl) ether
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chiorodibromomethane
Chloroethane
2-Chloroethylvinyl ether
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Pichloroethylene
1,2-Dichloropropane
cis-1,3-Oichloropropylene
Ethyl benzene
2-Hexanone
Methyl bromide
Methyl chloride
4-Methy1-2-pentanone
Frequency
5/5
2/5
1/5
1/5
1/5
2/6
1/5
1/5
Range
(ug/kg)
9-26,000
3-59
22
54
490
6-65
300
550
Mean
(ug/kg)
6,582
12
4
11
98
12
60
11
Frequency
7/18
2/18
6/18
1/18
1/18
5/8
1/8
2/18
1/18
1/18
Sediment
Range
(ug/kg)
<4-21,000
<9-55
5-260
<7
<2-32
15
<5-95
73
Mean
(ug/kg)
1,291
54
0.4
0.9
10
2
6
4
-------
I
K)
Compound
Volatile Organics (Cont'd)
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,2-Dichloroethylene
1,1,1-Trichloroethane
1,1 ,2-Trichloroethane
T r i ch1oroethy Iene
Trichlorofluoromethane
Vinyl chloride
trans-1 ,3-Dichloropropylene
Xylenes
Frequency
1/5
1/5
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Soil
Range Mean
(ug/kg) (ug/kg)
400 80
8 1.6
Sediment
Range
Frequency (ug/kg)
9/18 6-120
1/18 <2
V/18 <8-160
1/18 <<»
1/18 <10
Mean
(ug/kg)
23
0.1
17
0.2
0.6
1/5
130
26
3/18
1/18
56
Base Neutrals
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
benzo(a)pyrene
2/5
1/5
130
100
52
20
5/18
5/18
8/18
8/18
9/18
<82-810
<200-1,800
160-2,000
800-4.700
770-<»,100
73
197
392
971
1,063
-------
KJ
I
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Soil
Sediment
Compound
Base Neutrals (Cont'd)
Benzo(b)fluoroanthene
Benzo(ghi)pery1ene
Benzo(k)fluoroanthene
bis (2-Chtoroethoxy) methane
bis (2-Chloroethyl) ether
bis (2-Chloroisopropyl) ether
bis (2-Ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-ChioronaphthaIene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1 ,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phathalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Frequency
1/5
1/5
Range
(ug/kg)
HO
Mean
(ug/kg)
28
15
Range
Frequency
8/18
9/18
3/18
3/18
3/5
76-120
63
9/18
8/18
4/18
1/5
75
15
1/18
9/18
660-6,iiOO
4190-2.000
760-6,200
54-830
1,000-5,200
160-680
77-650
<65
90-1,800
Mean
(ug/kg)
1,240
518
436
90
1,259
158
79
4
312
-------
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Soil
Compound
Base Neutrals (Cont'd)
Frequency
Range
(ug/kg)
Mean
(ug/kg)
Frequency
Sediment
Range
(ug/kg)
Mean
(ug/kg)
K)
CO
Di-n-oct,, phthalate
1 ,2-Oiph. ,y Ihydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
llexachl orobutadi ene
Hexachlorocyclo-pentadiene
Itexachloroethane
ldeno(1,2,3-c,d)pyrene
Isophorone
2-Methyl naphthalene
Naphthalene
Nitrobenzene
N-ni trosodimethyl amine
N-nitrosodi-n-propylamine
N-ni trosodi pheny1 amine
Phenathrene
Pyrene
1,2,'t-Trichlorobenzene
Acid Extractables
Benzene Acid
2-Chlorophenol
2 ,i»-Dichloropheno1
2 ,'l-Dimethylphenol
5/5
i»3-300
7/18
7/18
9/18
2/18
2/5
5/5
3/5
5/5
51-120
49-920
78-260
<«8-210
398
89
3/18
10/18
7/18
3/18
2,200-U.OOO
110-2,100
520-2,000
<77-<80
56-1,000
<95-56,000
650-12,000
1,900-9,800
76-'«60
3,078
262
«i99
3
90
3,122
2,250
2,072
56
-------
TABLE 2-3
(Continued)
INDICATOR CHEMICAL SELECTION:
CONCENTRATIONS IN ENVIRONMENTAL MEDIA
Soil
Sediment
Compound
Acid Extractables (Cont'd)
Frequency
Range
(ug/kg)
Mean
(ug/kg)
Frequency
Range
(ug/kg)
Mean
(ug/kg)
4,6-Dini tro-o-cresol
2,4-Dinitrophenol
4-Methyl phenol
2-Nitrophenol
4-Nitrophenol
I p-Chloro-m-cresol
to Pentachlorophenol
Phenol
2,4,6-T r i chlorophenc
Dioxin
2,3,7,8-TCDD (ng/1)
OCDD (ng/1)
1/18
1,700
1/5
4,200
8<«0
0/87
104/152 0.03-10.6
NO
0.3
0/8
8/11 0.07-0.61
NO
0.2
-------
ROD DECISION SUMMARY Appendix A
Laurel Park. Inc.
-------
RESPONSIVENESS SUMMARY
FOR THE
LAUREL PARK, INC.
SUPERFUND SITE
NAUGATUCK, CONNECTICUT
JUNE 23, 1988
Prep-.ed for:
REGION I
U.S. ENVIRONMENTAL PROTECTION AGENCY
Prepared by:
BOOZ, ALLEN & HAMILTON Inc.
Under Subcontract No. TESK-TEAM-013, WA Number 949
EPA Contract No. 68-01-7331
-------
TABLE OF CONTENTS
Pace
PREFACE 1
I. RESPONSIVENESS SUMMARY OVERVIEW 2
II. BACKGROUND ON COMMUNITY INVOLVEMENT 2
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS... 3
A. REMEDIAL ALTERNATIVES 4
Capping 4
Groundwater Extraction 6
Pretreatraent 7
Leachate Control and Treatment 8
Remedial Costs 10
B. PREFERRED ALTERNATIVES COMPARED TO OTHER SYSTEMS 11
C. MONITORING 13
D. SECURITY FENCE 14
E. OFF-SITE CONTAMINATION 14
F. ENDANGERMENT ASSESSMENT 15
G. GENERAL COMMENTS 20
H. EXTENSION OF THE COMMENT PERIOD 23
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE LAUREL PARK, INC. SUPERFUND SITE 24
ATTACHMENT B - REFERENCES TO SECTION III.F ENDANGERMENT
ASSESSMENT RESPONSES 25
-------
Preface
The U.S. Environmental Protection Agency (EPA) held a public
comment period from May 12, 1988 to June 9, 1988 to provide an
opportunity for interested parties to comment on the draft
Feasibility Study (FS), and Proposed Plan prepared for the Laurel
Park, Inc. Superfund site in Naugatuck, Connecticut. The draft
FS, completed in May 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 prior to the public comment period. An informal public
meeting was held just prior to the public comment period.
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised during the public
comment period. EPA considers all of the comments summarized in
this document before selecting a final remedial alternative for
the Laurel Park, Inc. site (Laurel Park).
This Responsiveness Summary is divided into the following
sections:
I. Responsiveness Summary Overview This- section briefly
summarizes public comments on the draft FS and remedial
alternatives.
II. Background on Community Involvement and Concerns - This
section summarizes major community concerns identified
in the community relations plan and during the RI/FS at
the Laurel Park site.
III. Summary of Comments Received During the Public Comment
Period and EPA Responses to These Comments This
section summarizes both written and oral comments
received during the public comment period and provides
EPA responses to them. These comments are organized
into categories representing the major issue areas that
were identified from the comments received.
Attachment A - This attachment includes a list of the
community relations activities conducted by EPA during the
Remedial Investigation and Feasibility Study efforts at the
Laurel Park, Inc. Superfund site.
Attachment B - This attachment includes a list of references
cited in the responses in Section III. F. Endangerment
Assessment.
-1-
-------
I. OVERVIEW OF PUBLIC COMMENTS ON THE REMEDIAL ALTERNATIVES
EPA received oral comments during the public hearing, and
written comments during the four week public comment period on
the FS and Proposed Plan. Section III of this document
summarizes the comments received and EPA's responses.
The comments received at the public hearing and during the
comment period provided historical information of which EPA may
not have been aware, questioned the processes by which public
input was solicited during the RI/FS stages and the public
comment period, asked for additional information on several
components of the proposed alternative and other alternatives
that were considered, and expressed concern for direct and side
effects of implementing the components of the plan. Several
citizens endorsed EPA's preferred plan. Other plans were
endorsed by different citizens and by a potentially responsible
party (PRP).
