United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/042
September 1989
&EPA
Superfund
Record of Decision
Auburn Road Landfill, NH
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-89/042
3. Recipient'* Acceulon No.
4. Tide ind Subtitle
SUPERFUND RECORD OF DECISION
Auburn Road Landfill, NH
Second Remedial Action - Final
5. Report Date
09/29/89
7. Author(s)
8. Performing Organization Rept No.
9. Performing Organization Name and Addret*
10. Proiect/TMk/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(O
12. Sponsoring Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street,' S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
IS. Supplementary Note*
16. Abstract (Limit: 200 word*)
The Auburn Road Landfill site consists of four former land disposal areas on 200 acres
of land in Londenderry, Rockingham County, New Hampshire. The four disposal areas,
referred to as the Old Town Dump (3 acres), the Tire Dump (4 acres), the Solid Waste Area
(6 acres), and the Septage Lagoon (1 acre), are sources of soil and ground water
contamination at the site. Land bordering the site is occupied primarily by private
"(residences, and includes wetlands, streams, and a pond. In 1979, after verifying that
industrial wastes were being disposed of at the site, the State prohibited further
disposal of drums. Since 1980, 69 monitoring wells have been installed and numerous test
pits have been excavated at the site. In 1986 EPA removed approximately 1,000 drums of
waste materials from the site, the majority being removed from the Old Town Dump area.
The first operable unit for the site was completed in December 1987, when all residences
identified as being potentially impacted by site ground water contamination were
connected to a local public water supply. Concurrently the site owner erected a
seven-foot high fence around the Old Town Dump, the Tire Dump, and the Solid Waste area.
A second drum removal was conducted in October 1988 when EPA removed 16 drums from the
Old Town Dump and 300 drums from the Tire Dump. This ROD represents the second and third
operable units for the site and includes ground water remediation and reducing residual
(See Attached Sheet)
NH
17. Document Analyala a. Descriptor*
Record of Decision - Auburn Road Landfill,
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE, PCE), metals (arsenic, lead)
b. Identifiers/OpeivEnded Terms
c. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Ctas* (This Page)
None
21. No. of Page*
168
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
Or IIONAL rOHM 272 (4*77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R01-89/042
Auburn Road Landfill, NH
Second Remedial Action - Final
16. Abstract (Continued)
soil contamination which is a contamination source to ground water. The primary
contaminants of concern affecting the soil and ground water are VOCs including benzene,
toluene, TCE, and PCE; and metals including arsenic and lead.
The selected remedial action for this site includes downgradient ground water pumping
and onsite treatment using chemical coagulation and precipitation to remove metal
contaminants and air stripping to remove VOCs, which will be collected in a vapor phase
carbon adsorption system, followed by onsite discharge to recharge trenches; ground water
monitoring; and placing a multilayered natural and synthetic cap over each source area.
The estimated present worth cost for this remedial action is $24,100,000, which includes
annual present worth O&M costs of $1,460,000.
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RECORD OF DECISION
Auburn Road Landfill
Londonderry, New Hampshire
STATEMENT OF PURPOSE
The Decision Document represents the selected remedial action for
the Auburn Road Landfill Site in Londonderry, New Hampshire,
developed in accordance with the Comprehensive Environmental
Response, Compensation and liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1966, and to the extent practicable, the National Oil and
Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300 et
sea.. as amended. The Region I Administrator has been delegated
the authority to approve this Record of Decision.
STATEMENT OF BASIS
This decision is based on the administrative record which has
been developed in accordance with Section 113 (k) of CERCLA and
which is available for public review at the Londonderry Public
Library in Londonderry, New Hampshire and at the Region I Waste
Management Division' Records Center in Boston, Massachusetts. 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 Auburn Road Landfill Site includes
both source control and management of migration (or groundwater
control) components to obtain a comprehensive remediation.
1. Management of Migration MM-2 (Operable Unit II)
The management of migration operable unit chosen, (MM-2), will
include groundwater collection and treatment. Groundwater will
be collected by using a combination of overburden and bedrock
wells and.overburden collection trenches. The collection system
will be designed to recover contaminated groundwater immediately
downgradient of each Site source area, along an established
compliance boundary and off-site, north of the Whispering Pines
Pond. Once extracted, groundwater will be treated through
physical processes, to meet Federal and State drinking water
standards prior to discharge to on-site recharge trenches located
away from the source areas.
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Contaminated groundwater will first be treated through chemical
coagulation and precipitation to remove inorganic compounds
(metals). Following treatment for the inorganics, the
groundwater will be pumped to an air stripping tower. Air
stripping removes organic contaminants from groundwater by
accelerating the volatilization process. The contaminated air
stream is then discharged to a vapor phase carbon adsorption unit
prior to atmospheric discharge. If, after the air stripping
process, the treated groundwater effluent still does not meet the
Federal and State drinking water standards, it will be discharged
to an activated carbon treatment unit for final treatment.
EPA has estimated that groundwater treatment will continue for
six to ten years. This treatment period will allow for treating
three to five complete pore volumes of groundwater from the
overburden and shallow bedrock aquifer. Quarterly groundwater
monitoring will be initiated during the remedial design phase and
will continue through the post-remediation period, both on and
o.ff-site, to track the effectiveness of the collection and
treatment process. The monitoring network will be established
during remedial design.
2. Source Control SC-2 (Operable Unit III)
The Source Control Operable Unit, (SC-2), will consist of placing
a natural and synthetic cap over the Town Dump, Tire Dump and
Solid Waste Area. This operable unit may be implemented
concurrently with groundwater treatment and will be accomplished
with only minimal disturbance of existing waste material. At a
minimum, this multilayered cap will consist of a vegetative
topsoil layer, a subsurface drainage layer, and a low
permeability layer (barrier) that will underlie the drainage
layer. The vegetative layer will consist of topsoil (loam) that
will support vegetation growth and facilitate drainage. This
layer will protect the cap through soil stabilization and erosion
control. Directly beneath the topsoil layer will be a layer of
sandy soil that will promote sub-drainage of infiltrating
precipitation and protect the underlying low-permeability layer.
A synthetic liner composed of a high-density polyethylene
material (HOPE) was chosen for the low-permeability layer.
Because the current topography of the Auburn Road Site is not
suitable for capping, grading and compaction will be required to
form a proper sub-base for the cap. The final slope will be
designed to remove surface irregularities, provide proper
drainage, -and prevent erosion. Grading of the Site will be
accomplished with little or no disturbance of buried wastes.
DECLARATION
The selected remedy is protective of human health and the
environment, attains federal and state requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effective. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
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element to reduce the toxicity, mobility, or volume of hazardous
substances-. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
Date
Paul G. Kejiugh, Acting
Regional Administrator
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TABLE OF CONTENTS
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY 4
A. Response History 4
B. Enforcement History 5
III. COMMUNITY RELATIONS 6
IV. SCOPE AND ROLE OF OPERABLE UNIT OR
RESPONSE ACTION 7
V. SITE CHARACTERISTICS 8
A. Soil 8
1. Town Dump 8
2. Tire Dump 9
3. Solid Waste Area 9
4. Septage Lagoon 10
B. Groundwater 11
C. Surface Water 12
D. Air 13
VI. Summary of Site Risks . 13
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES ... 14
VIII. DEVELOPMENT AND SCREENING OF
ALTERNATIVES 16
A. Statutory Requirements/Response
Objectives 16
Groundwater 17
Soil 17
B. Technology and Alternative Development
and Screening 17
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS OF ALTERNATIVES 20
A. Source Control (SC) Alternatives
Analyzed 20
SC-1: No Action 20
SC-2: In Situ Closure of all Source
Areas 21
SC-3: On-Site Incineration/Capping
Solid Waste Area/On-Site Landfill . 21
SC-4: Excavation of all source
areas? On-Site Low-Temperature Thermal
Stripping(LTTS)/On-Site Landfill . . 24
SC-5: Excavation of all source
areas? On-Site Incineration and
On-Site Landfill 25
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SC-6: Excavation all source areas;
Off-Site Treatment and
Off-Site Disposal 26
SC-7: Excavation of all source
areas; Aerobic Soil Composting
and On-Site Landfill 27
B. Management of Migration (MM)
Alternatives Analyzed 29
MM-1: No Action 29
MM-2: Groundvater Extraction; On-
Site Treatment and On-Site
Discharge 31
MM-3: Groundvater Extraction;
On-Site Pretreatment with Off-Site
Treatment and Disposal 31
X. THE SELECTED REMEDY 33
A. Description of the Selected Remedy 33
1. Remedial Action Objectives/Cleanup
Goals 33
2. Description of Remedial Components .... 36
B. Rationale for Selection 42
1. Management of Migration 43
2. Source Control 44
XI. STATUTORY DETERMINATIONS 44
A. The Selected Remedy is Protective of
Human Health and the Environment 46
B. The Selected Remedy Attains ARARs 47
C. The Selected Remedial Action is Cost
Effective 50
D. The Selected Remedial Action Utilizes
Permanent Solutions and Alternative
Treatment Technologies or Resource
Recovery Technologies to the Maximum
Extent Practicable 50
E. The Selected Remedy Satisfies the
Preference for Treatment as a Principal
Element 51
XII. STATE ROLE 51
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - STATE CONCURRENCE
APPENDIX C - ADMINISTRATIVE RECORD INDEX
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LIST OF FIGURES
Page
Figure 1-1 Location Map 2
Figure 1-2 Site Map 3
Figure IX-1 Typical Landfill
Cross-Section 23
Figure X-l Location of Extraction
Wells & Trenches 37
Figure X-2 Cap Cross Section 41
LIST OF TABLES
Page
Table VIII-1 Alternatives 19
Table X-l Cleanup Goals 35
Table X-2 Cost Comparison 45
Table XI-1 ARARs Tables 48
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ROD Summary
Auburn Road Landfill
ROD DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
SITE NAME: Auburn Road Landfill Site
SITE LOCATION: Town of Londonderry, Rockingham County, New
Hampshire
SITE DESCRIPTION:
The Auburn Road Landfill Site ("the Site") is located in the
northeast corner of the Town of Londonderry, New Hampshire
(Figure 1-1). The Site consists of approximately 200 acres
on which four disposal areas containing hazardous substances
have been identified. The Old Town Dump, which is the
oldest of the four source areas, consists of approximately
three acres. The next oldest area is the Tire Dump which is
approximately four acres followed by the Solid Waste area
and Septage Lagoon which are approximately six acres and one
acre, respectively.
The study area is approximately bounded by Auburn Road to
the west, Old Derry Road to the south, State Highway 28
Bypass to the east, and the Londonderry-Auburn town line to
the north. Figure 1-2 depicts the general location of the
study area of the Site.
There are numerous hills and mounds on and around the Site.
Surface waters in the vicinity of the Site are numerous and
varied (wetlands, three streams, one pond). Several brooks
and streams drain the local area and flow in a general
north, northeast direction through the Site. The unnamed
brook on the eastern side of the Site joins with another
unnamed brook that flows through the center of the Site.
Downstream of this confluence, the stream flows to the north
where a concrete dam has been installed, causing this stream
to form the Whispering Pines Pond. The outflow of this pond
passes though a sluice and several culverts until it
discharges into Cohas Brook. Cohas Brook flows from the
northeast toward the Site until it joins with the discharge
from the pond. From this point, Cohas Brook flows to the
northwest. This meandering brook is often slow flowing with
a swampy shoreline.
j
Located in the northeastern portion of the study area is the
Whispering Pines Mobile Home Park. The perimeter of the
Site is surrounded to the south, east, and west by private
residences.
A more detailed description of the Site can be found in
Chapters 1 and 3 of the Remedial Investigation (RI) Report
prepared by NUS Corporation (NUS) dated April 10, 1989.
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KALE
Mnrr
FIGURE 1-1
AUBURN ROAD
LANDFILL SITE
LONDONDERRY, NEW HAMPSHIRE
•ME MAP IS A POmOM OF T>C UA.C4. OCMTT, IM
QUAMANOU ?J KNES. IM«
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AUBURN ROAD
LANOTLL SITE
SITE MAP
Figure 1-2
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ROD Summary
Auburn Road Landfill
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
In August 1979, an investigation by the State of Mew Hampshire
substantiated suspicions that industrial wastes were being
disposed of on the Site and the State ordered that no more drums
be accepted for disposal at the Site.
In 1981, an EPA contractor, Ecology and Environment, Inc. (EtE),
prepared a "Preliminary Site Assessment for the Auburn Road
Landfill* which concluded that the Site could contain hazardous
wastes and recommended further study to confirm this conclusion.
In 1982, E&E performed a hydrogeologic investigation of the Site
to further define the presence and extent of groundwater
contamination. Based on a Mitre Hazard Ranking System (HRS)
score of 36.6 and the Site proposed for listing in the National
Priority List (NPL) in December 1982, and was formally included
in the NPL in September 1983, ranking 383 out of 416 Sites.
Previous studies of the Site include several hydrogeologic
investigations/Site assessments, a neighborhood health survey, a
medical epidemiological review of that survey, and numerous
analytical testing rounds conducted by public agencies and
private consultants.
The most extensive work on-site has been conducted since 1980. A
total of 69 monitoring wells (some of which have clusters of
wells screened at multiple depths) have been installed and
numerous test pits have been excavated at the Site. In 1984, EPA
engaged NUS to conduct a RI and a Focused Feasibility Study
(FFS). The NUS RI involved additional well installations, test
pit excavations, sampling, and geophysical surveys, and was
reported in an RI report dated April 10, 1986. In November 1986,
EPA issued an Endangerment Assessment (EA) for public review.
The EA evaluated Site conditions and estimated the potential
present and future risks to human health and the environment
posed by the Site.
During the months of May and June 1986, the EPA Environmental
Services Division (ESD) commenced a removal action of drummed
materials and wastes from the four source areas on-site. During
the removal action, EPA ESD conducted test pit excavations in
each of the source areas in search of buried drums. As a result,
approximately 1,900 drums were removed from the Site, the
majority of which were removed from the Town Dump area.
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ROD Summary
Auburn Road Landfill
In 1987, all homes identified as potentially being impacted by
groundwater contamination from the Site, including the Whispering
Pines Mobile Home Park, were connected to the Manchester Water
Works public water supply. This action was taken based on a
First Operable Unit Record of Decision issued by EPA on September
17, 1986, and was carried out by the Town of Londonderry under an
Administrative Order issued on February 24, 1987. Also under
EPA's Administrative Order, the Site owner erected a seven-foot
high fence was erected around the Town Dump, the Tire Dump and
the Solid Waste Area.
During the latter half of 1987, a Supplemental RI was performed
for EPA by Roy F. Weston, Inc. (Weston). The objective of this
Supplemental RI study was to acquire data that would augment and
update previously accumulated data, particularly those data
included in the NUS RI Report.
During October 1988, EPA conducted a second drum removal
operation at the Tire Dump and Town Dump. At that time, 16 drums
were removed from the Town Dump, and approximately 300 drums were
removed from the central part of the Tire Dump. The drum removal
areas were designated based on the results of additional
geophysical testing and test pit excavation performed by Weston
as part of the Supplemental RI.
A more detailed description of the Site history can be found in
Chapter 1 of the NUS RI Report on Pages 1-2 and 1-7 through 1-16.
On July 10, 1989, EPA entered into a Consent Order with eleven
potentially responsible parties (PRPs) which authorized the PRPs
to obtain a new round of groundwater sampling from all wells that
could be sampled at the Site. The PRPs contracted with Canonie
Environmental of Indiana (Canonie), to conduct the groundwater
sampling, analyze the samples and prepare a report. Canonie's
"Final Report of the Remedial Action Assessment Investigation"
was presented to EPA on August 14, 1989, and is included in the
Administrative Record for the Site.
B. Enforcement History
From 1984 to the present, EPA has been conducting an ongoing
investigation to identify parties who are liable for response
costs at the Site. In this regard, EPA has issued approximately
200 information requests, employed private investigators,
conducted numerous interviews, and reviewed a multitude of
records. At various times throughout the duration of this
project, as information became available, parties who EPA
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ROD Summary
Auburn Road Landfill
determined' either owned or operated the Site, generated wastes
that were sent to the Site, arranged for disposal of hazardous
substances at the Site or transported hazardous substances -to the
Site, were notified of their potential liability with respect to
the Site. To date, 21 parties have been notified.