II. BACKGROUND ON COMMUNITY INVOLVEMENT
A variety of issues and concerns have been raised during the
20-year history of citizen involvement at the Laurel Park
Landfill. Beginning in the early -1960s, residents living near
the site complained about its operation. Complaints against the
landfill included uncontrolled burning, spillage of chemicals,
foul odors, and blowing debris.
The predominant concern in the past was over the potential
for exposure of area residents to contaminants seeping from the
landfill. Residents' fears about contamination focused on the
area's groundwater arid the unnamed stream running along Andrew
Avenue. Citizens also feared exposure of children to
contaminants in the steam that runs near an elementary school.
Area residents wanted to identify fully the extent of and
potential for contamination of their neighborhood. They
requested that the issue of dioxin be accurately addressed, that
samples be taken from residents' homes and from the school, that
stream sediments be tested, and that the potential threat to the
school be completely examined.
Two citizens groups have become involved in issues relating
to the landfill. The Pollution Extermination Group (PEG) has
been active since 1981. Originally organized to oppose
expansion of the landfill, PEG has been a vigorous proponent of
health testing for residents, and cleanup measures for the site.
The Andrew Avenue Homeowners Association, formed in 1983, focused
on concern over the leachate collection system and methods of
leachate disposal. Relations between the Naugatuck municipal
government and citizens living near the site have at times been
antagonistic. This friction between the citizens and the local
-2-
-------
officials is one of the reasons EPA has considered local access
to information and community involvement in the remedial process
critical to successful implementation of the Superfund cleanup
effort at the site. A series of "information exchanges" were
requested by residents. A roundtable meeting held in the Summer
of 1984 between PEG, Connecticut Fund for the Environment (CFE),
Connecticut Department of Environmental Protection (CDEP), Laurel
Park, Inc., Uniroyal, and EPA was a positive step in opening
communications between those involved.
In June 1985, EPA released a community relations plan that
outlined a program to address community concerns and keep
citizens informed about and involved in activities during the
Remedial Investigation, the Feasibility Study and the decision
process regarding the site cleanup. On June 6, 1985, EPA held an
informational meeting in the town to describe the plans for the
Remedial Investigation and Feasibility Study (RI/FS).
The RI/FS was conducted under EPA oversight between 1985 and
1988. This two-phased study defined the nature and extent of
contamination at the Laurel Park Site, and identified and
evaluated alternatives to address site contamination. EPA held
several meetings during this time to inform the public and answer
questions.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
An informal public hearing was conducted on May 25, 1988 to
receive oral comments. In addition, during the public comment
period EPA received written comments. A transcript of the public
hearing nd copies of written comments are available in the
Administrative Record at the information repository in the
Naugatuck Public Library, and also at EPA Region I offices in
Boston, Massachusetts.
This section of the Responsiveness Summary presents a summary
of all of the public comments offered during the public comment
period, and EPA responses to these comments. Ms. Mary Lou Sharon
and Ms. Mary Ann Maul, representing PEG, Mr. William Ostrander,
Ms. Daisy Ostrander, Ms. Dorothy Mason, Mr. Frank Parda, Ms. Mare
Swoditch, and Mr. Robert X. Schuster made oral comments at the
public hearing. Mr. & Ms. Ostrander (commenting twice, once on
behalf of themselves and a second time on behalf of PEG),
Ms. Sharon, representing PEG, Ms. Maul, representing the
Connecticut Fund for tne Environment on behalf of PEG, Ms. Ann
Marie Klosenski, Mr. Robert X. Schuster, Mr. Robert A. Smith,
Jr., representing Uniroyal and Honorable Joseph Lieberman,
Attorney General of Connecticut, submitted written comments.
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The comments and EPA's responses have been summarized under
eight major categories with subcategories, where appropriate.
Issues are summarized to synthesize several different points made
by commenters on a particular subject.
A. REMEDIAL ALTERNATIVES
CAPPING
Comment: Will placement of the cap stop run-off from the site?
Response; No, the landfill cap and planned vegetative cover will
control run-off, not eliminate it. Drainage channels are planned
as part of the cap design to control run-off and direct it to the
unnamed stream. After completion of the cap and drainage system,
nearly all run-off from the site will flow to the unnamed stream.
Because the landfill will be covered, the rainwater will not come
into contact with hazardous materials and the run-off to the
unnamed stream will be uncontaminated by the landfill.
Comment; Will surface run-off from the landfill be contained and
treated on-site, eliminating run-off to the unnamed brook?
Response; Surface run-off will not be contained on-site. As
described in Section 4.2.2.4 of the Feasibility Study, run-off
from the landfill cap will be channeled to the unnamed brook.
The water quality should improve- because rainfall will only come
in contact with the surface of the landfill cap and drainage
channels associated with the cap. The water quality of the
unnamed brook should improve significantly upon completion of the
cap and connection of the leachate collection system to the
Andrew Avenue sewer.
Commenc; Will run-off from the landfill corrode the culverts
that have been installed along Andrew Avenue in order to contain
the unnamed brook which originates at the landfill?
Response; The design of the landfill cap will include a system
of drainage ditches in order to control surface run-off during
rainstorms. Run-off from the capped landfill will be directed to
the unnamed stream to the north of the landfill, as described in
Section 4.2.2.4 of the Feasibility Study. After installation of
the leachate control system, which will convey leachate to the
sewer on Andrew Avenue, and installation of the cap, runoff to
the unnamed stream will be uncontaminated by the landfill because
rainwater will not come into contact with hazardous materials.
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Comment: How much water will leave the site after the landfill
has been capped?
Response; A detailed evaluation of the expected run-off from the
capped landfill has yet to be completed. Based on an evaluation
by a consultant for a PRP at a similar site in the region, it is
estimated that the total annual run-off from the Laurel Park site
after capping will be between 5-10 million gallons; or between
14,000 to 28,000 gallons per day on an average basis. During
rainstorms, peak flows will be higher.
comment! After the cap is built, will the landfill shrink?
Response! Yes, it is typical for capped landfills to settle and
shrink in size. This phenomenon will be evaluated during design
and means will be specified to assure that the integrity of the
cap will not be compromised by the expected settlement of the
landfill, or in other words, to ensure that the cap will not
crack or deteriorate. In addition, after the cap is complete, it
will be monitored annually as part of the operation and
maintenance procedures. Also, cap repairs such as slope
stabilization, regrading, and drainage ditch cleaning will also
be included in the on-going operations and maintenance program.
Comment: Will the construction of the cap destroy the monitoring
wells on site?
Responset It may be necessary to replace or retrofit certain
monitoring wells in order to complete construction of ^e
landfill cap. During design of the cap, construction stalls
will be prepared so that all wells affected by construction are
replaced or retrofitted prior to completion of construction.
Comment: What if asbestos was disposed of in the landfill
without first placing it in dedicated cells?
Response: Upon completion of the proposed landfill cap, the
potential for asbestos migration will be eliminated, regardless
of the initial means of landfilling it.
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GROUNDWATER EXTRACTION
Comment; Because of the groundwater extraction system,
Alternative #3 is not appropriate for this site and, in fact, may
have the potential to significantly increase the volume and
mobility of identified hazardous substances, pollutants and
contaminants migrating off-site.
The groundwater extraction system would require the construction
of deep trenches and extraction wells into rock. Construction
would require blasting or perhaps use of a special air impact
drill. This type of activity has <=. great potential for creating
many other fissures or increasing the size of the existing
shallow bedrock fractures. Such activity could cause increased
migration of contaminate flow or make new pathways of flow into
the aquifer, possibly exacerbating rather than minimizing
existing problems. Such recovery wells and trenches have not
been frequently used in bedrock aquifers elsewhere due to the
uncertainties in predicting and verifying capture of
contamination.
Response; Alternative 3 is not expected to increase the volume
of contaminants, rather the volume will be reduced as the
landfill is dewatered.
The potential for increasing the permeability of the shallow
bedrock was identified in the Feasibility Study, and was
considered during EPA's decision process. Increased permeability
of the shallow bedrock would allow it to have properties more
closely associated with a porous media. This is expected to
increase the efficiency of the groundwater extraction system.
The fact that groundwater extraction wells and trenches have not
been frequently used is not considered a limiting factor given
site conditions. In addition, it should be noted that
groundwater extraction wells and trenches have been used to
dewater bedrock systems in the construction field.
Commenti Groundwater extraction at this site is not appropriate
because such extraction is unnecessary in light of the public
water supply being installed.
Response; The groundwater extraction system is appropriate as a
mechanism to protect the aquifer regardless of the presence of a
water line.
Comment; It is not possible to predict with any certainty the
capture efficiency of the groundwater extraction system. If more
is needed for groundwater protection than is described in
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existing Alternative 5, more protection can be gained through
modifications in the existing leachate collection system. Such i
change would enhance the capture of leachate at or near the
generation source prior to entering the bedrock aquifer.
Response; The objective of the groundwater system is to extract
shallow groundwater in the immediate vicinity of the .landfill.
This system will extend on through to the shallow bedrock, which
is to the weathered and highly fractured zone of the bedrock
aquifer. The proposed system is expected to achieve this
objective. Modifications of the existing leachate collection
system would not achieve the above objective.
Installation of the cap will reduce the leachate flow
and thereby, over time, cause the bedrock aquifer level to.fall
below the critical capture point of all or part of the
groundwater extraction system. This drop in groundwater level
would make the system obsolete in a relatively short period of
time.
Response: This statement regarding the life of the groundwater
extraction system is difficult to agree or disagree with, since
the amount of leachate currently within the landfill and the
effectiveness of the cap is unknown. Extraction of groundwater
and leachate contaminated at levels seen in the vicinity of the
landfill, prior to its dispersion, is considered an effective
approach to reducing groundwater contamination in the bedrock
aquifer. Secondly, the evaluation of the present leachate
collection system identified large quantities of landfill
material to be saturated. This material is expected to generate
leachate for a period of time. The length of this period will be
dependent on the effectiveness of the cap, the amount of water
within the fill material, the driving head and the permeability
of fill and underlying materials. One of the extraction system's
objectives is to supplement the cap in depressing the water
table. It should be noted that many of the commentor's concerns
have been identified in the FS and incorporated in EPA's
decision. The selected remedial action recognizes some of these
outstanding issues by allowing for predesign work to help design
the groundwater extraction system.
PRETREATMENT
Comment: If alternative 13 is implemented (no pre-treatment) and
if it becomes necessary later to add pre-treatment, will leachate
continue to flow in the Andrew Avenue sewer during construction
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of the pre-treatment facilities, or would the leachate flow
freely into the unnamed brook along Andrew Avenue?
Response; If alternative #3 is implemented (no pre-treatment)
and pre-treatment is subsequently mandated, a decision regarding
the need to prevent leachate flow into the Andrew Avenue sewer
would be made based on the actual circumstances at that time.
The State of Connecticut DEP will maintain responsibility for
issuing and enforcing the pre-treatment operating permit. If it
becomes necessary to stop leachate flow from entering the Andrew
Avenue sewer, a system could be designed to prevent leachate from
running over the ground or into the unnamed brook.
Comment; What action will be taken if dioxin is detected in the
leachate, after completion of the landfill cap, when leachate is
disposed via the Andrew Avenue sewer to the Naugatuck Water
Pollution Control Plant?
Response; Presuming this would be in violation of the facilities
pre-treatment permit, issued by the State DEP, leachate flow to
the sewer would be stopped and controls would be installed to
prevent leachate flow to the unnamed stream or otherwise over
land. A treatment facility sufficient to comply with the State
of Connecticut DEP pre-treatment requirements could then be
designed and built on-site. Treatment technology is available
for dioxin removal from leachate, including for example, carbon
adsorption.
LEACHATE CONTROL AND TREATMENT
Comment; Will leachate that is discharged to the Rubber Avenue
Interceptor and West Side Interceptor have an adverse effect on
the integrity of the pipe and cause exfiltration from the Rubber
Avenue Interceptor?
Response; Discharge of leachate from the Laurel Park Landfill to
the Rubber Avenue interceptor is not expected to cause an adverse
impact on the integrity of the sewer system. The suitability of
the existing sewer system to convey leachate from Andrew Avenue
to the Naugatuck Waste Treatment Plant has been evaluated by EPA
and its contractors, Uniroyal and its contractors, and the
Borough of Naugatuck Water Pollution Control Board and its
engineers. No problems have been identified by these specialists
in the proposed design.
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Comment; What is the actual planned diameter for the proposed,
new Andrew Avenue sewer to be used to convey leachate from the
landfill to the existing Rubber Avenue sewer?
Response! The current planned diameter for the dedicated
leachate line in Andrew Avenue, described in Section 4.2.3.2.2 of
the Feasibility Study, is 6 inches. This is the actual internal
pipe diameter available to convey the flow. This pipe size will
be subject to review and revision by the Borough's Engineer
during the final design of the pipeline. According to
contractors for Uniroyal, as reported in a Public hearing
conducted by the Naugatuck Water Pollution Control Board on
May 5, 1988, the projected leachate flow from the Laurel Park
Landfill will occupy only 2.3 percent of the capacity of the
6-inch sewer line.
Will the effective diameter and capacity of the planned
Andrew Avenue sewer, to be used for conveyance of leachate, be
significantly reduced by the accumulation of sediment and gravel?
What would be the effect of sediment and gravel accumulation?
Responset It is unlikely that sand and gravel will accumulate in
the leachate line because it will be used only for leachate flow,
unlike some older sewers that also collect stormwater run-off (as
a source of sand and gravel). Further, steep s^oprs along Andrew
Avenue result in relatively high velocity flow which promotes
flushing of the lines. In addition, normal sewer maintenance
will include routine inspection and flushing, if needed, to
assure that no material accumulates in the pipe, restricting
flow.
Will a monitoring program be put in place to determine
if leaks develop over time in the sewer system that will convey
the leachate from the landfill to the Naugatuck Waste Treatment
Plant?
Response: Routine sewer maintenance normally evaluates pipeline
conditions including leakage.
Comment: Will the monitoring program include testing, after
completion of the remedial action, to assure th^t Uie water
quality of the unnamed brook is no longer being contaminated by
leachate or surface run-off?
Response: The monitoring program planned after completion of the
remedial action, as described in Section 4.2.1 of the Feasibility
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Study, will include analysis of surface water samples collected
from both the unnamed stream and Spruce Brook.
Comment; One commentor noted that the Town's Street
Superintendent has reservations about accessing the Andrew Avenue
leachate sewer for maintenance.
Response; There are a variety of occupational hazards associated
with maintenance activities on any sewer. One hazard is the
accumulation of toxic gases in the confined, unventilated space
characteristic of all sewers. These confined space hazards exist
whether or not leachate is included in the flow, and are well
documented by the Water Pollution Control Federation and the
Occupational Health and Safety Administration (OSHA). This
hazard is acknowledged and discussed in the Feasibility Study on
Page 4-62. Recognizing the potential hazards, appropriate health
and safety guidelines for sewer maintenance have been developed
by OSHA that are protective of human health. These guidelines
must be followed to perform routine maintenance activities on the
leachate sewer in Andrew Avenue in order to protect the health
and safety of maintenance workers.
REMEDIAL COSTS
Comment; What is the cost difference for the monitoring programs
planned for alternatives 2 and 3?
Response: The plan for monitoring after completion, described
in Section 4.2.1 of the Feasibility Study, is the same for all
alternatives. The feasibility study estimate of the annual cost
of the planned monitoring program is $131,700. The present worth
value of the planned monitoring program over 30 years -3
$1,241,500.
Comment; What is the true difference in cost between
alternatives 2 and 3?
Response; The Feasibility Study estimate for the cost of
construction for facilities associated with leachate and
groundwater treatment under alternative 2 is in excess of
$1,611,000.00 (in 1987 costs). The construction costs associated
with leachate and groundwater treatment in alternative 3 are
estimated in the Feasibility Study to be $200,000.00, a reduction
of more than $1,400,000.00 from the cost of implementing
alternative 2. In addition, the Feasibility Study states that
alternative 2 will cost $112,000.00 more per year to operate than
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alternative 3. (Note: All cost information is included in
Tables 4-12 and 4-13 of the Feasibility Study. Costs are
modified to reflect the current State position that no
pre-treatment facilities would be necessary for alternative 3.)
Comment; How much would a pre-treatment facility cost if it were
built at some time in the future, say in five year increments,
from five years to thirty years from now?
Response; It is not possible to project accurately the future
cost of pre-treatment facilities without defining what the
pre-treatment requirements would be. Assuming the pre-treatment
requirements are equivalent to those detailed in the Feasibility
Study, an inflation rate of 5% and a discount rate of 10%, the
present worth cost of pre-treatment for various times in the
future are:
Present Worth Cost
5 yrs. $1,086,600
10 yrs. 820,800
15 yrs. 620,100
20 yrs. 468,000
25 yrs. 353,900
30 yrs. 267,300
Comment; Residents should be reimbursed by the responsivble
parties and/or the cleanup fund for the water costs incurred by
connecting to the public water system.