III. COMMUNITY RELATIONS
Throughout the Site's history, community concern and involvement
has been high. EPA has kept the community and other interested
parties apprised of the Site activities through informational
meetings, fact sheets, press releases and public meetings.
In June 1984, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved during remedial activities.
On. June 28, 1984, EPA held an informational meeting at the
Londonderry Junior High School to describe the plans for the RI
and FS. Other meetings held for the Site include:
May 21, 19E5 - Informational meeting to discuss progress on
the RI
April 30, 1986 - Informational meeting to discuss results of
the RI
July 30, 1986 - Informational meeting to discuss the FFS
August 6, 1986 - Public meeting to receive comments on the
FFS
•
October 27, 1987 - Informational meeting to discuss the
Supplemental RI
September 27, 1988 - Informational meeting to discuss second
barrel removal action
March 22, 1989 - Informational meeting to discuss the FS
results and EPA's Proposed Plan
March 30, 1989 - Second informational meeting for those
people who could not attend the March 22nd meeting
.*
April 25, 1989 - Public Meeting to receive comments on the
FS and Proposed Plan
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ROD Summary
Auburn Road Landfill
On March I?, 1989, EPA made the Administrative Record available
at the Leach Public Library in Londonderry, New Hampshire. The
Agency, published a notice and brief analysis of the Proposed Plan
in the Derry News, Nashua Telegraph and Manchester Union Leader
on March 17, 1989.
From March 31, 1989 to May 5, 1989, the Agency held a public
comment period to accept comments on the alternatives presented
in the FS and the Proposed Plan and on any other documents
previously released to the public. This comment period was
extended to May 18, 1989, at the request of a number of PRPs. On
April 25, 1989, the Agency held a public meeting, which was
transcribed, to accept any oral comments. The transcript of this
meeting, a summary of the oral and written comments submitted and
EPA's responses to those comments are included in the attached
responsiveness summary (Appendix A).
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining a source control
alternative and a management of migration alternative, which,
together with the First Operable Unit, result in a comprehensive
approach for Site remediation. The First Operable Unit, a
waterline, was completed in December 1987. The remaining
remediation entails two additional operable units. The Second
Operable Unit consists of installing overburden and bedrock
extraction wells and/or trenches at the Town Dump, Tire Dump and
Solid Waste Areas to collect contaminated groundwater from
beneath each of these source areas. A series of overburden and
bedrock extraction wells will also be installed to capture
contaminated groundwater migrating off the Site toward Cohas.
Brook (Fig. X-l). Collected groundwater will be treated by means
of metal precipitation, air stripping and, if necessary carbon
adsorption. The need for carbon adsorption as well as the sizing
of other various treatment units will be determined based on
treatability studies and a pilot plant study to be conducted
during remedial design. Treated groundwater will be returned to
recharge trenches located within the Site property boundary.
The Third Operable Unit consists of constructing a multi-layered
cap over the Town Dump, Tire Dump and Solid Waste Area. The
Septage Lagoon Waste Mound will be consolidated with the Solid
Waste Area, and the two areas capped as one. The caps will be
constructed in compliance with Federal and New Hampshire State
hazardous waste landfill requirements for closure.
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ROD Summary
Auburn Road Landfill
V. SITE'CHARACTERISTICS
Chapter 1 of the FS contains an overview of the Supplemental RI.
The significant findings of the Supplemental RI are summarized
below.
A. Soil
The RI Report and Supplemental RI Report identified four areas of
soil contamination at the Site. During the Supplemental RI, 34
•oil samples were collected from test pits for analysis of the
Hazardous Substance List (HSL) volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), pesticides/ PCBs, and
inorganic compounds.
1. Town Dump
Analytical findings of soil samples collected in the Town
Dump detected the presence of 14 VOCs. Overall, the level
of VOC contamination in the Town Dump soil was lower than
that reported in the NUS RI. This could be due in part to
the drum removal actions which took place in 1986 and 1988.
The EPA ESD removed approximately 1,300 drums from the Town
Dump in 1986, and an additional 16 drums were removed during
the October 1988 removal operation.
There were 5 Semi-Volatile Organic Compounds (SVOCs) found
above the method detection limits in the nine test pit soil
samples collected in the Town Dump. The five compounds
which were detected are dimethyl phthalate, fluoranthene,
butylbenzyl phthalate, 4-methylphenol, and bis(2-ethylhexyl)
phthalate. No trend of SVOC distribution was evident from
the analytical data and contaminant levels were lower than
those reported by NUS (10 April 1986).
One pesticide, 4,4-DDD, was detected in one Town Dump soil
sample. Two PCBs, Aroclor 1248 and Aroclor 1254, were found
in trace concentrations in test pit soil samples. The PCBs
were found in soil samples collected from test pits located
in the north central area of the Town Dump.
Inorganic constituents were generally detected at levels
above background. The maximum concentration of beryllium,
nickel and lead were detected at the Town Dump. In this
area as well as other source areas, aluminum, calcium, iron,
manganese, and magnesium were found at levels exceeding
background conditions.
8
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ROD Summary
Auburn Road Landfill
2. Tire Dump
All ten soil samples collected from test pits in the Tire
Dump, with the exception of one, shoved levels of Total VOC
(TVOC) contamination of less than 17 parts per billion
(ppb). In the one test pit (TP-30) where the level of TVOC
exceeded 17 ppb, buried drums were uncovered. The discovery
of these buried drums prompted the second removal action,
which took place in October 1988, and resulted in the
removal of approximately 300 drums.
There vere 16 SVOCs found in Tire Dump soil samples at
quantifiable levels above the method detection limits. The
SVOCs included fluoranthene, pyrene, acenapthene, fluorene,
phenanthrene, benzo(a)anthracene, chrysene, benzo(b)-
fluoranthene, benzo(a)pyrene, ideno(l,2,3-cd)pyrene,
benzo(gfh,i)perylene, butylbenzyl phthalate, di-n-octyl
phthalate, n-nitrosodimethylamine, and 4-methylphenol. The
concentration of SVOCs in test pit soil samples varied from
not detected (ND) to 131,821 ppb (in TP-31). There were 12
semivolatiles detected at maximum concentrations in the soil
sample from TP-31, which is located in the north-central
portion of the Tire Dump.
No pesticides were detected in soil samples collected in
Tire Dump test pits. PCS Aroclor 1248 was detected in soil
samples from three of the ten test pits in the Tire Dump.
These test pits are located in the southwest portion of the
Tire Dump.
Inorganics that exceeded background levels were detected in
only two of the ten soil samples. In these two soil samples
(TP-27 and TP-28), inorganic compounds exceeding background
levels included zinc and lead. Test pits TP-27 and TP-28
are located in the southwest corner of the Tire Dump.
Material excavated in these two test pits included tires,
plastic, metal shavings, and metal moldings.
3. Solid Waste Area
VOCs vere detected in soil samples from each of the ten test
pits dug in the Solid Waste Area. VOCs were found at the
highest levels in test pits located in the northern portion
of this landfill. In this area, the total VOC concentration
in soil samples ranged from 1,704 ppb in TP-12 to 854 ppb in
TP-25, with an average concentration of 1,335 ppb for all of
the test pit samples. VOCs in these samples were primarily
ethylbenzene, 2-butanone, and 2-hexanone. Soil samples from
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ROD Summary
Auburn Road Landfill
test'pits in the southern portion of the landfill (TP-6,
TP-7, TP-8, TP-9, TP-10, and TP-11) had VOCs detected at
concentrations ranging from 20 ppb in TP-6 to 765 ppb in
TP-11, with an average concentration of 227 ppb for all of
the test pit samples in this area. The maximum
concentration of VOCs in these test pit samples was
2-hexanone, acetone, 2-butanone, xylene, and toluene.
Three SVOCs were measured above detection limits in Solid
Waste Landfill test pit soil samples. These compounds were
di-n-butyl phthalate, di-n-octyl phthalate, and butylbenzyl
phthalate. Di-n-butyl phthalate was detected in all ten
test pit soil samples, except one ( TP-26). Di-n-octyl
phthalate was found above the detection limit in samples
collected in three out of ten test pits.
Endosulfan I, a pesticide, was found in one soil sample
(TP-25), and PCB Aroclor 1260 was also found in one soil
sample (TP-24). Both TP-24 and TP-25 are located at the
north end of the landfill.
4. Septage Lagoon
As reported by NUS (10 April 1986), a composite surface soil
sample from the Septage Lagoon portion of the Septage Lagoon
area was found to have no detectable VOCs. A waste mound is
located adjacent to the Septage Lagoon containing
approximately 5,000 cubic yards of household debris, demo-
lition debris, tires, plastic, cloth, and sand. This waste
mound is considered a component of the Solid Waste Landfill
(which is located less than 100 feet west of the mound) in
all discussions in this ROD.
VOCs found in Septage Lagoon Test Pit (TP) soil samples were
at low levels (less than 100 ug/kg) and included xylenes
(TP-3), styrene (TP-4), and toluene (TP-4). TP-3 and TP-4
are located on the waste mound. No VOCs were detected in
soil samples from TP-1, TP-2, located in the former septage
lagoon, and TP-5, located in the waste mound.
Five SVOCs were detected in test pit soil samples. The
semivolatile compounds include di-n-butyl phthalate,
butylbenzyl phthalate, di-n-octyl phthalate, diethyl
phthalate, and phenanthrene. Di-n-butyl phthalate was found
in soil samples from six test pits, at concentrations
ranging from 1,500 ug/kg to 4,200 ug/kg. The presence of
the other semivolatiles was sporadic. Butylbenzyl phthalate
was detected in only one test pit, TP-2, at a concentration
10
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ROD Summary
Auburn Road Landfill
of 2,200 ug/kg. Di-n-octyl phthalate was found in 2 test
pits at concentrations ranging from 73 to 1,100 ug/kg.
Diethyl phthalate was found at concentrations of 420 and 110
ug/kg. Soil sample TP-3 contained 37 ug/kg of phenanthrene.
Lindane was detected at a concentration of 290 ug/kg in the
soil sample from TP-4.
With the exception of arsenic, no suspected carcinogenic
inorganic compounds were detected in Septage Lagoon soil
samples. Arsenic was found in each test pit, at
concentrations ranging from 1 to 2.6 mg/kg. Calcium, lead,
thallium, and vanadium were also found above background
levels in at least two soil samples.
B. Groundwater
As part of the Supplemental RI, groundwater samples were
collected from 47 wells, located throughout the Site as well as
in off-site locations near the Whispering Pines Ponds and Cohas
Brook, in August 1987. All wells were sampled and analyzed for
the Hazardous Substance List (HSL) VOCs. Selected wells were
sampled for HSL semivolatiles, pesticides/PCBs, and inorganic
compounds. Also, in response to comments provided by the public
and Potentially Responsible Parties (PRPs) on the Proposed Plan,
EPA authorized the PRPs to obtain a new round of groundwater
sampling from all wells that could be sampled at the Site. This
new round of sampling was conducted under a Consent Order, issued
on July 10, 1989. Results of this latest sampling round, as well
as other data collected under the Consent Order, are presented in
a report prepared by Canonie Environmental (Canonie) and entitled
"Final Report Of The Remedial Action Assessment Investigation
Auburn Road Landfill Superfund Site," (RAAI), dated August 1989.
These data represent the most current characterization of
groundwater quality at the Site.
Currently, the overall contaminant concentration at the Site
appears to be lower than that reported by NUS in April 1986, and
in the Supplemental RI. VOC contaminants presently exceeding
U.S. EPA Maximum Contaminant Levels (MCLs) include
trichloroethene, tetrachloroethylene, 2-Butanone, 1,2-
Dichloropropane, 1,2-Dichloroethylene, 1,1,1-Trichloroethane, and
vinyl chloride. There were 14 SVOCs detected in groundwater
samples obtained during the 1987 sampling round, including
4-nitroaniline, which is a suspected carcinogen. The
semivolatile compound found at the highest concentration (by an
order of magnitude) was benzoic acid. No trends of semivolatile
compound distribution are evident from the database. No
pesticides-were detected in groundwater samples. There were 21
11
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ROD Summary
Auburn Road Landfill
inorganic compounds detected in groundvater at the Site during
the 1987 sampling round. Of the three suspected carcinogenic
inorganic compounds detected (arsenic, beryllium, and nickel),
only arsenic was found at levels exceeding the U.S. EPA MCL in
both the 1987 and 1989 sampling round. Information regarding
background water quality can be found in the MUS report (10 April
1986).
Two primary plumes are evident at the Site (Figure 4-2,
Supplemental RJ Report). These plumes are based on VOC
distribution. A central plume originates in the Solid Waste
Landfill and trends northward, toward the WUS-1 well cluster. A
western plume likely originates in the Town Dump and also trends
northward. These two plumes merge in the vicinity of the NUS-2
well cluster. Secondarily, an arsenic central plume mimics the
areal geometry of the VOCs central plume. VOC concentrations
have become lower in the vicinity of the Solid Waste Landfill and
become higher downgradient, at the NUS-1 well cluster, suggesting
that the plume has migrated to the north. Based on EPA's
interpretation of data presented in the Canonie RAAI, the Central
Plume, as described in the Supplemental RI, is still
identifiable, although recent measurements of contaminant
concentrations appear to have decreased somewhat at the southern
end of the plume. This plume, as demonstrated by the RAAI data
and data from previous studies, occurs primarily in deep
overburden/weathered bedrock and not primarily in bedrock as
described by Canonie.
A complete description of the Site characteristics can be found
in Chapter 4 of the Supplemental RI Report.
t
C. Surface Water
The NUS RI included a surface water investigation to determine
the presence or absence of contamination in the unnamed brooks
on-site as well as the Whispering Pines Pond and Cohas Brook.
Surface water and sediment samples were collected and analyzed.
Results of the analysis indicate that the surface waters and
sediments on and adjacent to the Site are contaminated with low
levels (less than 20 ppb) of VOCs. The EA characterized the
risks associated with exposure to these contaminants at the
levels detected to be insignificant.
12
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ROD Summary
Auburn Road Landfill
D. Air
Ambient air monitoring was performed on three separate occasions
during the RI performed by NUS. Results of the air monitoring
showed that very low levels (less than 16 ppb) of VOCs were
detected on or near the Site. As characterized in the EA, the
levels of air contamination detected pose no threat to either
children or adults from inhalation of contaminants directly or
through inhalation of dust from the Site.
VI. Summary of Site Risks
In November 1986, EPA issued the EA for this Site. The EA was
performed to determine the present and future potential risks to
public health and the environment posed by the Site, based on
ex.isting conditions. Seventeen contaminants of concern were
selected for evaluation in the EA. These contaminants
constitute a representative subset of the more than 80
contaminants identified at the Site during the RI. The seventeen
contaminants were selected to represent potential on-site hazards
based on toxicity, level of contamination, frequency of
detection, and mobility and persistence in the environment.
Potential human health effects associated with the contaminants
of concern in soils and groundwater 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 fqr
exposure to hazardous substances based on the characteristic uses
and location of the Site.
The EA concluded that risks from exposure to contaminants from
the Auburn Road Site were, for the most part, low to minimal.
Exceptions to this conclusion included direct contact and
subsequent ingestion of subsurface soils in the Town Dump, Tire
Dump and Solid Waste Area and ingestion of contaminated
groundwater. Since completion of the EA, two removal actions
were completed, resulting in the removal of approximately 2200
barrels of waste from the Site. In addition, a fence has been
installed around each source area to prevent public access and a
waterline has been installed along Auburn Road to replace the
water supplies for the Whispering Pines Mobile Home Park and the
residences along Auburn Road. In order to assess current
conditions at the Site, the results of soil and groundwater
sampling conducted during the Supplemental RI were evaluated and
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ROD Summary
Auburn Road Landfill
new risk palculations performed in the FS (Appendix B). Based on
this data/ the risks associated with direct contact and
subsequent ingestion of contaminated subsurface soils is no
longer a threat. However, ingestion of contaminated groundwater
•till represents a major risk. This is not a current risk as
potentially affected residences have been supplied with an
alternative drinking water source. The remedial response
•elected here is based upon the revised risk calculations
presented in Appendix B of the FS.
A complete discussion of the Site risks can be found in Chapter 9
of the EA and Appendix B of the FS.
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA adopted a proposed plan for remediation of the Site on March
17, 1989. The management of migration portion of the preferred
alternative included installation of groundwater extraction wells
and trenches on and off-site; a groundwater treatment facility
consisting of metal precipitation, air-stripping and carbon
adsorption, if necessary; recirculation of a portion of the
treated groundwater and applying it back on to areas in the Tire
Dump and Solid Waste Area to promote flushing of residual soil
contamination; and discharge of the major portion of the treated
groundwater to recharge trenches located on-site. The source
control portion of the preferred alternative included
consolidation of the Septage Lagoon Waste Mound with the Solid
Waste Area; shredding all on-site tires and placing them on the
Tire Dump; and placing a multi-layered cap over the Town Dump,
Tire Dump and Solid Waste Area once groundwater cleanup goals are
attained.
•
The remedy proposed in this Record of Decision is essentially the
same as the remedy presented in EPA's Proposed Plan. However,
based on comments received during the comment period, and new
data presented in the RAAI, some minor changes to the Proposed
Plan have been made.
The proposed remedy provided for returning a portion of the
treated groundwater to the Solid Waste Landfill and to the
section of the Tire Dump where the 1988 drum removal was
performed. The intent was to try to flush contaminants from the
soils to the groundwater where it would be collected and treated.
This would, have constituted nothing more than accelerating the
natural flushing which presently occurs. However, in
consideration of comments received during the comment period, and
upon further review of flushing techniques as applied to the
14
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ROD Summary
Auburn Road Landfill
Site, EPA has concluded that the effectiveness of flushing
contaminants at the Solid Waste Landfill is questionable, due to
the types of materials located in the area, the proximity of the
debris to bedrock and the difficulty in controlling leachate.
Accordingly, flushing of contaminants at the Solid Waste Landfill
has been eliminated from the selected remedy. Flushing is still
considered a viable option at the Tire Dump, where none of the
above concerns apply. However, based on the most recent
groundwater sampling conducted during the RAAI, groundwater
contamination emanating from the Tire Dump no longer appears to
warrant flushing of contaminants from the soils to aid in
groundwater cleanup. Therefore, flushing of soils at the Tire
Dump has also been eliminated. Consequently, since capping of
the Site was to be postponed until completion of soil flushing,
and flushing of soils is no longer recommended, capping of the
waste areas can now be performed concurrently with groundwater
remediation.
Also, based on EPA's interpretation of the RAAI groundwater
results, a revised collection and treatment scheme was developed
and is presented in the Technical Oversight of PRPs Remedial
Action Assessment Investigation prepared by Weston and dated
September 1989 (Weston Response to RAAI). The number of
extraction wells and length of extraction trenches has been
reduced. Additionally, due to the fact that the highest levels
of contamination were found in either the deep overburden or
weathered bedrock, the overburden recovery wells have now been
assumed to be screened only in the bottom 10 feet of the
overburden and the bedrock recovery wells only in the top 15 feet
of the bedrock. This is in contrast to the deeper screenings
conceptually proposed in the FS. Finally, the groundwater
extraction rate has now been assumed to be 190 gallons per minute
(gpm) as opposed to the 275 gpm presented in the FS and Proposed
Plan.
Calculated costs, using the revised collection and treatment
system, are presented in the Weston Response to the RAAI. For
costing purposes, it has now been assumed that the wells near
Whispering Pines Pond will be pumped for a minimum of three years
and that total pumping time for all recovery wells will require
no more than ten years. Under these assumptions the total cost,
including capping, would range from $17.3 million to $20.6
million. This cost is lower than EPA's previous estimates of
$23.1 million as presented in the FS and Proposed Plan, but is
within the limits of the sensitivity analysis presented in the
FS. Since the actual number of and depth of extraction wells and
trenches will not be finally determined until Remedial Design,
15
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ROD Summary
Auburn Road Landfill
cost* carried through this ROD will be as presented in the FS
with the acknowledgement that these costs are conservative.
Finally, the compliance boundary, as shown in Figure 4-18 of the
FS, is now extended south along the unnamed brook and additional
extraction veils between the Solid Waste Area and the unnamed
brook are proposed. This is to insure that contaminated
groundwater from the Solid Haste Area, the Eastern Plume depicted
in the RAAI, meets EPA's cleanup goals prior to reaching the
unnamed brook.
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 CERCLA as enacted in 1980, and the revised National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300 (1988), promulgated in the Federal Register on November
20, 1985. Although EPA proposed revisions on December 21, 1988,
to the NCP to reflect SARA, until those proposed revisions are
finalized, the procedures and standards for responding to
releases of hazardous substances, pollutants and contaminants
•hall 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 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 sig-
nificantly, 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.
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ROD Summary
Auburn Road Landfill
A number of potential exposure pathways were analyzed for risk
and threats to public health and the environment in the EA and
the FS. Guidelines in the Superfund Public Health Evaluation
Manual (EPA, 1986) regarding development of 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:
Groundvater
To reduce potential present and future public health risks
from ingestion of contaminated groundwater.
To reduce potential present and future environmental risks
to aquatic and terrestial wildlife from exposure to the
groundwater which has migrated to the surface waters.
Soil
To reduce potential present and future public health risks
from ingestion of contaminated soil.
B. Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents, including "Guidance
on Feasibility Studies Under CERCLA" dated June 1985, 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) and the Interim Final "Guidance for
Conducting RIs and FSs under CERCLA," OSWER Directive No. 9355.3-
01, set forth the process by which remedial actions are evaluated
and selected. In accordance with these requirements and guidance
documents, a range of treatment alternatives, including a
containment option involving little or no treatment and a no
action alternative were developed for the Site.
Section 121(b)(l) 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 of CERCLA, 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
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ROD Summary
Auburn Road Landfill
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. Xmplenentability.
6. Community Acceptance.
7;~ State Acceptance.
8. Cost.
9. Overall Protection of Human Health and the Environment.
Chapter 3, Section 3.1 of the FS identified, assessed and
screened technologies based on waste-limiting (waste
characteristics that limit the effectiveness or feasibility of a
technology) and site-limiting (site characteristics, such as a
high water table, that preclude the use of a technology) factors
unique to the Site, and the level of technical development for
each technology. These technologies were combined into source
control (SC) and management of migration (MM) alternatives.
Chapter 3, Section 3.2 of the FS 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
alternatives for further detailed analysis while preserving a
range of options. Each alternative was then evaluated and
screened in Chapter 4 of the FS. In summary, of the 24 source
control and management of migration remedial alternatives
screened in Chapter 3, 10 were retained for detailed analysis.
Table VIII-1 identifies the 10 alternatives that were retained
through the screening process. Table 3-5 and 3-8 in the FS
identify the 24 alternatives that were retained through the
screening process, as well as those that were eliminated from
further consideration.
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ROD Summary
Auburn Road Landfill
Table VIII-1
Source Control and Management of Migration Alternatives
Auburn Road Landfill
SC-1 No Action
SC-2 In situ closure of all source areas.
SC-3 In situ closure of Solid Waste Landfill.
Excavation of Tire Dump and Town Dump source areas.
On-site incineration of selected Tire Dump and Town
Dump soil and wastes.
On-site landfill of ash and non-treated soil and
wastes.
SC-4 Excavation of all source areas.
Low Temperature Thermal Stripping (LTTS) of Town Dump
soil and soil requiring treatment from other source
areas.
On-site landfill of non-treated soil and wastes, and
treated soil.
Off-site treatment of nonvolatile soil and wastes
requiring treatment.
SC-5 Excavation of all source areas.
On-site incineration of selected soil and wastes.
On-site landfill of ash and non-treated soil and
wastes.
SC-6 Excavation of all source areas.
Off-site treatment and/or disposal of all excavated
soils and wastes.
SC-7 Excavation of all source areas.
Composting/aeration treatment of excavated soil.
On-site landfill of excavated wastes and treated soil.
MM-1 No Action
MM-2 Groundwater recovery, on-site treatment and discharge
to on-site recharge trenches.
MM-3 Groundwater recovery, on-site pretreatment and
discharge to off-site POTW.
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ROD summary
Auburn Road Landfill
IX. .DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
•ach alternative according to the evaluation criteria described
above. A tabular assessment of each alternative can be found in
Tables 4-1 through 4-10 of the FS.
A. Source Control (SC) Alternatives Analyzed
The source, control alternatives analyzed for the Site include a
minimal no action alternative (SC-1); one containment by capping
alternative (SC-2); four alternatives combining treatment by
either thermal destruction or composting followed by containment
by landfilling (SC-3, 4, 5 and 7); and one off-site treatment and
disposal alternative (SC-6).
No Action
The No Action alternative for the Auburn Road Site is limited to
fencing and long-term monitoring. No treatment of the source
waste is involved. Therefore, the environmental fate and removal
of contaminants found at the Site would be dependent on the
dynamics of natural transport mechanisms. The degradation
mechanisms that are relevant to the Auburn Road Site are
volatilization and leaching.
The three source areas have already been fenced with seven-foot
high fence. The fenced areas would be off-limits to all people
other than those authorized to take samples for monitoring
purposes. The fences would be repaired to prevent unauthorized
access. Keys to the gate to the overall Site would be available
to the Site owners and regulatory authorities.
Barren source areas would be seeded to control dust and de-
crease infiltration of contaminants to groundwater. This con-
trol would be effected once the seeds sprouted and the ensuing
vegetative growth covered these barren areas. These areas in-
clude part of the Tire Dump and most of the Town Dump.
Institutional controls would be implemented to limit future Site
use. The entire Site would be designated as a solid waste
facility thereby preventing future Site development.
In addition, a multimedia monitoring program (including air,
surface water, and groundwater sampling) would be conducted at
.the Site to evaluate potential exposure routes from the Site to
specific receptors.
20
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ROD Summary
Auburn Road Landfill
Although easily implementable, the No Action Alternative will not
comply with ARARs. By allowing residual soil contamination,
particularly VOCs and SVOCs, to continue to leach slowly from the
soils to the groundwater beneath each source area, Federal and
State groundwater and drinking water standards would not be met.
In addition, EPA's Ground Water Protection Strategy, which is a
factor to be considered, and the New Hampshire Ground Water
Protection Regulations would not be met. Except for preventing
direct contact with contaminated soils, this alternative would
provide no protection of human health and the environment.
A detailed assessment of this alternative can be found on Pages
4-48 through 4-55 of the FS.
Estimated Time For Design & Construction 15 to 18 months
Estimated Time For Operation 30 years
Estimated Capital Cost $240,000
Estimated O & M Cost(Present Worth) $2,150,000
Estimated Total Cost(Present Worth) $2,390,000
SC-2;In Situ Closure of all Source Areas
Under this alternative, a cap would be placed over each dispos-
al area, with only minimal disturbance of source material and no
excavation. For closure of the Auburn Road site, a multilayered
cap system would be installed that would, at a minimum, consist
of a vegetative topsoil layer, a subsurface drainage layer, and a
low permeability layer (barrier) that would underlie the drainage
layer. SC-2 was ulimately adopted as the source control
component of the remedy and is described in more detail in
Section X of this document.
Estimated Time For Design & Construction 1 year
Estimated Time For Operation 30 years
Estimated Capital Cost $5,100,000
Estimated O t M Cost(Present Worth) $2,400,000
Estimated Total Cost(Present Worth) $7,500,000
SC-3; On-Site Incineration/Capping
Solid Waste Area/On-Site Landfill
Like SC-2, this alternative entails in situ closure (capping) of
the Solid Waste Landfill. As distinct from SC-2, this
alternative includes excavation of both the Town Dump and Tire
Dump, and then either on-site incineration or on-site landfilling
of the excavated soils and wastes. The determination of whether
21
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ROD Summary
Auburn Road Landfill
the excavated material would be incinerated or placed directly in
an on-site landfill would be made on the basis of whether the
waste.is subject to RCRA Land Disposal Restrictions (40 CFR 268).
Hastes or soils which contain leachable organics or inorganics
would require treatment prior to placement in a landfill. The
procedures required to implement this alternative would include
excavation, transportation, hauling, incineration, landfill
construction, and site restoration.
For purposes of this alternative, the Solid Haste Landfill would
be capped due to the type of waste (primarily household) observed
in the test pits, the low levels of indicator chemicals detected
in soils, and the need to comply with Federal and Mew Hampshire
requirements for closure of a hazardous waste unit.
Approximately 220,000 square feet of capping would be required.
See Subsection 4.2.2 of the FS for a description of the capping
process.
Approximately 125,000 cubic yards of material containing solid
wastes, tires, and soil would be excavated. Test-pit data show
that some of this material may be contaminated with VOCs, SVOCs,
and pesticides and PCBs (at low concentrations). Of this total
excavated volume, some solid wastes may have to be incinerated
with the hazardous substances, depending on the level of
contamination of that solid waste.
Excavation, sampling and analysis, incineration, and landfill-
ing would proceed at a rate determined primarily by incinerator
capacity. A large mobile incinerator (300 cubic yards/day cap-
acity) would need 2 years to treat the anticipated volume of
wastes (56,000 cubic yards) which may require incineration.
Excavation would cease when the level of soil contamination •
remaining was below the level that would produce groundwater
concentrations that exceed the groundwater target cleanup levels
(Ref. Table 2-6 of the FS). This would be determined by sampling
of unexcavated soils.
An on-site landfill capable of handling approximately 110,000
cubic yards of material would be required to dispose of solidi-
fied incinerator ash and material not needing treatment. The
on-site landfill would be constructed in accordance with the
current Federal and state laws and regulations. At a minimum,
the landfill would include a double-liner system with a leachate
collection> storage, and treatment system; a leak-detection
system; a multilayered final cover (cap); surface drainage
controls; and a network of groundwater monitoring wells. A
typical landfill cross-section is shown in Figure IX-1.
22
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INTERMEDIATE COVER
WITH GAS COLLECTION
SYSTEM
PREPARED
SUBGRAOE
MULTI-LAY
1SEE FIQUR
S.HW.T.
\
LEACMATE COLLECTION/ \
LEAK DETECTION PIPING \
\
\
\
\
r
"? SAND
/
*"" ' • * ^-
"1 SAND
^ SAND
\
GEOTEXTILE FABRIC
DRAINAGE NET
• «0MIL HOPE
Q
C
i-l
0)
TYPICAL SECTION
NOT TO SCALE
RCRA LANDFILL
(ALTERNATIVES SC-3.SC-4.SC-5)
DOUBLE-LINER SYSTEM
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ROD Summary
Auburn Road Landfill
This alternative could easily be implemented as equipment needed
is readily available. This alternative would result in a
reduction of toxicity and volume of the wastes on-site. It- would
also provide a high degree of protection for human health and the
environment as well as attain all ARARs. However, the cost of
this alternative is approximately five times greater than
alternative SC-2.
A detailed assessment of this alternative can be found on Pages
4-67 through 4-82 of the FS.
Estimated Time For Design & Construction 2 years
Estimated Time For Treatment Operation 2 years
Estimated Capital Cost $38,000,000
Estimated O & M Cost (Present Worth) $3,200,000
Estimated Total Cost (Present Worth) $41,200,000
SC-4; Excavation of all source areas;
On-Sitc Low-Temperature Thermal
Stri in f LTTS 1 /On-Site
In this alternative, all source areas would be excavated,
selected soils would be treated on-site, soils and wastes would
be landfilled on-site, and if necessary, soils and certain small
volumes of wastes would be treated and disposed of off -site. The
on-site treatment for soils would be the Low-Temperature Thermal
Stripping (LTTS) process.