Response: The waterline to be constructed under an agreement
between Uniroyal Chemical Company, the Borough of Naugatuck, and
the State of Connecticut will be installed and hooked up to the
homes of the residents at no cost to them. The waterline will
benefit these properties and will likely augment their value. It
is inappropriate for EPA to commit to any form of enforcement
action against potentially responsible parties or to any aspects
of a negotiated settlement, and premature to comment on any
contemplated enforcement action or the Agency's position in any
settlement negotiations.
B. PREFERRED ALTERNATIVE COMPARED TO OTHER SYSTEMS
A commentor asked a series of questions seeking
information on the existence of systems with components that
match those four 3 in both alternatives 2 and 3. The series
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includes questions relating to compliance with local codes; level
of public participation in the decision process that approved the
systems; .use of public sewers as components of the systems; air
pollution monitoring; existence of health studies connected to
the systems; dissemination of public information about the
systems; and inspection and maintenance schedules for the
systems.
Response; Installation of caps at landfills, collection of
leachate and extraction of groundwater are measures employed
nationally at hazardous waste sites. Under the Superfund
program, landfill caps have been included in 64 Records of
Decision (ROD) signed as of June 1, 1988. Leachate collection
systems are included in 41 of these RODs, while groundwater
extraction is a component of 26 of the RODs.
These landfill sites cover a wide spectrum of size, hazardous
waste content, hydrogeologic setting and locality. Remedial
actions are planned at each site in a manner that considers site
specific conditions. Of the 41 sites where RODs have been signed
that include systems for leachate collection, 11 use municipal
sewer systems to dispose wastewater, and four sites dispose
untreated leachate in this manner. A total of 22 RODs have been
signed to date that include some means of on-site leachate
treatment. All of the sites disposing untreated leachate into
municipal sewer systems are located in developed areas; three
sites are in New Jersey and one is in Minnesota.
The Superfund process is highly structured, and is implemented
consistently at all sites. Because each of the sites referenced
is a Superfund site, selection and implementation of remedies
that protect health and the environment, are cost-effective and
utilize permanent resolutions to the maximum practical extent is
rigorously and uniformly undertaken at each site. Prior to
completion and signing of a Record of Decision, all sites are
subject to the same project phases as Laurel Park, including: a
Remedial Investigation, a Feasibility Study and a public comment
period. Each of the sites with remedies similar to the Preferred
Alternative for Laurel Park, whether in whole or in part, evolved
from an evaluation of appropriate data, analysis of alternatives
and consideration of public comment.
Every Superfund site evaluation must consider all applicable and
appropriate requirements necessary to protect the public health,
welfare and the environment according to the National Contingency
Plan. As such, to the extent that Federal, State and local
requirements are applicable, relevant or appropriate,
consideration is given to these requirements during development
and evaluation of remedial action alternatives. The suitability
of the existing sewer system for conveying leachate from Laurel
Park included technical evaluations by engineers on behalf of the
Uniroyal, the EPA and the local municipal authority responsible
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for wastewater collection, conveyance and treatment. Similar
evaluations may have been made at the four Superfund sites where
this component is included in the remedial plan.
Regarding the dissemination of public information under
Superfund, all sites include several public comment periods where
documents such as Remedial Investigation Reports and Feasibility
Studies are made available for review by the public. In
addition, frequent public meetings, mailing of fact sheets to
interested parties, and other community relations activities are
important aspects of the Superfund program. In these ways, all
issues related to selected remedies for all sites are fully
presented for public consideration and comment.
Sewer maintenance is generally a local responsibility. The
Agency assumes no responsibility under the Superfund program for
the operation or maintenance of local facilities. Maintenance
procedures for such sewers remains the responsibility of local
authorities, despite the use of publicly owned sewers as
components of Superfund remedial actions.
C. MONITORING
Why does EPA not plan to install monitoring on the
southeast and northeast sides of the landfill after the cap is
installed?
Response : The monitoring program to be implemented after
completion of the remedial action has yet to be finalized. The
goal of this monitoring program will be to assess the
effectiveness of the remedy in achieving the program objectives
as defined in the "Record of Decision," including protection of
human health and the environment. For purposes of completing the
Feasibility Study, a monitoring program was developed (reference
Section 4.2.1) that includes analysis of samples from existing
monitoring wells on all sides of the landfill.
Comment; Why was well monitoring and sampling discontinued after
a priority pollutant scan failed to detect priority pollutants?
Response; The Monitoring Program discussed in this question is
provided for in the Stipulated Judgment of the Hartford Superior
Court, issued February 1, 1983, and approved by the Commissioner
of CT DEP by letter dated July 31, 1984. This Monitoring Program
is, therefore, separate from the EPA Superfund RI/FS rules.
However, page 4 of the Amended Monitoring Program states:
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"Pursuant to discussions at meeting held August 9, 1984, DEP
agrees, as to any parameter not found at any of the sampling
locations during the first quarter of sampling, analysis will
not be required in the second, third, and fourth quarters."
D. SECURITY FENCE
Comment t A number of commentors requested that a security fence
be installed around the perimeter of the site.
Response; The ROD includes security fencing as a component of
the remedial action. A perimeter fence is an independent design
and construction activity from the remainder of the remedial
action. As such it may occur on an independent schedule.
E. OFF-SITE CONTAMINATION
Comment; One commentor asked if the area northwest of the site
along Andrew Mountain Road from the crest of Andrew Mountain,
easterly to Long Meadowbrook Pond has been contaminated.
Response: It is our understanding chat the area of concern
mentioned in the comment is a wetland area approximately 2,000
feet northwest of the site at a similar elevation a 3 t>-e
landfill, just south of Andrew Mountain Road. In October 1985
the EPA Region I Water Quality Branch visited that area to
determine if the wetlands might be impacted by remedial
activities at the landfill. Observations from that visit
included: .
The wetland area is at least five acres in size
It is an extensive open water, scrub-shrub wetland
complex
Numerous animal "trails" were in evidence throughout
upland areas, and many deer tracks were seen
No surface water connections to the landfill area were
observed.
EPA concluded that because no surface water connections exist
between the landfill and the wetland, and because of the distance
between these areas, no impacts upon the wetland are anticipated
from proposed remedial activities at the landfill.
Comment; The water quality of Spruce Brook is currently being
affected by run-off from the landfill. Why is this happening
even though the landfill is closed?
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Response: The Remedial Investigation documented the presence of
volatile organic compounds and polyaromatic hydrocarbons (PAH) in
Spruce Brook and suggested that these contaminants may have
migrated from the Laurel Park Landfill. Likely sources include
surface run-off, leachate and groundwater seepage into the brook.
After capping of the landfill and completion of the leachate and
groundwater collection systems, it is anticipated that the
quality of Spruce Brook will be improved. As detailed in Section
4.2 of the Feasibility Study, Spruce Brook will be monitored
after completion of the remedial action in order to evaluate the
remedial effect on its water quality.
Comaentors provided descriptions of two off-site
dumping areas and photographs of an on-site area.
Response; EPA appreciates the photographs of the on-site area
and the information that was provided on the two additional
"dump1* sites in Naugatuck. That information has been provided to
the Superfund Support Section in EPA Region I. EPA will review
and investigate these potential hazardous waste sites.
F. ENDANGERMENT ASSESSMENT
Note: The comments and responses in this section are technical
in nature. A list of references cited in the responses may be
found at the end of this document in Attachment B.
Comment: in presenting what is depicted as both a likely and
"conservative" evaluation of exposure levels resulting from well
contamination, observed contamination "means" and "maximums" are
cited in the Feasibility Study, Endangerment Assessment. The
value of such data may be misleading. Leaching of material from
a waste site does not occur at a uniform rate; rather, material
leaches out in "pulses." These "pulses" occur when large
quantities of water are introduced into the aquifer, such as
during a heavy rainfall or the rapid melting of snow. This
increased amount of water leads to a temporary increase of
out-migration of material from the site and intermittently
elevated levels of leachate entering the aquifer. Thus, in the
absence of long-term monitoring and correlation with groundwater
conditions, the actual historic levels of contamination present
in the drinking water are only very crudely modeled by the
limited sampling of residential wells.
Response; The contaminant concentration in groundwater leaving
the Laurel Park Landfill site varies. This is due to variations
in the amount of water applied to the landfill by rain and
snowmelt and to the heterogeneity of the deposited material
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itself. Because this type of situation is very common at
hazardous waste sites, the Superfund Public Health Evaluation
Manual specifies that all risk calculations will be done twice,
with a "best estimate" and an "upper bound estimate" of the
contaminant concentrations. The Endangerment Assessment (EA) has
done this with its use of "means" and "maximums." The analytical
results are a sampling of possible results and the numbers used
are the "estimates," in the statistical sense. To arrive at a
better estimate of the true maximum would be an extremely
laborious task, requiring sampling at frequent intervals (1 hour,
5 minutes, perhaps less) for an extended period of time (weeks or
months) and taking great pains to ensure consistency over time of
the laboratory results. The biological effect estimates are
based on long-term (usually lifetime) average exposures. Using
the observed maximum assay values should provide an adequate
overestimate of the adverse effects in the absence of corrective
action.
Commentt Section 5.1.1 of the EA contains the second aspect of
the exposure estimation that is likely to have been incorrect.
In the section on non-drinking water use, airborne exposures as
the result of release of volatiles into the air were considered
to last for only twenty minutes, the length of a shower.
Andelman, (Science of the Total Environment, 1985;47:443-460),
has shown in a recent study that exposure resulting from
showering is likely to persist over a longer period of time. The
empirical measurements presented suggest that the EA data could
underestimate exposure from this source by as much as 10-fold.
Response; Andelman (1985a, 1985b) built a "scaled-down model
shower." He found that air concentrations of his model compound
(trichloroethene) had not reached equilibrium (maximum)
concentrations even after 80 minutes of continuous operation.
When water flow was shut off, air concentration decreased
approximately linearly, at a rate similar to the initial rate of
rise. Andelman's studies (1985a, 1985b) assumed an exposure rate
of 1 hour per week (less than 10 minutes per day) in the shower;
this produces (assuming complete absorption from both routes) an
intake quite similar to that from ingestion.
The Endangerment Assessment cites a later abstract by Andelman
(1986) as its sources for the values of 50 percent liberation of
dissolved chloroform and 80 percent liberation of dissolved
trichloroethene. However, the EA based its calculations on the
complete liberation of the dissolved chemicals. The EA
assumptions of room volume, water use and shower exposure (20
minutes/day), are within the "likely range" used by McKone and
are generally similar to the "representative values" used in
these extremely elaborate three-component model analyses. McKone
(1987) concluded that inhalation uptake of various volatile
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organic compounds, including two used by the EA, would be 1.5 to
6.0 times the ingestion uptake. In Malcolm Pirnie's
calculations, total shower inhalation intake was very similar to,
but slightly less than, total ingestion intake.
The U.S. EPA concludes that these variations in numerical results
are distinctions without a significant difference in risk. The
results of the EA are reasonable estimates of the shower
exposure. If the "true" risk from this one exposure were
underestimated by a factor of ten, this would bring the
conservative case risk estimates outside U.S. EPA's target range
of 10~4 to 10"', but the representative case and maximum
residential well data estimates would still be well within that
range.
Despite the implementation of a comprehensive
containment of the site (Alternatives 2 or 3), contamination of
some surface water may continue. This being the case, the result
would likely be an underestimate by the EPA of the level of
potential exposure to hazardous substances from surface water.
Response; U.S. EPA is unable to respond to this because it does
not identify a location or mechanism for surface water
contamination. All considered alternatives, except Alternative 1
(no action), include either collection and treatment of
contaminated leachate or elimination (by removal or treatment) of
the source of the leachate.
Comment; The cancer risk assessment as presented in the EA omits
several considerations that may have lead to a significant
underestimate of risk on which the FS is based. First, several
recent human epidemiologic studies dealing with the indicator
chemicals were ignored. A study by Isacson, et al. (Am J
Epidemiol 1985;121:856-869) observed increased risk of colon and
rectal cancer associated with 1,2 dichloroethane in the water
supply. The levels were estimated at greater than or equal to
0.1 ug/1. A study of a leukemia cluster in Wobum, Massachusetts
(Lagakos, et al.) (J. Am. Statis. Assoc. 1986;81:583-596) found
an association with well water contaminated with
trichloroethylene (267 ppb) and perchloroethylene (21 ppb).
While these two studies are far from conclusive, and most would
suggest quite controversial, they indicate that risks of cancer
from chlorinated hydrocarbons may be greater than the EA
estimates for the site.
Response: It is generally accepted by epidemiologists that
isolated epidemiologic studies are inadequate to determine
cause/effect relationships because they only show association.
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One authority (cited in Gambel and Battigelli, 1978) lists nine
criteria for determining cause and effect:
Association (probability)
Consistency (reproducibility in time and space)
Specificity (uniqueness)
Temporality
Biological gradient (dose/response effect)
Plausibility (biological possibility)
Coherence (biological compatibility)
Experimental verification
Analogy (biological extrapolation)
Determining cause/effect relationships requires multiple,
consistent studies (as with smoking). The only cases when the
necessary repetitions could be decreased would involve an
extremely rare (or even unique) effect, such as the peculiar
tumors (hepatic hemangiosarcomas in humans and rodents) produced
by vinyl chloride.
The Iowa study (Isacson and others, 1985) is a multiple
regression analysis of many types of cancer (at least 12 are
listed in the paper) and various chemicals (11 volatile organic
chemicals and 43 elements). A positive relationship between
cancer and 1,2-dichloroethane in drinking water was noted in
their study. There are over one thousand statistical
comparisons. Using the traditional critical probability level of
p = 0.05, one would expect that two or three chemicals (actually
0.05 times 54, the number of chemicals) would show a
statistically significant association with each type of cancer
considered if the entire data set is randomly distributed, that
is, if there are no real relationships at all. The actual
results of the study are rather similar to this assumption. The
most recent (March 1988) revision of the U.S. EPA's Integrated
Risk Information System (IRIS) file on 1,2-dichloroethane
includes no human data to support the carcinogenicity of this
compound.
The commentor states that the Woburn Study (Lagakos and others,
1986a) is "quite controversial." In fact, the published study is
followed immediately by a series of "Invited Comments" (MacMahon
and others, 1986) the same length as the basic article and by a
briefer "Rejoinder" (Lagakos and others, 1986b). The U.S. EPA
has little to add to those comments. The last one (by
Whittemore), for instance, applies the cause and effect criteria
listed above and finds the study lacking in all nine criteria.
Not mentioned by any commentator is the basic problem of the
distribution of a rare effect (such as childhood leukemia) in
relatively small population subgroups. If one takes a large
population (such as the United States) and divides it into groups
(the Woburn neighborhood that was studied and many thousands of
other, equal-size groups), the incidence of leukemia will vary
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between the groups, following a Poisson distribution. Most
neighborhoods will have no cases or one; a few will have many
cases. With more limited studies (such as the Alsea, Oregon,
miscarriage reports) this random distribution, alone, is an
adequate explanation for the "cluster." Lagakos and others
(1986a) did not provide the data for testing this hypothesis.
U.S. EPA concludes that these two epidemiological studies are
inadequate, in themselves, to modify the current risk estimators
used in the EA. Additional work, along the lines of the criteria
cited above, is necessary.
The EA relatively ignores chemicals such as chromium,
which are well demonstrated carcinogens. The rationalization is
that only inhalation is considered to be a demonstrated route of
exposure for chromium to act as a carcinogen; however, it is
clear that, just as volatile agents may enter the household air
through non-drinking uses of water, so may inorganic
particulates.
Response; The most recent, authoritative review (ATSDR, 1987)
notes that while low level inhalation exposure to hexavalent
chromium is well known to be carcinogenic to humans, there are no
reported human or animal carcinogenicity effects after oral
exposure.
The commentor suggested that groundwater may produce inorganic
particulates that could be inhaled. U.S. EPA notes that although
processes that produce inorganic, particulates from water
("spray-drying") are used industrially in various branches of the
chemical industry, the only possible household approximation
would be watering a lawn with a sprinkler on an extremely hot,
dry day. Such a process would be very incomplete, and the only
particulates would be of near-molecular dimension, since only the
smallest water droplets could evaporate fully. These ultrafine
particles are very poorly absorbed because they do not settle in
the respiratory tract. No such particulates would be produced in
a saturated atmosphere, such as a shower. Therefore, this
inhalation exposure is negligible, at most.
Comment! The assumption of the cancer risk being additive from
the different chemical exposures very likely results in an
underestimate of the overall cancer risk. The interaction of two
or more agents to greatly increase risks of c?n -er in excess of
additivity is well established. Perhaps the best known example
is the interaction of cigarette smoking and asbestos in the
production of lung cancer. Given the large number of proven and
suspect carcinogens present at the Laurel Park site, the
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likelihood of an interactive combination existing there appears
almost certain.