Approximately 240,000 cubic yards of materials would be excavated
from the source areas. An estimated 40,000 cubic yards of
contaminated soils would be treated in the LTTS unit. The same
criteria as discussed for Alternative SC-3 would be used to
determine which soils and wastes would need treatment. All
treated and untreated soils and wastes would be placed in an
on-site landfill built to Federal and State standards (See Figure
IX-1) . Clean soil would be transported to the Site to backfill
the excavated areas.
During the preliminary design phase, contaminated soils from the
Auburn Road Site would be used in a pilot plant test to deter-
mine the operating conditions and the efficiency of the LTTS
process. The primary contaminants found in the soils at the Site
have been removed effectively with this process at other sites.
At full-scale operation, the LTTS system would process approxi-
mately 60 cubic yards of soil during a 10-hour day. The proc-
essing rate would be partly determined by the soil moisture
24
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ROD Summary
Auburn Road Landfill
content. The operation would be completed within 4 years after
startup, if the facility operated on a single 10-hour shift and
had a staff of 7 to 10 full-time personnel.
Implementability of this alternative is good as the type of
equipment necessary is readily available. Implementation of this
alternative would also result in a reduction of toxicity but not
necessarily volume as contrasted with SC-3. This alternative is
in compliance with all ARARs and would also provide a high level
of protection of human health and the environment. The cost of
this alternative is approximately $9 million less than
alternative SC-3 but 4 times greater than SC-2.
A detailed assessment of this alternative can be found on Pages
4-82 through 4-94 of the FS.
Estimated Time For Design & Construction 2 years
Estimated Time For Treatment Operation 4 years
Estimated Capital Cost $31,300,000
Estimated O & M Cost(Present Worth) $1,400,000
Estimated Total Cost(Present Worth) $32,700,000
SC-5: Excavation of all source areas;
On-Site Incineration and On-Site
Landfill
As with Alternative SC-4, in this alternative, all source areas
would be excavated. The excavated material would then be sampled
and analyzed. Based on that analysis, these materials would .be
either incinerated or landfilled on-site. Incineration would
destroy the organic compounds in the contaminated soils and
wastes. Approximately 240,000 cubic yards of materials
(containing solid wastes, tires, and soil) would be excavated.
Data from test pit samples indicate that some of the soil and
waste may be contaminated with VOCs and SVOCs which may require
treatment to meet current land disposal requirements. Of the
approximately 80,000 cubic yards that may require on-site
incineration, 50,000 cubic yards of ash would be generated, which
would be landfilled in accordance with Federal and state
regulations. The incinerator ash and remaining volume of
excavated materials (approximately 160,000 cubic yards total)
would be placed in an on-site landfill as described for
Alternative SC-4.
Excavation, sampling and analysis, incineration, and landfill-
ing would proceed at a pace limited primarily by incinerator
capacity throughput. A large mobile incinerator (300 cubic
25
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ROD Summary
Auburn Road Landfill
yards/day capacity) would require 2 years to treat 80,000 cubic
yards of contaminated materials.
This alternative is equivalent to alternatives SC-3 and SC-4 in
terms of implementation and compliance with ARARs. However, this
alternative would provide a greater reduction in toxicity and
volume than either SC-3 or SC-4. This alternative would also
provide a high degree of protection of public health and the
environment. The total cost of this alternative is approximately
$21 million more than SC-4, $12 million more than SC-3 and $46
million more than SC-2.
A detailed assessment of this alternative can be found on Pages
4-94 through 4-99 of the FS.
Estimated Time Tor Design & Construction 2 years
Estimated Time For Treatment Operation 2 years
Estimated Capital Cost $52,200,000
Estimated O i M Cost(Present Worth) $1,400,000
Estimated Total Cost(Present Worth) $53,600,000
SC-6; Excavation all source areas?
Off-Site Treatment and
Off-Site Disposal
In this alternative, contaminated soil and other wastes would be
excavated, dewatered, sampled and analyzed, containerized, and
transported off-site, without pretreatment, to a Treatment,
Storage, and Disposal facility (TSD) in compliance with Federal
and State laws and regulations. Any soils not requiring off-site
treatment (i.e., not subject to land disposal restrictions) would
be transported directly to a RCRA landfill for disposal. Final
site restoration would include grading and backfilling with
on-site materials.
•
Backhoes and earth-moving equipment would be required, as would
trucks, laboratory and administration trailers and equipment, and
health and safety equipment.
Waste and soil characteristics would be determined to ensure
appropriate methods of handling, transportation, and disposal.
Excavated materials would be transported in compliance with ap-
plicable Federal and State regulations. All vehicles would be
carefully loaded, secured, and decontaminated to prevent contami-
nation of public areas.
26
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ROD Summary
Auburn Road Landfill
An appropriate accessible TSD facility in compliance with Federal
and State laws and regulations would need to be identified with
sufficient capacity to accept the large waste quantity. The
facility must also be able to accept solid wastes, tires, and
other debris, and soils containing metals and organic compounds.
This alternative would treat or properly manage soil and wastes
(240,000 cubic yards) contaminated with VOCs, extractable
organics, and inorganics from all three source areas. Experience
with this technology shows that approximately 800 cubic yards/day
could be excavated, field-analyzed, and transported to a TSD
facility. At this rate, excavation and backfilling would require
approximately 2 years.
Since all wastes would be removed from the Site, this alternative
would meet all ARARs and would provide the highest long term
effectiveness of all alternatives evaluated. It would also
provide for the greatest reduction of toxicity, mobility and
volume at the Site. However, locating a disposal facility which
could accept the large volume of waste from the Site could be
very difficult, making this alternative difficult to implement.
While this alternative would provide the greatest long term
protection of public health and the environment, short term
protection of public health and the environment would be low due
to increased truck traffic along Auburn Road and the potential
for an accident involving a truck hauling hazardous materials.
The total cost of this alternative also greatly exceeds that of
any of the other alternatives evaluated.
A detailed assessment of this alternative can be found on Pages
4-100 through 4-107 of the FS.
Estimated Time For Design £ Construction 2 years
Estimated Time For Operation 2 years
Estimated Capital Cost $190,100,000
Estimated O & M Cost (Present Worth) $0
Estimated Total Cost(Present Worth) $190,100,000
SC-7; Excavation of all source areas;
Aerobic Soil Composting and On-Site
Landfill
In this alternative, source areas would be excavated, a select-
ed quantity of soil and waste vould be treated and landfilled
on-site, and a lesser quantity of soil and waste would be treated
and disposed of off-site. On-site treatment would be aerobic
composting. On-site disposal would be in a landfill as described
for alternative SC-3. Off-site treatment and disposal would be
27
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ROD Summary
Auburn Road Landfill
at a treatment, storage, and disposal (TSD) facility in
compliance with Federal and State lavs and regulations.
Approximately 240,000 cubic yards of solid wastes and soils would
be excavated. Based on the results of previous test pit
excavations, it is estimated that approximately 50 percent of
this material would be solid wastes and the remainder soil.
Approximately 40,000 cubic yards of contaminated soil may require
treatment prior to disposal in an on-site landfill.
Excavation and staging, sampling and chemical analysis, separa-
tion of soil from solid wastes, and construction of an on-site
landfill would be performed as described for Alternative SC-4.
The primary difference between this alternative and Alternative
SC-4 is the method of treating contaminated soil.
Aerobic composting would be performed in a 400-foot by 100-foot
building to control potential atmospheric VOC emissions and to
permit year-round operation. Due to the volume of contaminated
soil to be treated (40,000 cubic yards) and the time required to
adequately treat the soil, the soil treatment (at a rate of
approximately 28 cubic yards per day) would require approxi-
mately 5 years. A commercially-available sludge composting
process would be adapted to treat the contaminated soils. An
aerobic process was selected because it would provide more rapid
biodegradation, better generation and control of biological
activity and heat, and additional VOC removal during the aeration
and mixing processes.
The Auburn Road facility would consist of 10 composting bays.
Contaminated soil would be deposited daily into the mixing area.
It would be combined with a bulking agent at a volume ratio of 2
to 1. The bulking agent would provide increased porosity and
nutrients to the soil. Suitable bulking agents would be horse
and/or cow manure; inorganic nutrients and straw or grains could
also be used.
As with alternative SC-3, SC-4 and SC-5, this alternative is
relatively easy to implement and would be designed and operated
to meet all ARARs. This alternative would provide some reduction
in toxicity although to a lesser degree compared with other
alternatives. Because of the need to add other materials such as
manures, straw or wood chips to improve the composting
efficiency', the total volume of material for landfill disposal
would be greater than with other alternatives. Implementation of
this alternative would be as protective of public health and the
environment as alternatives SC-3, SC-4 and SC-5. The total cost
of this alternative is estimated to be less than the cost for
28
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ROD Summary
Auburn Road Landfill
alternative SC-3, SC-5 and SC-6, but approximately four times
greater than SC-2.
A detailed assessment of this alternative can be found on Pages
4-107 through 4-119 of the FS.
Estimated Time For Design & Construction 2 years
Estimated Time For Treatment Operation 5 years
Estimated Capital Cost $28,400,000
Estimated O 4 M Cost(Present Worth) $1,400,000
Estimated Total Cost(Present Worth) $29,800,000
B. Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
Site, contaminants have combined with groundwater and migrated
from the Town Dump, Tire Dump and Solid Waste Areas generally in
a northerly direction. The contaminated groundwater has moved
beyond the Site's northerly property boundary, under Whispering
Pines Pond and toward Cohas Brook. The management of migration
alternatives evaluated for the Site include a minimal no action
with monitoring alternative (MM-1), an alternative consisting of
groundwater extraction, treatment and on-site discharge (MM-2),
and an alternative consisting of groundwater extraction,
treatment and discharge to a Publicly Owned Wastewater Treatment
Works (MM-3).
MM-1; No Action
In this alternative, groundwater and surface water would be '
monitored. To date, contaminant concentrations that exceed ARARs
have not been detected in surface water downgradient of the Site.
However, if levels of contaminants exceeding ARARs were detected
in Cohas Brook or Whispering Pines Pond, these exposure Routes
and associated risks and potential impacts on aquatic life would
be assessed and remedial actions considered.
Since contaminants would continue to migrate from the Site to
potential human and environmental receptors, three types of water
quality monitoring would occur; i.e., groundwater monitoring,
surface-water monitoring, and residential well monitoring.
• Groundwater Monitoring — On-site wells would be
monitored in accordance with the selected source
control alternative. Off-site wells would be used
29
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ROD Summary
Auburn Road Landfill
to monitor off-sit* contaminant migration.
Additional on-site and off-site monitoring wells
would be installed if determined necessary for an
effective monitoring program.
• Surface-Water Monitoring — Both Cohas Brook and
the brooX flowing into Whispering Pines Pond would
be monitored. Cohas BrooX would be monitored
downstream of the confluence of the brook and the
outfall from Whispering Pines Pond. The brook
flowing into Whispering Pines Pond would be
monitored just upstream of the pond.
• Residential Well Monitoring — Approximately 15
residential wells northwest and northeast of the
Site would be included in the residential well
monitoring program. Homes located on Shady Lane,
Longwood Avenue, and the Route 28 by-pass would be
included. The scope of the residential well
monitoring program would be expanded if any of the
well data indicated potential impacts from the
Site.
The groundwater, surface water, and residential wells would be
sampled every 6 months for all pollutants on the EPA HSL. This
monitoring would continue until the source no longer presented a
threat to human health and the environment. For the purposes of
cost development, monitoring for 30 years has been assumed.
Institutional restrictions (through zoning or similar local land
use ordinances) on groundwater withdrawal and usage would be
required for properties located between Whispering Pines Pond and
Cohas Brook. Additional restrictions might be required in the
future based on monitoring results.
Because this alternative involves only monitoring, it could be
readily implemented. However, this alternative provides no
reduction in toxicity, mobility or volume and does not meet
ARARs, specifically, Federal and State groundwater and drinking
water standards. Nor does this alternative comply with EPA's
Ground Water Protection Strategy, which is a factor to be
considered', or the New Hampshire Ground Water Protection
Regulations. In addition, since groundwater contamination levels
would continue to exceed acceptable drinking water standards off-
site, this alternative would not provide protection of public
health or the environment.
30
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ROD Summary
Auburn Road Landfill
wr
A detailed assessment of this alternative can be found on Pages
4-120 through 4-125 of the FS.
Estimated Time For Design fc Construction 15 - 18 months
Estimated Time For Operation (Monitoring) 30 years
Estimated Capital Cost $14,000
Estimated O t M Cost(Present Worth) $2,000,000
Estimated Total Cost(Present Worth) $2,014,000
MM-21 Groundwater Extraction ?
On-Site Treatment and On-Site Discharge
In this alternative, groundvater would be extracted and treated
by using a combination of overburden and bedrock veils and over-
burden collection trenches, and a groundwater treatment system.
Following treatment, the groundwater would be discharged on-site
outside the source control areas. MM-2 was ultimately adopted as
the management of migration component of the selected remedy and
is described in more detail in Section X of this document.
Estimated Time For Design £ Construction 3 years
Estimated Time For Operation (Monitoring) 10 years
Estimated Capital Cost $5,600,000
Estimated O & M Cost(Present Worth) $11,000,000
Estimated Total Cost(Present Worth) $16,600,000
MM-3; Groundwater Extraction;
On-Site Pretreatment with Off-Site
Treatment and Disposal
This remedial alternative entails extracting contaminated
groundwater from the overburden, pretreating it to meet
industrial pretreatment discharge standards, and discharging it
to a local Publicly Owned Treatment Works (POTW) for final
treatment and discharge. The required pretreatment would most
likely include chemical precipitation and air stripping with
vapor phase activated carbon treatment for air emissions.
The pretreatment system design would depend on the discharge
standards established by the State of New Hampshire and local
agencies. The City of Manchester Waste Water Treatment Plant
(WWTP) is the nearest secondary wastewater treatment plant with
excess capacity and, therefore, would be the most likely choice
for this alternative. The pretreated groundwater would be dis-
charged to the Town of Londonderry sewers, which, in turn, would
discharge to the Manchester WWTP. Therefore, the Londonderry
31
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ROD Summary
Auburn Road Landfill
Sewer Commission, the Manchester Sewer Commission, and the New '
Hampshire Department of Environmental Services (NHDES) would
determine the discharge standards that would be established
through review of the discharge permit application.
The groundwater collection system would be the same as for
Alternative MM-2. In order to meet anticipated pre-treatment
standards, the treatment system for this alternative would be
similar to that contained in Alternative MM-2, with the exception
that activated carbon polishing would not be required for the
effluent. Following air stripping, the pretreated groundwater
would be discharged directly to the municipal sewer. Since the
nearest sewer main that discharges to the Manchester WWTP is
located at the intersection of Nev Hampshire Route 28 and Perkins
Road in Londonderry, approximately 8,000 feet of 4-inch diameter
sewer main would have to be installed between the on-site
treatment plant and the existing sewer main. A 10,000-gallon
holding tank and a pumping station would also be installed to
transport the treated groundwater.
Regularly scheduled sampling and analysis of the pretreatment
system discharge would be required by the Londonderry and Man-
chester Sewer Commissions to ensure that pretreatment standards
were being met. The sampling frequency and parameters analyzed
would be determined by the commissions, based on the quality and
volume of the water being discharged. A monthly sampling and
analysis program with full EPA HSL analyses is anticipated.
This collection and treatment system conceptual design would
collect five pore-volume equivalents of overburden groundwater
beneath the source areas in 10 years.
Alternative MM-3 is essentially equal to the proposed alternative
MM-2. The same type of treatment equipment would be used, it
would comply with all ARARs, its cost is essentially equivalent
and it provides equal protection of public health and the
environment as alternative MM-2. However, because of the need
for formal agreements between the Manchester WWTP and the
Londonderry Sewer Commission, this alternative is not as readily
implementable as MM-2.
A detailed assessment of this alternative can be found on Pages
4-146 through 4-158 of the FS.