Response: Neither the EA nor U.S. EPA found any solid evidence
of interactions among the indicator chemicals, much less the
isobolograms required to quantitatively evaluate such an
interaction. Such data are available for a number of drug
combinations (such as sulfcnamides and folic acid reductase
inhibitors) but for very few other chemicals. In addition,
interactions may be negative (antagonistic) as well as positive
(synergistic). In fact, selenium, for one, is reported to cause
both sorts of interaction (Carson and others, 1986). Because of
these considerations, it is the general U.S. EPA policy to assume
additivity of both different chemicals and various exposure
routes (U.S. EPA, 1986, page 101).
G. GENERAL COMMENTS
Comment; EPA and Uniroyal have a vested interest in the
selection of the remedial action. EPA and Uniroyal have already
implemented or agreed to implement elements of the preferred
remedy the cost of which Uniroyal as a PRP will be required to
pay.
Response: These comments are argumentative and not founded on
fact. It is inappropriate and premature for EPA to comment on
the issue whether any particular person will be liable to pay the
cost of response actions. EPA and Uniroyal have not implemented
or agreed to implement any portion of the preferred remedial
action. EPA has no "vested interest" in the selection of the
remedial action, but is statutorily charged with responsibility
for the selection of the remedial action.
Comment: In its discussion of groundwater treatment technology,
the FS "double-counts the factors of economics and feasibility
based on the Safe Drinking Water Act (Maximum Contain.: nt
Levels)" to the detriment of the considerations of health and the
environment.
Response; The reference to "double counting" in this comment is
unclear. In analyzing remedial alternatives under CERCLA, EPA
does not "count" factors. Rather, as stated in the ROD, EPA
analyzes remedial alternatives in light of certain specified
criteria and is obligated to find that the selected remedial
action satisfies the requirements of CERCLA and, to the extent
practicable, the NCP. CERCLA specifically requires that the
selected remedial action must be protective of human health and
the environment, and must satisfy applicable or relevant and
appropriate statutory or regulatory requirements and must be cost
effective.
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The Superfund amendments disfavor off-site treatment.
However, because off-site-treatment is one. of the key elements of
the preferred alternative, EPA should provide a more persuasive-
justification for that selection than- the Feasibility Study does
now.
Response; CERCLA Section 121(b) states that remedial actions in
which treatment that permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances,
pollutants and contaminants is a principal element, are to be
preferred over remedial actions that do not involve such
treatment. The offsite transport and disposal [emphasis added]
of hazardous substances or contaminated materials without such
treatment should be the least favored alternative remedial action
where practicable treatment technologies are available.
Comment; One commentor stated that the issue of remedial
selection is a human rights issue and that on-site treatment of
leachate protects his "constitutional rights to life, liberty,
pursuit of happiness and quality of life."
Response; The commentor has not made clear the manner in which
the choice of a recommended remedial action implicates his
constitutional rights. EPA believes that its selected remedial
action does not infringe upon any of the commentor's
constitutionally guaranteed rights, especially any rights
traditionally considered to be human rights or civil rights, such
as equal protection of the laws and due process of law.
Comment; There appears to be no reference in the Feasibility
Study to the fact that dioxin has been detected in several
residential wells.
Response; Analytical data for the site are presented in the
Remedial Investigation Report. Interested parties may refer to
page 3-35 of the RI report for a discussion on the issue.
Supporting data is included in Appendix A of the RI.
Comment; One commentor expressed concern that radioactive waste
or nuclear waste might have been dumped in the landfill when
material from the Westport Landfill was transferred to Laurel
Park.
Response; There is no evidence of radioactive waste disposal at
Laurel Park based on the investigations performed to date. No
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evidence of radioactive waste has been noted by investigators in
the field. In addition, no records have been discovered that
document the disposal of.radioactive or nuclear waste at either
the Laurel Park or Westport Landfills. Westport public officials
are formally on the record with EPA declaring that no hazardous
waste was disposed in the Westport Landfill. The disposal of
radioactive waste is strictly regulated by the Nuclear Regulatory
Commission. It is unlikely that radioactive waste was disposed
of in the Westport Public Landfill.
Comment; Residents requested that the remedial package include a
long-term health effects study, a health registry and a health
surveillance program.
Response; CERCLA Section 104(i)(l) states that the Agency for
Toxic Substances and Disease Registry (ATSDR) shall "effectuate
and implement the health related authorities of this Act."
The ATSDR has performed a "health assessment" of the site as
required under Section 104(i)(6). If a pilot study of health
effects for selected groups is desired as discussed in Section
104(i)(7), the individual or group desiring such a pilot study
must petition the ATSDR directly for such a study.
Petitions should be sent to:
Barry Johnson, Ph.D.
Associate Director
CDC/ATSDR
1600 Clifton Rd., N.E.
Atlanta, GA 30333
Petitions should include:
The name, address and phone of a contact person
- Any information the petitioner feels is important,
including complaints, known or potential exposures,
nearby facilities or sites, and any symptoms.
The ATSDR will respond within ten working days of receipt of the
petition. It should be noted that the ATSDR will determine if
such a study is necessary, and if so, perform the pilot study.
Additionally, on the basis of the results of the pilot study,
health assessment, or other study, the ATSDR may decide it is
appropriate to conduct full scale epid-nniological or other
health studies as may be necessary to determine the health
effects on the population exposed.
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Because the NHPCF is owned by several potentially
responsible parties, as defined under CERCLA §107(a), and third
party defendants in The B.F. Goodrich Company v. Harold Murtha.
Civil Action No. N-87-52 (PCD), a citizen oversight committee
should determine when back-up measures should be implemented in
the case of failure of off-site treatment.
Response; This comment does not specify the connection between
naming the Borough of Naugatuck (the only owner of the NWPCF
known to EPA) as a third party defendant in the B.F. Goodrich
litigation and the need for a citizen oversight committee, nor
can EPA discern any such connection. If there were any need for
such a committee, EPA knows of no authority under which EPA could
require it. The NWPCF will be required by the State of
Connecticut to comply with the provisions of its NPDES permit.
In addition, a Pretreatment Permit which is also issued by the
the State of Connecticut is required to discharge to the sewer.
H. EXTENSION OF THE COMMENT PERIOD
Comme.nt1 EPA received two written requests and several verbal
requests to extend the public comment period to allow the
requestors to procure a Technical Assistance Grant (TAG) to
obtain assistance to comment on the Feasibility Study.
Response: EPA responded to these two requests directly in
writing copies may be found in the Administrative Record. EPA
denied these requests for an extension of the public comment
period. To extend the public comment period to allow processing
of the TAG Grant application would violate the Interim Final
Technical Assistance Grant regulations which state:
"The schedule for response activities at a site will not be
affected by the Technical Assistance Grant application
process."
Comment: Several commentors requested expedited treatment of the
TAG application.
Response: EPA also responded to this request in a letter dated
June 2, 1988. Once a complete application is received, EPA will
make every attempt to evaluate the application as quickly as
possible. EPA would like to point out that the process for
review and evaluation of technical assistance grant applications
and the procurement of a technical advisor must follow certain
steps as described in the TAG regulations and EPA's grant and
procurement regulations (40 CFR Parts 30 and 33, respectively).
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ATTACHMENT A
Community Relations Activities Conducted
at the Laurel Park. Inc. Superfund Site in
Nauaatuck. Connecticut
November, 1984 - EPA released a community relations
plan that described citizen concerns about the site, and
outlined a program to address those concerns and inform
and involve citizens in site activities during the
remedial phase.
June 6, 1985 - EPA held an informational public meeting
to describe the plans for the Remedial Investigation and
Feasibility Study.
November 13, 1985 - EPA held an informational public
meeting to discuss the Remedial Investigation progress
to date.
February 26, 1987 - EPA held an informational public
meeting to discuss and respond to questions concerning
the results of the Remedial Investigation and
Endangerment Assessment.
May 11, 1988 - EPA held an informational public meeting
to discuss cleanup alternatives presented in the
Feasibility Study and t'o present the Agency's proposed
plan.
May 12, 1988 through June 9, 1988 - EPA held a public
comment period to accept public comments on the
alternatives presented in the Feasibility Study, the
Proposed Plan, and all other documents previously
released to the public.
May 25, 1988 - EPA held a public hearing to accept oral
comments on the alternatives presented in the
Feasibility Study, the Proposed Plan, and all other
documents previously released to the public.
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ATTACHMENT B
References to Section III.F.
Endanaerment Assessment Responses
Agency for Toxic Substances and Disease Registry, 1987. Draft
Toxicoloaical Profile for Chromium.