Estimated Time For Design * Construction 3 years
Estimated Time For Treatment Operation 10 years
Estimated Capital Cost $4,100,000
Estimated O & M Cost (Present Worth) $12,100,000
Estimated Total Cost(Present Worth) $16,200,000
32
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ROD Summary
Auburn Road Landfill
X. 'THE SELECTED REMEDY
The selected remedial action is a comprehensive approach for site
remediation which includes a management of migration component
(MM-2) and a source control component (SC-2). These components
will be implemented as two operable units, referred to herein as
Operable Unit II and III (Operable Unit I was a water line). A
comprehensive approach is necessary in order to achieve the
response objectives established for site remediation and the
governing legal requirements.
A. Description of the Selected Remedy
1. Remedial Action Objectives/Cleanup Goals
The selected remedy was developed to satisfy the following
remedial objectives which will guide the design of the remedy and
be used to measure the success of the remedy.
a. Groundwater - Specific groundwater target cleanup levels will
be met at the compliance boundary and in off-site 1 ocatleans in
the remedial action in order to:
• Restore the contaminated portion of the aquifer to
drinking water quality in as short a time as
practicable; and
• Prevent the migration of contaminated groundwater
into uncontaminated portions of the aquifer.
Groundwater contamination is primarily limited to volatile
organic compounds and metals. In order to meet the groundwater
objectives, target cleanup goals were developed and are presented
in Table X-l.
The Agency's decision to restore the groundwater to drinking
water quality at the compliance boundary was based on several
factors. The Agency considered its Ground Water Protection
Strategy (GWPS) (Office of Ground Water Protection, August, 1984)
which provides guidance concerning how different groundwaters
throughout the country should be classified and to what extent
cleaning up a particular class of groundwater is appropriate.
EPA also considered the Agency's draft Guidance on Remedial
Actions for Contaminated Ground Water at Superfund Sites (October
1986).
The policy under the GWPS establishes groundwater protection
goals based on "the highest beneficial uses to which groundwater
33
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ROD Summary
Auburn Road Landfill
having significant water resources value can presently or
potentially be put." Guidelines for protection of aquifers are
differentially based, relative to characteristics of
vulnerability, use and value. Under the classification scheme,
the groundwater at the Auburn Road Site is Class IX groundvater.
This groundvater is considered to be a current drinking water
source since groundwater is used for drinking water within a two
nile radius of the Site (the classification review area).
Therefore, EPA has determined that the appropriate groundwater
cleanup levels should be consistent with drinking water standards
as set by MCL's, PMCL's and Health Advisories (Table X-l).
EPA believes that active restoration of the groundwater is
appropriate for the Site. Although residences in the immediate
vicinity of the Site are connected to a municipal water supply,
there are residents in the area that obtain their water from
either the overburden aquifer or bedrock aquifer systems. Con-
tinued migration of contaminants and/or increased development
resulting in increased groundwater demand could result in impacts
to downgradient wells in the future.
EPA chose the northern property boundary of the Site as part of
the compliance boundary, that is, the point where groundwater
will at a minimum meet cleanup goals established for the Site and
be protective of public health and the environment. EPA also
determined that the compliance boundary should extend parallel to
the unnamed brook which is east of the Solid Waste Area. This is
to insure that contaminated groundwater exceeding cleanup goals
will not move easterly or discharge to the unnamed brook.
t
EPA chose this compliance boundary rather than a more restrictive
boundary at the edge of each source area on the basis that the
State of New Hampshire considers the entire Site to be a waste
management facility. As such, the State Department of
Environmental Services (NHDES), through N.H.R.S.A. 147-A:13,
N.H.R.S.A. 147-B:l and N.H. Code of Admin. Rules, He-P
1905.08(d)(1)(d), has the authority to restrict any activity at
the Site which would be adverse to the public health and welfare,
and to prevent exposure of humans and the environment to harmful
quantities of hazardous waste or its constituents. Specifically,
the NHDES has the authority to restrict land use within the area
between the source areas and the compliance boundary after
closure to insure that the closure devices, facilities and
monitoring systems are not disturbed. The NHDES will exercise
this authority consistently with the objectives of this response
action.
34
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ROD Summary
Auburn Road Landfill
Table X-l
Cleanup Goals
of Indicator Chemicals in Groundvater
Auburn Road Landfill, Londonderry, Hew Hampshire
Indicator
Chemical1
Reference
Cleanup
Level1(Goals)
Inorganic
Arsenic
Lead
Volatiles fua/L)
Vinyl chloride
Trans-1,2-dichloroethene
2-Butanone
Trichloroethene
Tetrachloroethene
Toluene
Benzene
MCL
MCL
MCL
MCL
HA
MCL
PMCL
PMCL
MCL
50
50
2
70
172
5
5
2,000
5
Reference Subsection 2.3 of the FS for cleanup level discussion.
2The development of the clean-up goal for 2-Butanone is based on
an EPA Health Advisory and as such is not an ARAR, but rather "To
Be Considered" (TBC). If, during treatability studies to be
conducted during design, EPA determines that the goal of 172 ppb
cannot be obtained with the treatment system proposed, additional
treatment methods and/or the appropriateness of this goal will be
evaluated.
35
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ROD Summary
Auburn Road Landfill
r_
b. Soils - Specific soil cleanup goals were not developed
because soil data presented in the Supplemental RI shoved that
the risks associated with direct contact and subsequent
ingestionof on-site soils is already within the acceptable risk
range of 10 to 10 established for Superfund sites. However,
an objective of the remedial action is to reduce flushing of
residual soil contamination to groundwater and also to prevent
migration of these soils which could result in contamination of
nearby surface waters.
2. Description of Remedial Components
a. Management of Migration MM-2 (Operable Unit II)
Groundwater contamination is primarily limited to volatile
organics and metals. The groundwater treatment alternative would
focus on the removal of these contaminants. The management of
migration operable unit chosen (MM-2) will include groundwater
collection and treatment. Groundwater will be collected by using
a combination of overburden and bedrock wells and overburden
collection trenches. The actual number and location of
collection wells, as well as the location and length of the
collection trenches, will be determined based on results of
groundwater sampling conducted during the first phase of Remedial
Design.
The collection system will be designed to recover contaminated
groundwater immediately dovngradient of each source area, along
the compliance boundary and off-site north of the Whispering
Pines Pond. Conceptually, the collection system will consist of
shallow overburden wells and bedrock wells. Since the
contamination is believed to be primarily in the deep overburden
and shallow bedrock aquifer, the overburden wells will be
screened just above bedrock while the bedrock wells will be
screened in the top 15 feet of the bedrock. In addition,
collection trenches, designed to intercept shallow contaminated
groundwater as it moves off the source areas, may be installed in
the old Town Dump and along the southern edge of the Solid Haste
Area. Finally, collection wells will be installed off-site,
north of the Whispering Pines Pond, to collect contaminated
groundwatex which has moved beyond the property boundary. Once
extracted, groundwater will be treated through physical
processes,' to meet Federal and State drinking water standards
prior to discharge to on-site recharge trenches located away from
the source areas. Figure X-l shows the proposed locations for
the extraction wells and trenches, compliance boundary and
recharge trenches.
36
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LIE —|
BOUNDARY I . « ,
* I .»•*
'"••• ../...:...itv*^*"
AUBURN ROAD
LANOFXL SITE
MEVISCO QROUNDWATCM
RECOVERY SYSTEM
-------
ROD Summary
Auburn Road Landfill
One* collected, contaminated groundvater will first be treated
through chemical coagulation and precipitation to reduce arsenic
down to the goal of 50 parts per billion (ppb). In addition to
removing arsenic, this process will also remove iron from the
groundvater. Removing iron is desirable to prevent clogging of
the organics treatment system (air-stripper). The clarified
liquid produced in this operation would be stored temporarily
prior to further treatment in the organics treatment system. The
precipitate, or sludge (metallic hydroxide), from the metal
removal process would be further thickened and would then be
pumped to a filter press for dewatering. The dewatered sludge
would consist primarily of iron, magnesium, and calcium
hydroxide, and is expected to be considered non-hazardous. The
sludge would be disposed of in a landfill constructed on-site
specifically for this purpose. The landfill would be designed to
hold only the estimated volume of sludge to be generated and
would be constructed as the landfill described for Alternative
SC-3.
Following treatment in the inorganics treatment system, the
clarified contaminated groundwater would be pumped to an air
stripping tower. VOCs would be driven from the water into the
air stream, and removed in a vapor phase carbon adsorption
system.
Air stripping is a relatively inexpensive, yet effective, means
of removing these contaminants. Air stripping removes organic
contaminants from groundwater by accelerating the evaporation
process. The contaminated wastewater is sprayed downward over
packed material in an enclosed upright metal tower, as clean air
is pumped upward through the tower. The packing disperses the
water as it cascades downward through the tower, to maximize •
air/water contact. Based on the gas-liquid equilibrium between
the water and the air, the VOCs leave the water and enter the air
stream. The cleaner wastewater is discharged from the tower
bottom. The contaminated air stream it. then discharged to a
vapor phase carbon adsorption unit prior to atmospheric
discharge.
Removal efficiencies will vary for the different types of
chemical groups found at the Site. For most of the VOCs listed
in Table X-l, the removal efficiency would range from 70 to
approximately 99 percent. However, the removal efficiency for
the 2-Butanone will range from only 10 to 25 percent. If after
the air stripping process, the treated groundwater effluent still
does not meet the Federal and State drinking water standards, it
will be discharged to an activated carbon treatment unit for
final treatment. If the goals for 2-Butanone cannot be obtained
38
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ROD Summary
Auburn Road Landfill
following air stripping, other treatment methods as well as the
appropriateness of the goal will be evaluated. Following carbon
adsorption, the treated effluent would be discharged back to the
groundwater, away from the source areas, but still on-site.
The exhaust air, from the air-stripper, would be de-humidified
and then passed through vapor-phase, activated-carbon units in
which the VOCs would be removed. The exhaust air from the
activated carbon units would then be discharged through an
exhaust stack to the atmosphere. This exhaust will be monitored
for total VOCs. Once VOC vapors are detected in the emission,
the air stream will be manually redirected to an alternate vapor
phase carbon bed for further treatment. The used carbon will be
shipped off-site and thermally regenerated.
The treatment combination of chemical coagulation, air stripping
and activated carbon will result in organic and metal
concentrations vhich will be at or below the Federal and Mew
Hampshire drinking water standards in the effluent from the
treatment plant.
EPA has estimated that groundwater treatment will continue for
six to ten years at a pumping rate of 195 to 250 gpm. This
treatment period will allow for treating three to five complete
pore volumes of groundwater from the overburden and shallow
bedrock aquifer. Quarterly groundwater monitoring will be
initiated during the remedial design phase and will continue
through the post remediation period, both on and off-site, to
track the effectiveness of the collection and treatment process.
When the cleanup goals are consistently met at the compliance
boundary and throughout the off-site plume, and the cumulative
risk of all remaining compounds falls within EPA's 10"* to 10"7
acceptable risk range, then the collection and treatment systems
will be turned off. Groundwater will then continue to be
monitored quarterly for a period of three years. The monitoring
network will be established during remedial design. If, during
this three year monitoring period, the level of contamination
begins to exceed the cleanup goals, the collection and treatment
systems will be re-activated and remain on until such time as the
goals are again consistently met, provided that the cumulative
risk for that area falls within EPA's acceptable risk range. The
collection- system for either the on-site or off-site atea may be
turned off independently of each other once cleanup goals for
that area are met. Groundwater monitoring will immediately begin
once either collection system is turned off. However, the three
year monitoring period will not begin until the treatment system
is turned "off. If the groundwater goals are not attained after
39
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ROD Summary
Auburn Road Landfill
ten years of collection and treatment, EPA will re-evaluate the
appropriateness of the remedy and/or the cleanup goals.
Once groundvater cleanup goals are maintained for the three year
monitoring period, a monitoring program for the Site in
accordance with Mew Hampshire Hazardous Waste and Solid Waste
Rules will be implemented. Additionally, in accordance with
CERCLA f 121 (c), EPA will conduct a review of the Site every five
years.
b. Source Control SC-2 (Operable Unit III)
The Source Control Operable Unit, (SC-2), will consist of placing
a natural and synthetic cap over each disposal area. This
operable unit may be implemented concurrently with groundvater
treatment and will be accomplished with only minimal disturbance
of existing waste material. The multi-layered cap system would
meet NHDES requirements and also the relevant and appropriate
portions of 40 CFR Part 264 relating to closure and post closure
of waste units. At a minimum, this multilayered cap would
consist of a vegetative topsoil layer, a subsurface drainage
layer, and a low-permeability layer (barrier) that would underlie
the drainage layer. Figure X-2 shows the cross section of a
typical multi-layered cap. The vegetative layer would consist of
topsoil (loam) that would support vegetation growth and
facilitate drainage. This layer would protect the cap through
soil stabilization and erosion control. Through
evapotranspiration and drainage control, this layer would remove
approximately 50 percent of infiltrating rainfall. Directly
beneath the topsoil layer would be a layer of sandy soil that
would promote sub-drainage of infiltrating precipitation and
protect the underlying low-permeability layer. Additional soil
to construct this layer may have to be purchased off-site.
The topsoil and sand layers would comprise a cover above the
low-permeability layer and drainage netting. This cover would be
sufficient to protect the underlying impermeable layer from
frost. Infiltrating water would be captured and transported
along the plane (surface) of the netting and discharged at the
Site perimeter away from the area of contamination. An
intervening layer of geotextiie fabric would be placed between
the drainage netting and overlying cover materials to prevent
soil from entering the drainage zone. Beneath this intermediate
drainage layer is the low-permeability layer. A synthetic liner
composed of a high-density polyethylene material (HOPE) was
chosen for the low-permeability layer. An HOPE liner can attain
virtual impermeability, assuming good quality control. The
40-mil thick liner would be set at an approximate depth of 3
feet. The.material has superior physical and chemical
40
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FERTILIZER , MULCH A SEED
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INTERMEDIATE ^
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TYPICAL SECTION
NOT TO SCALE
IN-SITU CLOSURE / RCRA LANDFILL
ALTERNATIVES SC-2, SC-3, SC-4, SC-5)
MULTI-LAYERED CAP
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ROD Summary
Auburn Road Landfill
characteristics and should be highly resistant to deterioration.
The desigft- life of an HDPE-cap system is indefinite with proper
post-closure maintenance of the Site.
The selected low-permeability liner would be anchored at the ends
to prevent slippage. An anchor trench would consist of an
excavated earthen trench within which the liner cap would be
placed. The liner would then be backfilled with appropriate
drainage material and graded (or sloped) to permit removal of
seepage. The vegetative layer would extend over the trench. The
anchor trench also would function as a conduit for diverting
rainfall infiltration to the surface drainage system for
discharge directly to natural surface waters, since the infil-
tration would be clean and virtually free of sediment.
Because the current topography of the Site is not suitable for
capping, grading and compaction would be required to form a
proper sub-base for the cap. The final slope would be designed
to remove surface irregularities, provide proper drainage, and
prevent erosion. Grading of the Site would be accomplished with
little or no disturbance of buried wastes. Approximately
150,000 cubic yards of soil materials from off-site sources is
estimated for construction of the multilayer cap. During
construction activities for this alternative, runoff and
sedimentation would be controlled using silt fences and
sedimentation ponds.
B. Rationale for Selection
The rationale for choosing the selected alternative is based on
the assessment of each criteria 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 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, including, short term effectiveness, long
term effectiveness, iaplementability, use of treatment to
permanently reduce the mobility, toxicity and volume, and cost.
EPA also considered nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance. Based upon this assessment, taking into account the
statutory preferences of CERCLA, EPA selected the following
remedial approach for the Site.
42
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ROD Summary
Auburn Road Landfill
1. Management of Migration
f
Chapter 4 of the FS presents a detailed evaluation of two
management of migration alternatives (MM-2 and MM-3), which'will
satisfy the remedial groundwater objectives presented earlier in
this section.
A comparison of Alternative MM-2, Groundwater Extraction/On-Site
Treatment and Discharge, to Alternative MM-3, Groundwater
Extraction/On-Site Treatment with Off-Site Disposal, shows that
these alternatives are equal with respect to protection of human
health and the environment, compliance with ARARs, short and long
term effectiveness, and reduction in toxicity, mobility and
volume. Both alternatives can be designed to provide the degree
of treatment necessary to attain the established groundwater
cleanup goals. Thus, they are equally protective of human health
and the environment, and provide the same degree of reduction of
toxicity, mobility and volume of the contamination in
groundwater. Each alternative will provide the same degree of
short term effectiveness in protection of the community and on-
site workers, as well as in groundwater improvements as soon as
each system is activated. As both alternatives are equal with
respect to groundwater collection and utilize similar treatment
technologies, the long term effectiveness of each in providing
reliable treatment is equivalent. In terms of cost, although MM-
3 appears to be slightly less costly, the difference in cost
between the two alternatives is within the degree of accuracy
(450%, -30%) expected for these estimates. Therefore, these two
alternatives are considered essentially equal in cost. MM-2 was
chosen over MM-3 primarily on the basis of implementability.
Implementation of MM-3 would require the construction of an 8,000
foot sewer main from the On-Site Treatment Facility to the
nearest Town of Londonderry sewer. It would also be dependent on
the willingness of the Manchester and Londonderry Sewer
Commissions to accept the pretreated groundwater. Prior to
implementing Alternative MM-3, an industrial discharge permit
application that lists the types and concentrations of the
contaminants present would be required by both commissions. The
sewer commissioners would evaluate each hazardous constituent
listed in the application to determine whether or not the
Manchester WWTF could treat it, and whether or not the
constituents would create hazardous conditions in the sewers.
Representatives of the Town of Londonderry and residents of the
Auburn Road area have expressed a preference for the
implementation of Alternative MM-3 over Alternative MM-2. As
discussed,-EPA considers Alternatives MM-2 and MM-3 to be
technically equal. If, at any time during design, the necessary
agreements between the Town of Londonderry and the Manchester
WWTP can be reached, and it can be shown that implementation of
MM-3 would not have an adverse impact on local wetlands, then
43
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ROD Summary
Auburn Road Landfill
Alternative MM-3 may be substituted for Alternative MM-2. The
State of New Hampshire has stated at various public information
meetings that it would support either MM-2 or MM-3. Table X-2
presents the capital and operation and
maintenance costs for all of the Source Control and Management of
Migration Alternatives evaluated.
2. Source Control
Chapter 4 of the FS also evaluated four source control
alternatives which would provide a permanent solution to the
remaining soil contamination at the Site. One of the
alternatives, SC-1 Composting, is also considered an alternative
treatment technology.
Alternatives SC-3, SC-4, SC-5, SC-6 and, SC-7 all involve
excavation and treatment of all or some portion of the source
materials. In the short term, while excavation is taking place,
these alternatives present a greater risk of exposure for workers
and nearby residents than SC-2. Once excavation is complete,
each alternative is protective of human health and the
environment. Each alternative could be constructed and operated
to meet ARARs. All, except SC-2, would provide for some level of
reduction of toxicity in the soils and, in the case of
incineration, would also provide for reduction in volume.
However, based on the most recent soil analyses presented in the
Supplemental RI, the level of soil contamination found at each of
the source areas is already within the range which EPA considers
protective of human health for direct contact and subsequent
ingestion of soils.
These alternatives are all equally implementable, as the
equipment for each alternative is readily available. However,
these alternatives are significantly more expensive than SC-2,
the selected remedy, and do not provide an increased degree of
protectiveness proportional to their cost. EPA has therefore
determined that the selected source control remedy, SC-2, is both
cost effective and protective.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Site is
consistent-with CERCLA and, to the extent practicable, the NCP.
The selected remedy is protective of human health and the
environment and attains ARARs. The selected remedy also offers
the best combination of effectiveness, implementability, and cost
in comparison with the other alternatives that provide the same
level of protection. The selected remedy also satisfies
44
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ROD Summary
Auburn Road Landfill
Table X-2
COST COMPARISON Of ALTERNATIVES
SOURCE CONTROL ALTERNATIVES
Capital O&M Cost *Present
Cost ($/yr) Worth
SC-l No Action 240,000 138,000 2,400,000
SC-2 In Situ Closure 5,100,000 160,000 7,500,000
SC-3 On-Site Incineration/In 38,000,000 228,000 41,200,000
Situ Closure/On-Site
Landfill
SC-4 Low Temperature Thermal 31,300,000 104,000 32,700,000
Stripping/On-Site Landfill
5 On-Site Incineration/On- 52,200,000 105,000 53,600,000
Site Landfill
SC-6 Off-Site Treatment/Off-Site 190,000,000 0 190,000,000
Landfill
SC-7 Composting/On-Site Landfill 28,400,000 104,000 29,800,000
MANAGEMENT Of MIGRATION
MM-1 No Action 13,000 130,000 2,000,000
MM-2 Groundwater Recovery/ 5,600,000 1,300,000 16,600,000
Treatment
MM-3 On-Site Pretreatment/Off- 4,100,000 1,400,000 16,200,000
Site Treatment and Disposal
45
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ROD Summary
Auburn Road Landfill
the statutory preference for a permanent solution and for
treatment which reduces the mobility, toxicity or volume as a
principal element. Additionally, the selected remedy utilizes
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this Site will permanently reduce the risks
presently posed to human health and the environment by
contaminated groundwater. The Agency has selected cleanup goals
in groundwater as presented in Table X-l, based on MCLs, PMCLs
and Health Advisories. Vinyl chloride is a carcinogen with a MCL
of 2 ppb. The risk associated with vinyl chloride at its MCL is
1.3 x 10 . However, vinyl chloride is also a compound which,
due to its physical properties, is more readily removed from
water than most other VOCs when subjected to the proposed
aeration process. EPA expects that meeting or exceeding the
treatment goals for the other VOCs will result in near total
removal of vinyl chloride and therefore the remedy will be
protective at completion.
The groundwater cleanup goal for inorganic arsenic is the MCL of
50 ppb. The excess lifetime risk associated with this concen-
tration is estimated to be 2.5 x 10 . Because of several uncer-
tainties which are currently unresolved on a scientific basis,
this value may be overestimated by as much as an order of
magnitude. EPA will consider any new information regarding
arsenic and its associated cancer risk in reviewing the remedial
action. To the extent required by law, EPA will review the Site
at least once every five years after the initiation of remedial
action to assure that the remedial action continues to protect
human health and the environment. As described below, EPA will
also evaluate the cumulative risk posed by the Site at the '
completion of the remedial action to insure that the remedy is
protective. The groundwater remediation will continue until the
goals for each compound are attained or exceeded at all locations
at the compliance boundary and throughout the off-site plume. At
that point, EPA will evaluate the cumulative risk of all
compounds to insure that the total carcinogenic risk falls within
EPA1 s 10'* to 10*7 acceptable risk range1 and the non-carcinogenic
risks are at an acceptable level. Groundwater treatment will
continue until both carcinogenic and non-carcinogenic cumulative
risks are determined to be at acceptable levels. Although
groundwater under the Site, primarily between the Solid Waste
Area and the compliance boundary, may not meet the cleanup goals,
1This evaluation will take into account EPA's policy
regarding arsenic.
46
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ROD Summary
Auburn Road Landfill
NHDES has sufficient authority to restrict land use on the Site
to insure that public health and the environment will be
adequately protected. Risks associated with direct contact and
subsequent ingestion of soils are already within the acceptable
range for superfund sites (10** to 10 ). However, closure of the
source areas with a cap, in accordance with State requirements
and RCRA part 264, will further insure that the public will not
come into direct contact with contaminated soils and will also
prevent the possibility of snow melt or rain water from filtering
down through the contaminants and adding to groundwater
contamination.
As noted in Section IX above, Alternative MM-3 is as protective
of human health and the environment as is Alternative MM-2.
B. ' The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the
Site. Substantive portions of the environmental laws listed
below are applicable or relevant and appropriate to the selected
remedial action at the Site:
Resource Conservation and Recovery Act (RCRA)2
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Executive Order 11988 (Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
Clean Air Act (CAA)
Occupational Safety and Health Administration (OSHA)
New Hampshire Surf ace-Water Quality Standards (Ws '430)
New Hampshire Protection of Ground Water Regulations(Ws
410)
New Hampshire Hazardous Waste Rules (He-P 1905)
New Hampshire Solid Waste Rules (He-P 1901)
New Hampshire Air Quality Rules (RSA Chapter 125-C)
New Hampshire Wetland Protection Rules (RSA 149 and RSA
483)
.'able 2-1 and Table 2-2, in Chapter 2 of the FS, list the
chemical specific and location specific ARARs, respectively, and
outline the action which will be taken to attain the ARARs.
Table 2-3 'and Appendix E of the FS contain the action specific
ARARs for all the alternatives, present a brief synopsis of the
requirements, and outline the action which will be taken to
attain the ARARs. The attached Table XI-1 presents the action-
specific ARARs for the selected alternative.
New Hampshire is a RCRA authorized State program.
47
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Table XI-2A
Action-Specific ARARs for Alternative SC-2: In Situ Closure
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
KCMA regulation! - Groundwater
Protection (40 CFR 264.90-264.109)
OSHA regulations - Safety and
Health Standards for Federal
Service Contracts
MCRA regulations - Standards for Owners
and Operators of remitted Haiardous
Waste facilities (40 CFi 264.lt-264.18)
HCRA regulations (40 CFR 264.228 and
2b4.3IO)
RCRA regulations - Closure and Pest-
Closure (40 CFR 2M.llt-264.l20)
These regulations detail the requirements for
• groundwater Monitoring program to be in-
•t«Hed at the site.
This docunent contains instructions con-
cerning worker safety at RCRA or Superfund
hazardous waste facilities.
General facility requirements outline general
waste analysis, security Measures, inspections,
training, and location requirements.
fheto regulations detail the technical re-
fuiroments for capping • RCRA facility.
These regulations detail the spec*He re-
quirements for closure and post-closure of
haiardeus waste facilities.
A groundwater Monitoring prograM would be designed.
installed, and operated to assess the release of con-
tamination from source areas to groundwater. C«i it ing
wells would be used as appropriate.
All appropriate safety equipment would be on-site and
appropriate procedures would be followed during reme-
diation.
During all site work, a waste analysis plan would be
written and maintained on-site. Entry to the site
would be prevented by a 24-hour surveillance system
written inspection
workers properly
and appropriate signs posted. A wri
program would be developed, and all
trained.
The requirements would be used as guidance for design
and construction of the cap.
Pathway* of potential enposure would be limited. Un-
treated baiardous and nonhatardous wastes wou,ld be
capped but not contained. The 30-year post-closure plan
required for a landfill would include monitoring and
maintaining the cap, removing liquid from the leachate
collection system, and Monitoring groundwater quality.
-------
Table XI-2A
(continued)
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
CAA regulations - National Ambient Air
Quality Standards for Total Suspended
P-rliculates (40 CfR 129.105. 750)
Protection of Archaeological
Resources (32 CFR 229. 229.4)
CWA regulations (40 CFR 122)
NHDF.S Hazardous Maste Management
Regulation} - Waste Facility
Security Requirements
(NH Admin. Cod* He-P !90S.08(d))
NHOES Haiardous Wast* Management
Regulations - Personnel Training
(NH Admin. Cod* Me-P I905(d)(4)(*))
NHOFS Haiardous Wast* Management
Regulations - Location Standards
(NH Admin. Cod* Me-P 1905(d)(4)(g»
These regulations specify maximum primary and
secondary 24-hour concentrations for particulate
matter.
These regulations develop procedures for the
protection of archaeological resources.
These regulations address discharges to surface
Maters.
Incorporates, by reference. 40 CfR 264.14 -
General facility requirement for security
measures.
Incorporates, by reference, 40 CFR 264.16 •
General facility requirement for personnel
training.
Incorporates, by reference. 40 CFR 264.18 •
Location requirement for landfills.
Fugitive dust emissions from site activities would be
maintained below 150 ug/cu m (secondary standard) by
water sprays and other dust suppressants.
If archaeological resources are encountered during soil
excavation, work would be stopped until the area has
been reviewed by Federal and state archaeologists.
Groundwater collected by the groundwater depression
system at each source area would be treated lo el-
fluent quality appropriate for the point of discharge.
During all site work, entry to the site would be pre-
vented by a 24-hour surveillance system. Appropriate
signs would be posted.
During all site work, personnel would be properly
trained. Written records of such training would be
maintained.
The landfill facilities would be located, designed,, and
operated according to these regulations.
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Table XI-2A
(continued)
ARARs
Requirement Synopsis
Action to be taken to Attain ARARs
NODES Haiardous Waste Management
Regulations - Preparedness and
Prevention
(NH Attain. Code He-P !90S.08(d)
I4|(hn
NHOCS Haiardous Waste Management
Regulations - Contingency Flan
(NH Admin. Code M*-P 1905.M(d)
(4Mi»
NHOtS Haiardous Waste Management
Regulations - Closure and Post-
Closure
(NH Ad«in. Code He-P 1905.08(d)
NHOCS Haiardous Waste Management
Regulations - Creundwater Protec-
tion
(NH Admin. Code He-P 1905.08(d)
MMJ))
NHDCS Haiardous Wast* Management
Regulations -^Transfer of Facility
(NH Admin. Coda He-P I905.08(d)(5))
Incorporates, by reference. 40 CfR 264.30-
264.31 - Requirements for safety programs
and spill control.
Incorporates, by reference, 40 CfR 264.50-
264.56 - Requirements for contingency plan
and emergency procedures.
Incorporates, by reference, 40 CFR 264.1)0-
264.120 - Specific requirements for closure
and post-closure activities at haiardous
waste facilities.
Incorporates, by reference. 40 CFR 264.90-
264.109 - Establishes additional standards
for groundwater Monitoring and appropriate
remediation at h«iardous waste facilities.
The provision prohibits the discharge of
contaminants into groundwater. above Federal
•CRA limits, for tuch contaminants at the
compliance point (the boundary of each waste
Management unit under 40 CFR 264.95).
Requirement establishes requirements for
notifying the Division and future owners or
operators when the facility is transferred.
During all site work, safety and communication equip-
ment would be installed. tocal emergency response
authorities would be familiariied with the site.
Plans and emergency procedures Mould be developed
during the remedial design and implemented during the
remedial action. Copies e< the plans would be kept
on-site at all times.
Residual contamination mutt have low mobility and
tonicity, and pathways of potential exposure must be
limited. Ireated haiardous wastes and untreated non-
haiardous wastes would be contained in the landfill
cell, fhe 30-year post-closure plan required for a
landfill would include monitoring and maintaining the
cap. removing liquid from the leachate collection
system, and monitoring grtfundwater quality.
A groundwater monitoring and protection program would
be implemented, in accordance with this provision.
Compliance with this provision would be required prior
to any transfer of facility ownership or operation.
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Table XI-2A
(continued)
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
NHDES Hazardous Waste Management
Regulations - Monitoring (NH Admin.
Code He-P 1905.08(d)(6))
NHOES Haiardous Waste Management
Regulations - General Environ-
mental Standards
(NH Admin. Code He-P 190S.08(d)
NHOES Haxardous Waste Management
Regulations - General Design
Standards
(NH Admin. Code He-P 190S.08(d)
Requirement establishes groundwater monitor-
ing requirements and authorizes the Division
to require other appropriate environmental
•onitoring.
Requirement requires facilities to comply
with specified state and Federal environ-
mental standards and to provide protection
to workers in accordance with state and
Federal occupational health and safety
requirements. Applicable occupational
standards Include 29 CFR 1910 (industry
standards); 29 CFR 1926 (safety and health
standards); NH RSA 277-A (Worker's Right-
to-Know Act); NH Admin. Code He-P 1800, Part
1803 (tOHic substances in the workplace).
Requirement establishes general facility
design standards to prevent release of
hazardous constituents.
Groyndwater monitoring would be required; additional
monitoring, including air emissions testing, might be
necessary to detect releases of fugitive dust or VOCs
durino r
Facility operation must comply with environmental and
occupational safety requirements.
Plans for the facility would be required to
incorporate these design standards to control releases
of hazardous constituents•
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Table XI-2A
Icontinued)
ARARs
Requirement Synopsis
Action to bt taken to Attain ARARs
NHOCS Hazardous Mast* Management
Krgulations - Additional Technical
Standards for Treatment (NH Admin.