Andelman, Julian B. and others, 1986. Volatilization of
Trichloroethylene and Chloroform from an Experimental Bath and
Shower System. NTIS PBS6 - 176120. Abstracts, 192nd American
Chemical Society Conference, September.
Andelman, Julian B., 1985a. Inhalation Exposure in the Home to
Volitile Organic Contaminants of Drinking Water. Sci. Total
Environ. 47:143-160.
Andelman, Julian B., 1985b. Human Exposure to Volatile
Halogenated Organic Chemicals in Indoor and Outdoor Air. Envir.
Health Perspec. 62:313-318.
Carson, Bonnie L., Harry V. Ellis III, and Joy L. McCann, 1986.
Toxicology and Biological Monitoring of Metals in Humans.
Chelsea, Michigan, Lewis Publishers.
Gamble, John F., and Mario C. Battigelli, 1978. Epidemiology, in
Patty's Industrial Hygiene and Toxicology. Third Revised
Edition, Volume I. New York, Macmillan.
Isacson, Peter, and others, 1985. Drinking Water and Cancer
Incidence in Iowa, III. Association of Cancer with Indices of
Contamination. J. Amer. statis. Assoc. 121:856-869.
Lagakos, S.W., B.J. Wessen, and M. Zelen, 1986a. Analysis of
Contaminated Well Water and Health Effects in Woburn,
Massachusetts. J. Amer. Statis. Assoc. 81:583-596.
Lagakos, S.W., B.J. Wessen, and M. Zelen, 1986b. Rejoinder. J.
Amer. Statis. Assoc. 81:611-614.
MacMahon, Brian, and others, 1986. Invited Comments. J. Amer.
Statis. Assoc. 86:597-610
Malcolm Pirnie, Inc., 1987. Endangerment Assessment, Laurel Park
Landfill, February.
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Maul, Mary Ann, 1988. Connecticut Fund for the Environment,
Inc., letter to Margaret Velie, U.S. EPA Region I, June 8.
McKone, Thomas E., 1987. Human Exposure to Volatile Organic
Compounds in Household Tap Water: The Indoor Inhalation Pathway.
Environ. Sci. Technol. 21:1194-1201
U.S. Environmental Protection Agency, 1986, Superfund Public
Health Evaluation Manual. EPA 540/1-86/060. OSWER Directive
9285.4-1.
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ROD DECISION SUMMARY Appendix B
Laurel Park. Inc.
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Laurel Park, Inc.
NPL Site Administrative Record
Index
As of June 29, 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 Laurel Park, Inc.
National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and
Section H cites guidance documents ased by EPA staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region Ts Office in Boston,
Massachusetts, and at the Howard Whittemore Memorial Library, 243 Church Street, Naugatuck,
Connecticut 06770. 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 Superrund Amendments and
Reauthorization Act (SARA).
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Section I
Site-Specific Documents
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Page 1
ADMINISTRATIVE RECORD INDEX
for the
Laurel Park, Inc. NPL Site
1.0 Pre-Remedial
1.2 Preliminary Assessment
1. "Preliminary Site Assessment," Ecology and Environment, Inc.
(February 27,1981).
3.0 Remedial Investigation (RI)
3.1 Correspondence
1. Letter from Matt Senweisberg, EPA Region I to Camille Connick, EPA Region I
(Octobers, 1985).
2. Letter from Merrill S. Hohman, EPA Region I to William F. Broden, Uniroyal
Chemical Company, Inc. (October 16,1986).
3. Letter from Susan H. Shumway, Uniroyal Chemical Company, Inc. to Merrill S.
Hohman, EPA Region I (October 22,1986).
3.2 Sampling and Analysis Data
The Sampling and Analysis Data for the Remedial Investigation (RI) may be reviewed,.
by appointment only, at EPA Region I, Boston, Massachusetts.
3.4 Interim Deliverables
1. "Remedial Action Master Plan," Camp Dresser & McKee Inc. (June 1983).
2. "Site Operations Plan," Malcolm Pirnie (June 1985).
3.6 Remedial Investigation (RI) Reports
1. "Draft Remedial Investigation Report," Malcolm Pirnie (August 1986).
2. "Remedial Investigation Report," Malcolm Pirnie (February 1987).
3.7 Work Plans and Progress Reports
1. "Remedial Investigation/Feasibility Study Work Plan," Malcolm Pimie
(May 1985).
3.9 Health Assessments
1. "Health Assessment for the Laurel Park Landfill," U.S. Department of Health and
Human Services, Agency for Toxic Substances and Disease Registry
(Dece~w-r 4,1986), including Addendum (May 11,1988).
3.10 Endangerment Assessments
1. "Draft Endangerment Assessment," Malcolm Pirnie (May 1986).
2. "Endangerment Assessment," Malcolm Pimie (February 1987).
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Page 2
4.0 Feasibility Study (FS)
4.1 Correspondence
1. Letter from Heather M. Ford, EPA Region I to William F. Broden, Uniroyal
Chemical Company, Inc. (March 27, 1987).
2. Letter from Edward K. McSweeney, EPA Region I to Ira Leighton, EPA Region I
(March 15,1988).
4.5 Applicable or Relevant and Appropriate Requirements (ARARs)
1. Letter from Heather M. Ford, EPA Region I to Edward Parker, State of
Connecticut Department of Environmental Protection (April 17,1987).
2. Cross-Reference: Set of Comments from Elsie B. Patton, State of Connecticut
Department of Environmental Protection on the February 1988 "Draft Feasibility
Study" (Set of Comments Dated March 14,1988). [Filed and cited as entry
number 1 in 4.6 Feasibility Study (FS) Reports].
4.6 Feasibility Study (FS) Reports
1. Set of Comments from Elsie B. Patton, State of Connecticut Department of
Environmental Protection en the February 1988 "Draft Feasibility Study" (Set of
Comments Dated March 14,1988).
2. "Feasibility Study," Malcolm Pirnie (May 1988).
Comments received during the public comment period on the Feasibility Study (FS)
Report are filed and cited in 4.9 Proposed Plans for Selected Remedial Action.
4.7 Work Plans and Progress Reports '
1. Cross-Reference: "Remedial Investigation/Feasibility Study Work Plan,"
Malcolm Pimie (May 1985) [Filed and cited as entry number 1 in 3.7 Work Plans
and Progress Reports].
4.9 Proposed Plans for Selected Remedial Action
1. "Proposed Plan for Remedial Action," EPA Region I (May 3,1988).
2. Set of Comments from Mary Anne Maul, Pollution Extermination Group,
Inc. on the May 1988 "Feasibility Study" and the May 3, 1988 "Proposed Plan for
Remedial Action" (Set of Comments Dated May 6,1988).
3. Transcript, Laurel Park, Inc. Public Hearing Commenting on the May 1988
"Feasibility Study" and the May 3, 1988 "Proposed Plan for Remedial Action"
(May 25, 1988).
4. Set of Comments from Ann Marie Klosenski on the May 1988 "Feasibility Study"
and the May 3,1988 "Proposed Plan for Remedial Action" (Set of Comments
Dated May 30,1988).
5. Set of Comments from Mary Lou Sharon, Pollution Extermination Group, Inc.
on the May 1988 "Feasibility Study" and the May 3,1988 "Proposed Plan for
Remedial Action" (Set of Comments Dated May 1988).
6. Response from Margaret Velie, EPA Region I on the May 6,1988 Set of
Comments from Mary Anne Maul, Pollution Extermination Group, Inc.
(Response Dated June 2,1988).
7. Set of Comments from Daisy Ostrander, Pollution Extermination Group, Inc.
on the May 1988 "Feasibility Study" and the May 3,1988 "Proposed Plan for
Remedial Action" (Set of Comments Dated June 6, 1988).
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Page 3
8. Set of Comments from Joseph J. Liebcrman, State of Connecticut Attorney
General on the May 1988 "Feasibility Study" and the May 3,1988 "Proposed
Plan for Remedial Action" (Set of Comments Dated June 6,1988).
9. Set of Comments from Daisy Ostrander and William F. Ostrander, Sr., Members
of the Public on the May 1988 "Feasibility Study" and the May 3,1988 "Proposed
Plan for Remedial Action" (Set of Comments Dated June 6,1988).
10. Set of Comments from Robert A. Smith, Jr., Uniroyal Chemical Company, Inc.
on the May 1988 "Feasibility Study" and the May 3,1988 "Proposed Plan for
Remedial Action" (Set of Comments Dated June 7,1988).