Cod* He-P l90S.M(f)(2Ha»
NHOCS Hatardous Wast* Management
Hfgulations - Storage Standards
(NH Admin. Cod* He-P !90S.08(f)
(2HOI
NHOCS Hazardous Waste Management
Regulations - Technical Standards
(or Waste Piles (NH Admin. Cod*
He-P l90S.M(f)(1Hd), incorporat-
ing, by reference. 40 CFR 264.
Subpart I)
NHOCS Haiardous Waste Management
Regulations - Technical Standards
(or Use and Management of Con-
tainers (NH Admin. Code He-P
l90S.M(f)(l)(a), incorporating.
by reference. 40 CFR 264. Subpart
I)
Requires a demonstration that proposed
treatment methods will meet specified design
Mid construction requirements.
Requirement specifies design and construc-
tion standards for facilities that store
hazardous wastes.
Requirements incorporate Federal RCRA
standards for waste piles.
Requirements incorporate Federal RCRA
standards for facilities that store
containers of hazardous wastes.
The owner/operator of a treatment facility must
demonstrate that the technology will be effective;
will include automatic controls to stop inflow in any
continuous flow process; will control tonic gases or
fumes; and will meet other design requirements of this
provision.
The owner/operator of a facility must minimise any
danger to human health or the environment, must
include mechanisms to prevent and detect releases to
the environment, and must otherwise comply with design
standards set forth in this provision, while storing
hazardous wastes, groundwater treatment residuals, and
contaminated soils.
The owner/operator of the facility must operate any
waste pile in accordance with 40 CFR 264. Subpart L.
The owner/operator must comply with the design and
management standards for hazardous waste containers.
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Table XI-2A
(continued)
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
)ES Air Pollution Control Reg-
itions - Air Pollutant Emissions
I Admin. Code. Air. Parts 604
-ough 606)
OES Air Pollution Control Regu-
tions - Fugitive Oust Emissions
H Admin. Code. Air. Part 1002)
NHOCS Solid Waste Regulations -
treatment. Storage, and Disposal
(ISO) facilities (RSA Ch. 149-M.
NH Solid Waste Management Act; NH
Admin. Code He-P 1901)
These provisions establish limits for the
emission of air pollutants, including VOCs
and hatardous air pollutants. Applicable
standards include the Most stringent of the
following requirements:
• Federal New Source Performance Standards
(40 CFR 60)
» Federal National Emission Standards for
Hazardous Air Pollutants (40 CfR 61)
• New Hampshire State Implementation Plan
limits (see RSA I25-C:6; NH Admin. Code,
Air 101.09 and Air 606.01).
This provision requires prevention, abate-
ment, and control of fugitive dust during
specified activities, including construc-
tion, excavation, and bulk hauling (see NH
Admin. Code. Air 1002.02).
These provisions establish standards appli-
cable to the treatment, storage, and dis-
posal of solid wastes and the closure of
solid waste facilities.
The owner/operator of a ha/ardous waste facility must
comply with the standards set forth in these provi-
sions, including the limits on the release of volatile
organic compound (VOC) contaminants into the environ-
ment.
On-site air monitoring would be required to indicate
low levels of volatile organic compounds in the ambient
air. in and around the sit*. Measures would be taken
during remedial action to prevent unpermitted air
emissions from the site.
Thw owner/operator must control fugitive dust
emissions, during and after site remediation.
Th« owner/operator of a solid waste facility must
man«ge. store, treat, and dispose of nonha/ardous
wastes on-site, in accordance with the Solid Waste
Management Act and the rules thereof.
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Table XI-2B
Action-Specific ARARs for Alternative HH-2: Groundwaler Recovery/Treatment
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
NCRA regulations - Groundwater
Protection (40 CFR 264.90-264.109)
RCRA regulations - Closure
Post-Closure (40 CfR
264.110-264.1201
NHUCS Hazardous Waste Management
Regulations - Personnel training
(Ntt Admin. Code He-P l90S(d)(4)(e)>
NHOCS Hazardous Waste Management
Regulations - Location Standards
(NH Admin. Code He-f )905(d)(4)(gM
These regulations detail the requirements for
a groundwater Monitoring program to be in-
stalled at the site.
These regulations detail the specific re-
quirements for closure and post-closure of
haiardous waste facilities.
Incorporates, by reference. 40 CFR 264.16 -
General facility requirement for personnel
training.
Incorporates, by reference. 40 CfR 264.18 -
Location requirement for landfills.
A surface-water-and groundwater monitoring program
would be designed, installed, and operated to assess
groundwater contamination migration. New and enisling
wells would be used as appropriate.
This alternative •> ..»i e»pected to attain this ARAR.
Contaminant levels would n-main above groundwater
standards and criteria for a period of years.
During all site work, personnel would •» properly
trained. Written reivrdt of such tr.n»iiij would be
maintained.
The landfill facilities would be located, designed, and
operated according to these regulations.
NHOES Hazardous Waste Management
Regulations - Preparedness and
Prevention
(NH Admin. Code He-P !90S.08(d)
NHOCS Hazardous Waste Management
Regulations - Contingency Plan
(NH Admin. Code He-P 1905. 08(d)
NHOCS Hazardous Waste Management
Regulations - Closure and Post-
Closure
(NH Admin. Code He-P 1905. 08|d)
<4)(kM
Incorporates, by reference, 40 CfR 264.30-
264.31 - Requirements for safety programs
«nd sptll control.
Incorporates, by reference. 40 CfR 264.50-
264.56 - Requirements for contingency plan
and emergency procedures.
Incorporates, by reference. 40 CfR 264.110-
264.120 - Specific requirements for closure
and post-closure activities at hazardous
waste facilities.
During all site work, safety and communication equip-
ment would be installed. Local emergency response
authorities would be familiarised with the site.
Plans and emergency procedures would be developed
during the remedial design and implemented during the
remedial action. Copies of the plans would be kept
on-site at all times.
Residual contamination must haw low mobility and
toaicity. and pathways of potential exposure must be
limited. Treated hazardous wastes and untreated non-
hazardous wastes would be contained in the landfill
cell. The 30-year post-closure plan required for a
landfill would include monitoring and maintaining the
cap. removing liquid from the leachate collection
system, and monitoring groundwater quality.
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Table XI-2B
(continued)
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
NHOCS Hazardous Waste Management
Regulations - Groundwater Protec-
t ion
(NH Admin. Code He-P 1905.08(d)
NHDfS Hazardous Waste Management
Regulations - Monitoring
(NH Admin. Code He-P I
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Table XI-2B
(continued)
ARMs
Requirement Synopsis
Action to be taken to Attain ARARs
NHOCS Hazardous Waste Management
Regulations - Storage Standards
(NH Ad«in. Code He-P 190S.M(f)
NHOES Hazardous Waste Management
Negulations - technical Standards
lor Waste Piles (NH Altain. Code
He-P 190S.08|f)(l)(d). incorporat-
ing, by reference. 40 CFR 264.
Subpart L)
NHOES Hazardous Waste Management
Regulations - technical Standards
for Use and Management of Con-
tainers (NH Admin. Code He-P
1905.08(1 UIHa). incorporating,
by reference, 40 CFR 264. Subpart
n
Requirement specifies design and construc-
tion standards for facilities that store
hazardous wastes.
Requirements incorporate Federal RCRA
standards for waste piles.
Requirements incorporate Federal RCRA
standards for facilities that store
containers of hazardous wastes.
the owner/operator of a facility must minimize any
danger to human health or the environment, must
include mechanisms to prevent and delect releases to
the environment, and must otherwise comply with design
standards set forth in this provision, while storing
hazardous wastes, groundwater treatment residuals, and
contaminated soils.
the owner/operator of the facility must operate any
waste pile in accordance with 40 CFR 264. Subpart t.
the owner/operator must comply with the design and
management standards of hazardous waste containers.
NHOCS Hazardous Waste Management
Negulations - technical Standards
for tanks (NH Admin. Code He-P
190S.Oe(fHI)(b), incorporating.
by reference. 40 CFR 264. Subpart J)
NHOCS Hazardous Waste Management
Negulations - Standards for Gen-
erators (NH Admin. Code He-P
I90S.06)
Requirements incorporate Federal RCRA
standards for facilities using tanks to
treat or store hazardous wastes.
Requirement establishes standards applicable
to generators, including persons transporting
hazardous wastes or treatment residues
off-site.
the owner/operator must comply with design and mainte-
nance standards for storage tanks, the owner/operator
must also implement regular tank inspection and
maintenance in compliance with these requirements.
the owner/operator of a facility generating wastes for
transport off-site must comply with these require-
ments, including the performance of hazardous waste
determinations and the maintenance of records regard-
ing facility activities.
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Table XI-2D
(continued)
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
NHOES Hazardous Waste Management
Regulations - Manifesting Require-
ments (NH Admin. Code He-P 1905.04)
NHOES Hazardous Waste Management
Regulations - Packaging and
Labelling Requirements (NH Admin.
Code He-P 1905.OS. incorporating.
by reference. NH Admin. Code
Saf-C-600 and 49 CFR 172, 173,
178. and 179)
NUDES Solid Waste Regulations -
treatment, Storage, and Disposal
(ISO) Facilities (RSA Ch. 149-M.
NH Solid Waste Management Act; NH
AJmin. Code He-P 1901)
NHOES Air Pollution Control Reg-
ulations - Air Pollutant Emissions
(NH Admin. Code. Air.
Parts 604 through 606)
Requires the transport of any hazardous
wastes off-site to comply with the mani-
festing and recordkeeping requirements set
forth in this provision.
Requires hazardous wastes transported off-
site to be packaged and labelled in accor-
dance with New Hampshire Department of
Safety rules and federal transportation
requirements.
These provisions establish standards appli-
cable to the treatment, storage, and dis-
posal of solid wastes and the closure of
solid waste facilities.
Thes* provisions establish limits for the
•mission of air pollutants, including VOCs
and hazardous air pollutants. Applicable
standards include the most stringent of the
following requirements:
• Federal New Source Performance Standards
(40 CFR 60)
• Federal National Emission Standards for
Hazardous Air Pollutants (40 CFR 61)
• New Hampshire State Implementation Plan
limits (set RSA I25-C:6; NH Admin. Code,
Air 101.09 and Air 606.01).
The owner/operator must properly manifest and handle.
in accordance with this provision, shipments of haz-
ardous wastes, including treatment residuals, from the
site for further treatment or disposal.
The owner/operator must package and handle hazardous
wastes, including treatment residuals, in compliance
with this provision. Containers of hazardous wastes
must be clearly marked and transport vehicles properly
placarded, prior to off-site transport.
The owner/operator of a solid waste facility must
manage, store, treat, and dispose of nonhazardous
wastes on-site. in accordance with the Solid Waste
Management Act and the rules thereof.
The owner/operator of a hazardous waste facility must
comply with the standards set forth in these provi-
sions, including the limits on the release of volatile
organic compound (VOC) contaminants into the environ-
ment .
On-site air monitoring would be required to indicate
low levels ol volatile organic compounds in the ambient
air. in and around the site. Measures would be taken
during remedial action to prevent unpermitted air
emissions from the site, including volatilization of
soil contaminants, and to prevent the release of
fugitive dust.
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Table XI-2B
(continued)
ARARs
Requirement Synopsis
Action to be taken to Attain AMARs
NNOCS Air Pollution Control Regu-
lations - Fugitive Oust (Missions
(NN Attain. Cod*. Air. Part 1002)
OSHA regulations - Safety and
Health Standards for Federal
Service Contracts
OSHA regulations - Recordkeeping.
Reporting, and Related Regulations
U9 CFR 1904)
NHDCS Hazardous Waste Management
Regulations - Waste Facility
Security Requirements
(NH Admin. Code He-F» 1905.08(d))
This provision requires prevention, abate-
ment, and control of fugitive dust during
specified activities, including construc-
tion, eicavation, and bulk hauling (see NH
Admin. Code. Air 1002.02).
This document contains instructions con-
cerning worker safety at RCRA or Superfund
hazardous waste facilities.
These regulations outline the recordkeeping
and reporting regulations for an employer
under OSHA.
Incorporates, by reference. 40 CfR 264.14 -
General facility requirement for security
measures.
Ihw owner/operator must control fugitive dust
emissions, during and .if'i-i site remediation.
All appropriate safety equipment would be on-site and
appropriate procedures would be followed during moni-
toring.
Ihese regulations would be applicable to the construc-
tion company(ies) that would be contracted to perlorm
itoring on-site.
During all site work, entry to the site would be pre-
vented by a 24-hour surveillance system. Appropriate
signs would be posted.
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ROD Summary
Auburn Road Landfill
r
The remedial action will involve the installation of groundwater
collection wells and trenches, construction of a groundwater
treatment facility and, placement of a natural and synthetic cap
over each of the source areas. During all construction and
operation activities OSHA requirements are applicable.
In the case of the selected remedy, SC-2 and MM-2, since no
direct surface water discharge is anticipated, the requirements
of the CWA are not applicable. However, CWA requirements are
considered relevant and appropriate, and the recharge trenches
will be placed so as to avoid any adverse impacts to nearby
surface waters. If HM-3 is substituted for MM-2, then the CWA
requirements are applicable, as this alternative involves
discharging to a CWA-regulated treatment facility. Any pre-
treatment permit required would have to be obtained.
Standards promulgated under the CAA for the discharge of
particulates and other pollutants are considered relevant and
appropriate to the exhaust discharge from the air stripper.
Exhaust gases will be monitored to insure compliance. To ensure
protectiveness, and consistent with EPA policy for providing air
emission control for air strippers in ozone non-attainment areas,
a carbon column will be installed following air stripping.
The Site is not a RCRA facility and therefore the requirements of
RCRA are not applicable. However, because of the previous
hazardous waste disposal practices at the Site and because
hazardous substances still remain, the requirements of RCRA are
considered relevant and appropriate. The design of the cap and
the disposal cell for the groundwater treatment residuals will be
in accordance with the relevant and appropriate portions of RCRA,
particularly State standards under the State's authorized program
that are more stringent than federal standards.
The cleanup goals for the Site were established to meet SDWA
Maximum Contaminant Levels (MCLs). Although the MCLs are
applicable to public water supplies, they are considered relevant
and appropriate at this Site. In addition, Proposed MCLs, MCL
Goals and EPA Health Advisories are considered to be TBCs. The
groundwater beyond the compliance boundary is designated a Class
II aquifer under EPA's Ground Water Protection Strategy and
therefore suitable for drinking water. The cleanup goals were
therefore established to insure the groundwater beyond the
compliance- boundary is of drinking quality.
Executive Order Nos. 11988 and 11990 deal with floodplain
management and wetland protection, respectively. These orders
are considered applicable. The groundwater treatment facility
and recharge trenches will be designed and constructed so as not
to encroach upon the 100 year floodplain or any nearby wetlands.
49
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ROD Summary
Auburn Road Landfill
Finally, a description of the above-listed State ARARs and the
actions needed to attain them can be found in Appendix F of the
FS.
C. The Selected Remedial Action is Cost Effective
Of those remedial alternatives that are protective and attain
ARARs, EPA selected a remedial alternative that is cost effective
and achieves the cleanup goals.
There were only two alternatives for groundvater remediation
evaluated in the detailed analysis chapter of the FS. As
discussed in Section X of this document, both alternatives, MM-2
and MM-3, were considered equal in cost and protectiveness. EPA
chose MM-2 rather than MM-3 only because of MM-2's relative ease
of implementation compared to MM-3.
Although the source control alternatives SC-3, SC-4, SC-5, SC-6
and, SC-7 provide varying degrees of protectiveness greater than
SC-2, SC-2 is also considered protective. However, the cost of
each of these alternatives is significantly greater than the cost
of SC-2. Taking into account the degree of protectiveness and
its associated cost, EPA considers alternative SC-2 to be cost
effective as it provides a degree of overall protection which is
proportional to its cost.