11. Set of Comments from Mary Anne Maul, Pollution Extermination Group, Inc. on
the May 1988 "Feasibility Study" and the May 3,1988 "Proposed Plan for
Remedial Action" (Set of Comments Dated June 8,1988).
12. Set of Comments from Robert X. Shuster, Member of the Public on the May 1988
"Feasibility Study" and the May 3,1988 "Proposed Plan for Remedial Action"
(Set of Comments Dated June 8,1988).
13. Response from Margaret Velie, EPA Region I on the June 8,1988 Set of
Comments from Robert X. Shuster, Member of the Public (Response Dated
June 21,1988).
14. Response from Mary H. Grealish, EPA Region I on the June 8,1988 Set of
Comments from Robert X. Shuster, Member of the Public (Response Dated
June 22,1988).
5.0 Record of Decision (ROD)
5.4 Record of Decision (ROD)
1. Record of Decision, EPA Region I (June 29,1988).
10.0 Enforcement
10.3 State and Local Enforcement Records
1. Letter from Elizabeth C. Barton, Laurel Park, Inc. to the Honorable John W.
Anderson, State of Connecticut Department of Environmental Protection
(April 16,1987).
10.7 Administrative Orders
1. Administrative Order, Uniroyal Chemical Company, Inc. and Laurel Park, Inc.
(May 16,1985).
2. Administrative Order, Uniroyal Chemical Company, Inc. and Laurel Park, Inc.
(June 16,1986).
3. Cross-Reference: Letter from Merrill S. Hohman, EPA Region I to William F.
Broden, Uniroyal Chemical Company, Inc. (October 16,1986) [Filed and cited as
entry number 2 in 3.1 Correspondence].
4. Cross-Reference: Letter from Susan H. Shumway, Uniroyal Chemical Company,
Inc. to Merrill S. Hohman, EPA Region I (October 22,1986) [Filed and cited as
entry number 3 in 3.1 Correspondence].
5. Administrative Consent Order, Uniroyal Chemical Company, Inc., State of
Connecticut, and the Borough of Naugatuck, Connecticut (May 27,1987).
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Page 4
10.9 Pleadings - Directly Related! to Trial (Current Enforcement Activity)
1. Complaint, United States of America v. Harold Murtha, Terrance Murtha, Murtha
Trucking, Inc., Murtha Enterprises, Inc., Murtha Waste Control Corporation,
Beacon Heights, Inc., and Laurel Park Inc., United States District Court for the
District of Connecticut, Civil Action No. N-87-74 (PCD) (March 3,1987).
2. Motion for Leave to Amend Pleading, The B.F. Goodrich Company et al., v.
Harold Murtha et al.; Uniroyal Chemical Company, Inc. v. Harold Murtha et
al.; United States of America v. Harold Murtha et al.; State of Connecticut v.
Harold Murtha et al. United States District Court for the District of Connecticut
Civil Action No. N-87-52,-67,-73, &-74 (PCD) (February 16,1988).
3. First Amended Complaint, United States of America v. Harold Murtha et al.,
United States District Court for the District of Connecticut, Civil Action No.
N-87-74 (PCD) (February 16,1988).
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
1. Cross Reference: Letter from Heather M. Ford, EPA Region I to William F.
Broden, Uniroyal Chemical Company, Inc. (March 27,1987) [Filed and cited as
entry number 1 in 4.1 Correspondence.
2. Master Notice Letter from EPA Region I to PRPs, with Attached List of"
Recipients (May 19,1988).
13.0 Community Relations
13.2 Community Relations Plans
1. "Community Relations Plan," NUS Corporation (June 1985).
13.3 News Clippings/Press Releases
1. "Environmental News Release," EPA Region I (May 20,1985).
2. "Environmental News Release," EPA Region I (October 28,1985).
3. "Environmental News Release," EPA Region I (February 13, 1987).
4. "Press Release," U.S. Department of Justice (March 3,1987).
5. "Environmental News Release," EPA Region I (June 3,1987).
6. "Environmental News Release," EPA Region I (May 2,1988).
13.4 Public Meetings
1. EPA Region I Meeting Agenda, Public Meeting (June 6, 1985).
2. EPA Region I Meeting Agenda, Public Meeting (November 13, 1985).
3. EPA Region I Meeting Agenda, Public Meeting (February 26, 1987).
4. EPA Region I Meeting Agenda, Public Meeting (May 11," 1988).
5. Cross Reference: Transcript, Laurel Park, Inc. Public Hearing Commenting on
the May 1988 "Feasibility Study" and the May 3,1988 "Proposed Plan for
Remedial Action" (May 25,1988) [Filed and cited as entry number 3 in 4.9
Feasibility Study (FS) Reports].
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PageS
13.5 Fact Sheets
1. "Laurel Park Landfill, Inc. Fact Sheet," EPA Region I (May 1985).
2. "Laurel Park Landfill - EPA Progress and Plans," EPA Region I (July 1986).
3. "Superfund Program Fact Sheet," EPA Region I (February 1987).
4. "Superfund Program Fact Sheet," EPA Region I (May 1988).
16.0 Natural Resource Trustee
16.1 Correspondence
1. Letter from Gordon E. Beckett, U.S. Department of the Interior to Margaret
Velie, EPA Region I (July 21,1987).
2. Letter from Kenneth Finkelstein, National Oceanic and Atmospheric
Administration to Margaret Velie, EPA Region I (September 18,1987).
16.4 Trustee Notification Form and Selection Guide
1. Letter from Merrill S. Hohman, EPA Region I to William Patterson, U.S.
Department of the Interior (June 12,1987).
2. Letter from Merrill S. Hohman, EPA Region I to Sharon Christopherson,
National Oceanic and Atmospheric Administration (June 12,1987).
17.0 Site Management Records
17.7 Reference Documents
The appendices for the records cited in entry numbers 2 and 4 may be reviewed, by
appointment only, at EPA Region I, Boston, Massachusetts.
1. "Hydrogeologic Report - Laurel Park Landfill - Relative to Abatement Order
Compliance," Fuss & O'Neill, Inc. (January 20,1982).
2. "Assessment of the Geology and Hydrogeology of the Laurel Park Landfill -
Volume I," Fred C. Hart Associates, Inc. (February 1983).
3. "Oxford Sewer Connection Study," Malcolm Pirnie (April 1985).
4. "Annual Monitoring Report," Fred C. Hart Associates, Inc. (October 1986).
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Section II
Guidance Documents
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Page 6
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EPA Guidance Documents
1. Comprehensive Environmental Response. Compensation, and Liability Act of 1980. amended
October 17,1986.
2. Memorandum from Gene Lucero to the U.S. Environmental Protection Agency,
August 28,1985 (discussing community relations at Superfund Enforcement sites).
3. Memorandum from J. Winston Porter, July 9,1987 (discussing interim guidance on
compliance with applicable or relevant and appropriate requirements).
4. "National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
Regulations (Tide 40, Part 300), 1985.
5. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-o),
September 1983.
6. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Handbook of Remedial Action at Waste Disposal Sites (EPA/625/6-85/006), October 1985.
7. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft
(lllidflnce on Remedial Actions for Contaminated Ground Water at Superfund Sites (OSWER
Directive 9283.1-2), September 20,1986.
8. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-1), October 1986.
9. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Ground-Water
Protection Strategy. August 1984.
10. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions. (OSWER Directive
9355.0-21), July 24,1987.
11. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Response.
Compensation, and Liability Act) (EPA/540/G-85/003), June 1985.
12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investigations under CERCLA ("Comprehensive Environmental
Response. Compensation, and Liability A^t) (EPA/54C, G-85/002), June 1985.
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24,1986.
14. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement The
Endangarment Assessment Handbook. August 1985.
15. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement. Toxicology
handbook. August 1985.
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Page?
16. U.S. Environmental Protection Agency. Office of Water and Waste Management. Evaluating
Cover Systems for Solid and Hazardous Waste. 1980. '
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ROD DECISION SUMMARY Appendix C
Laurel Park. Inc. .
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STATE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
June 24, 1988
Mr. Michael R. Deland
Regional Administrator
U.S. EPA Region I
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Deland:
I am writing to inform you that Connecticut has reviewed the draft Record
of Decision for the Laurel Park Landfill and concurs with the selected remedy.
I am looking forward to the implementation of remedial measures at this
site which as you know is the State's highest priority site on the National
Priority List.
Sincerely yours,
Leslie A. Carothers
Commissioner
LA:et
Phone:
165 Capitol Avenue Hartlorcl. Ci'i
An r.i/inil ' '/'/'""i'"''l I n-.i'li
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