D. The Selected Remedial Action Utilizes Permanent
Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent
Practicable
The principal elements of the remedy consist of removing
contamination from the groundwater via air-stripping prior to
discharging it back to the ground. The air-stripping process is
a proven technique which provides a permanent solution to the
contaminated groundwater. This process has been used
successfully at other hazardous waste cleanup sites. As
discussed in previous sections of this document, alternative MM-3
would also satisfy this requirement. No alternative treatment
technologies are appropriate to groundwater remediation at the
Site.
50
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ROD Summary
Auburn Road Landfill
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The principal element of the selected remedy is the management of
migration portion of the selected remedy. This element addresses
the primary threat at the Site, contamination of the groundwater
by VOCs and arsenic. The selected remedy satisfies the statutory
preference for treatment as a principal element by treating the
VOCs and arsenic contamination to acceptable levels through use
of Air Stripping and Carbon Adsorption.
XII. STATE ROLE
The New Hampshire Department of Environmental Services has
reviewed the various alternatives and has indicated its support
for the selected remedy. The State has also reviewed the RI, EA
and FS to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State environmental laws
and regulations. The State of New Hampshire concurs with the
selected remedy for the Auburn Road Landfill Site. A copy of the
declaration of concurrence is attached as Appendix B.
51
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APPENDIX A
RESPONSIVENESS SUMMARY
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EPA CONTRACT NO. 68-W9-0036
EPA WORK ASSIGNMENT NO. 01-1L53
EPA PROJECT OFFICER: NANCY BARMAKIAN
EPA REMEDIAL PROJECT MANAGER: CHESTER JANOWSK]
FINAL RESPONSIVENESS SUMMARY
AUBURN ROAD LANDFILL SITE
LONDONDERRY, NEW HAMPSHIRE
SEPTEMBER 1989
PREPARED BY:
ICF TECHNOLOGY, INC.
UNDER SUBCONTRACT TO
METCALF £ EDDY, INC.
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TABLE OF CONTENTS
Page
PREFACE 1
I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN 3
II. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT
AND CONCERNS 7
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS 11
A. Summary of Resident and Other Interested Party
Comments 11
1. Potentially Responsible Parties 12
2. EPA's Preferred Alternative 14
3. Miscellaneous Comments 23
B. Summary of Potentially Responsible Party Comments. 27
1. EPA's Preferred Alternative 28
2. The Supplemental RI/FS 33
3. The Removal Action 46
IV. REMAINING CONCERNS 47
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE AUBURN ROAD LANDFILL SUPERFUND SITE IN
LONDONDERRY, NEW HAMPSHIRE
ATTACHMENT B - DETAILED SUMMARY OF POTENTIALLY RESPONSIBLE
PARTY COMMENTS
ATTACHMENT C - TRANSCRIPT OF THE APRIL 25, 1989 INFORMAL
PUBLIC HEARING
ATTACHMENT D - COST AND SENSITIVITY ANALYSIS TABLES
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Preface
The U.S. Environmental Protection Agency (EPA) held a 49-day
iublic comment period from March 31, 1989 to May 18, 1989 to
provide an opportunity for interested parties to comment on the
Remedial Investigation (RI), Endangerment Assessment (EA),
Feasibility Study (FS), and the Proposed Plan prepared for the
Auburn Road Landfill Superfund site (the Site) in Londonderry,
New Hampshire. EPA made a preliminary recommendation of its
preferred alternative for site remediation in the Proposed Plan
issued on March 22, 1989, before the start of 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 will consider all of the comments
summarized in this document before selecting a final remedial
alternative to address contamination at the Site.
This Responsiveness Summary is organized in the following
sections:
I. Overview of Remedial Alternatives Considered in the
Feasibility Study and Proposed Plan - This section
briefly outlines the remedial alternatives evaluated in
the FS and Proposed Plan, including EPA's preliminary
recommendation of a preferred alternative.
II. Site History and Background on Community Involvement
and Concerns - This section provides a brief site
history, and a general overview of community interests
and concerns regarding the Site.
III. Summary of Comments Received During the Public Comment
Period and EPA Responses to These Comments - This
section summarizes and provides EPA responses to the
comments received from residents and other interested
parties during the public comment period. In addition,
comments received from the Potentially Responsible
Parties (PRPs) are summarized and EPA's responses to
these comments are provided.
IV. Remaining Concerns - This section summarizes comments
raised during the public comment period that cannot be
fully addressed at this stage of the Superfund process
and which thus may continue to be of concern during the
design and implementation of EPA's selected remedy for
the Site. EPA provides responses to these comments and
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will address these concerns during the Remedial Design
and Remedial Action (RD/RA) phase of the cleanup
process.
Attachment A - This attachment provides a list of the community
relations activities that EPA has conducted to date at the Site.
Attachment B - This section contains a detailed summary of
Potentially Responsible Parties* comments.
Attachment C - This attachment provides a transcript of the April
25, 1989 informal public hearing on the Site, held in
Londonderry, New Hampshire.
I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN
Using information gathered during the RI (an investigation
of.the nature and extent of contamination at the Site) and the EA
(an assessment of the potential risks to human health and the
environment associated with the Site contamination), EPA
identified several cleanup objectives for the Site.
The primary cleanup objective is to reduce the risks to
public health and the environment posed by exposure to the on-
site source areas or to contamination that has migrated, or may
potentially migrate, off-site. Cleanup goals for soils are set
at levels intended to attain the desired cleanup of the
groundwater that EPA considers to be protective of public health
and the environment.
After identifying the cleanup objectives, EPA developed and
evaluated potential cleanup alternatives, called remedial
alternatives. The FS report describes the remedial alternatives
considered for addressing contamination of soil and groundwater,
as well as the criteria EPA used to narrow the list to seven
potential source control (SC) remedial alternatives and three
potential management of migration (KM) remedial alternatives.
EPA1s preliminary recommendation of a preferred alternative
to address the different aspects of Site contamination includes:
1) constructing multi-layer caps over each disposal area; and 2)
extracting contaminated groundwater and treating it by air
stripping.
REMEDIAL ALTERNATIVES EVALUATED IN THE FS
The 10 remedial alternatives considered by EPA are listed
below. The March 1989 Proposed Plan should be consulted for a
detailed explanation of these remedial alternatives as well as
EPA's preferred alternative.
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Alternatives to Address Soil Contamination
'Alternative. SC-l! No Action
-Alternative SC-2t In-Situ Closure of the Source Areas
EPA has recommended this as the preferred SC alternative.
^Alternative SC-3: On-Site Incineration/Capping of Solid Waste
Urea/On-Site Landfill
-Alternative SC-4: Excavation (All Source AreasWOn-Site Low-
Temperature Thermal Strippinq/On-site Landfill
Alternative SC-5; Excavation (All Source AreasWOn-site
Incineration/On-Site Landfill
Alternative SC-6t Excavation (All Source AreasWOf f-Site
Treatment and Disposal
Alternative SC-7t Excavation (All Source Areas)/On-Site
Composting - On-Site Landfill/Off-Site Treatment - Off-Site
.Landfill
tematives to Address Groundwater Contamination
'Alternative MM-lt No-Action
Alternative MM-2t On-Site Treatment by Extraction/Chemical
Precipitation/Air Stripping/Carbon Treatment
EPA has recommended this as the preferred MM alternative.
Alternative MM-3: Off-Site Treatment of Groundvater
II. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND-
CONCERNS
The Site is a 200-acre parcel of land in the northeastern
corner of Londonderry, New Hampshire. The Site has been the
location of sand and gravel mining operations from the late 1940s
to the present. Waste disposal occurred on the Site in four
primary areas — the Town Dump, the Tire Dump, the Septage
Lagoon, and the Solid Waste area — each of which covers from
one-half to five acres. The Town Dump operated during the 1960s
for landfilling of municipal waste, and was the disposal site for
over a thousand drums of chemical waste. The Tire Dump was
primarily vised for the disposal of tires and demolition debris,
and also was the disposal site for several hundred drums of
chemical waste. For a short time, in the mid-1970s, when the
Tire Dump area was filled to capacity, landfilling operations
shifted to a waste mound next to the Septage Lagoon. The most
recent landfilling occurred in the Solid Waste area, which
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appears to b« the largest on-site disposal area. The Solid Waste
area was active until the entire Site was closed in January 1980.
EPA involvement with the Site commenced following the
discovery by the State of Mew Hampshire of contaminants in
surface water on and near the Site and groundvater samples from
residential veils and monitoring veils. The four disposal areas
on-site vere determined to be the source of the groundwater
contamination, and so are referred to as "source areas." In
1983, due to the presence of this contamination, the Site vas
added to the Super fund National Priorities List (NPL), a list of
the nation's hazardous vaste sites eligible to receive Federal
Super fund monies for cleanup.
In 1986, EPA conducted a removal action at the Site,
consisting of excavating and removing 1,954 drums, primarily from
the Town Dump area. Also in 1986, as part of a long-term
Superfund remedial action, EPA completed a RI, which further
defined the nature and extent of contamination in the study area,
and a Focused Feasibility Study (FFS), which analyzed remedial
alternatives to address hazards posed by the contamination.
The 1986 RI identified over 80 different contaminants in the
soils, air, surface water and groundwater at the Site. EPA
determined that the contaminated groundwater flowing off-site
toward the drinking water supply wells at the nearby Whispering
Pines Mobile Home Park, and potentially to other private
residential veils on Auburn Road, posed a potential risk to human
health and the environment. A replacement waterline to area
residents, vhich EPA identified in the FFS to be the most
protective of human health, became operational in December 1987.
It vas constructed and paid for by the Town of Londonderry (the
Town), one of the former operators of the Site under an
administrative order issued by EPA.
EPA recently completed a Supplemental RI to collect
additional information necessary to select an overall cleanup
plan to address the four source areas and contaminated
groundwater on-site. In 1988, while conducting field activities
for the Supplemental RI, EPA discovered 360 additional drums
buried in the Tire Dump. EPA subsequently excavated and removed
these drums.
Using data collected during the RI and Supplemental RI, EPA
developed a FS that includes the seven SC remedial alternatives
to address .the four landfill areas, and the three KM remedial
alternatives to address contaminated groundwater.
One of the Town residents' foremost concerns continues to be
the possibility that all of the barrels have not been removed.
They question what action would be taken should either more
barrels or contaminants be found on the Site in the future. Many
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citizens have also expressed concern regarding the extent of
groundwater contamination, as well as the possibility that
private veils nay have been contaminated before EPA established
an alternative drinking water source. Citizens continue to be
concerned about the possible adverse economic impact the Site
could have on the Town.
A complete list of community relations activities conducted
at the Site is included in Attachment A at the end of this
document.
III. SUMMARY OP COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments EPA
received during the public comment period held from March 31,
1989, to May 18, 1989. Eight sets of written comments were
received: 1 from a resident, 1 from an interested party and 6
from potentially responsible parties (PRPs). In addition, four
oral comments were received at the informal public hearing held
on April 25, 1989. All of these comments are summarized below
and a detailed summary of PRP comments is included in Attachment
B. A copy of the transcript from the informal public hearing is
included in Attachment C of this document and is available at the
Site information repositories at the Londonderry Town Hall,
Londonderry Public Library, and at the EPA Records Center, 90
Canal Street, Boston, Massachusetts.
A. Summary of Resident and Other Interested Party Comments
Comments from a resident and an interested party, are
summarized below, along with EPA responses. The comments are
organized in the following three categories: 1) Potentially
Responsible Parties; 2) EPA's Preferred Alternative; and 3)
Miscellaneous Comments.
1. Potentially Responsible Parties
Comment a; One resident asked whether any of the PRPs could
propose to EPA one of the other more comprehensive and
costly options outlined in the FS, or whether EPA would
prevent the PRPs from implementing a more comprehensive
cleanup option, if they offered to do so.
EPA's Response; Once EPA has issued its Record of Decision,
which'Will specify the cleanup option to be implemented, EPA
will enter into negotiations with the responsible parties in
an attempt to have the PRPs either pay for the cleanup or
implement the remedy themselves. If, during those
negotiations, the PRPs propose to implement a remedy more
protective than what EPA requires and if EPA agrees with
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such a proposal, EPA will issue a revised Record of Decision
and solicit public comment concerning the changes.
Comment bt One resident referred to an article published in
the March 13, 1970 Manchester Union Leader indicating that
the State of New Hampshire was aware of hazardous materials
being disposed of at the old town landfill, and asked why
the State of New Hampshire has not been named as a PRP.
EPA1* Response; Section 107 of the Comprehensive
Environmental Response, Compensation and Liability Act,
(CERCLA) as amended, sets forth the basis of liability at
hazardous waste sites. Section 107(a) provides in part,
that the owner or operator of a facility or any person who
arranged for transportation or disposal of hazardous
substances for transport to the facility is liable for all
costs for investigation and cleanup. The mere awareness
that hazardous substances were being disposed of at the Site
is not grounds for liability under CERCLA. Therefore, the
State of New Hampshire has not been designated as a PRP at
this Site.
Comment e; One resident asked which PRPs have been
identified as having directly deposited hazardous waste in
the old town landfill.
EPA's Response; A list of all parties which EPA has
identified as potentially responsible is presented in the
Auburn Road Administrative Record and is available for
public review. Specific evidence relating to the liability
of particular PRPs is information which was compiled for
enforcement purposes, the release of which would interfere
with the Agency's enforcement proceeding. As such, it is
confidential and exempt from public disclosure pursuant to
the Freedom of Information Act, 5 U.S.C. §552(b)(7).
Comment dt One resident asked if the PRPs offered to
excavate and contain all the waste in the old town landfill
in a double-lined landfill, in a manner compliant with all
State and Federal regulations, whether EPA would allow them
to do so.
EPA's.Response! Refer to Response to A.I.a.
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2. EPA's Preferred Alternative
Comment at One resident inquired what would happen 25 years
from now after the Site is declared clean if more hazardous
waste is found in the groundvater.
EPA's Response; EPA's proposed remedy for cleanup at the
Site is expected to take from 6 to 10 years to complete.
Once cleanup is complete, the State of New Hampshire will be
responsible for monitoring the Site for 30 years. If,
during that monitoring period, it becomes apparent that
additional hazardous substances are being released which
threaten public health or the environment, then EPA will
reimplement the RI/FS procedures of 40 CFR §300.430 of the
Proposed National Contingency Plan (NCP). These procedures
would include, to the extent deemed necessary, developing a
Supplemental Remedial Investigation to characterize the
problem, preparing a Supplemental Feasibility to address
various alternatives for correcting the problem, and issuing
an amended Record of Decision.
Connnent £; One resident asked when the old Town Dump will
be capped under the proposed cleanup plan and whether the
old town landfill could be capped before the groundwater
cleanup is started in that area.
EPA's Response: As explained in the Record of Decision,
since EPA is no longer proposing soil flushing, capping of
all source areas will occur concurrently with groundwater
remediation.
Comment c; One resident asked whether EPA could submit to
him a letter stating that the implementation of the proposed
cleanup plan would ensure safe conditions for human
habitation of residential property within 500 feet of the
hazardous waste site. In addition, the resident requested a
letter from EPA stating that the proposed cleanup plan would
have no adverse environmental effects on his property, which
abuts the old town landfill. If EPA is unable to comply
with his request, the citizen asked to know why.
EPA's Response; No one can definitively predict or
guarantee the future, and EPA is no exception. EPA's ROD,
however, constitutes a declaration of EPA's belief that the
remedy selected is protective of human health and the
environment. In coming to its decision, EPA evaluated the
present and future potential risks to public health and the
environment posed by the Site. Potential public health
effects associated with the various contaminants in soil and
groundwater were estimated quantitatively through the
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development of several hypothetical exposure scenarios.
These scenarios included evaluating non-carcinogenic and
carcinogenic effects on both adults and children associated
with ingestion of groundwater, ingestion of soils and direct
contact with soils. On the basis of these evaluations, EPA
has concluded that the selected remedy is protective of
public health and the environment both directly on the Site
and in neighboring areas that nay be affected by conditions
on the Site. EPA will send you a copy of tbe ROD which,
although not in the form of a letter, addresses the concerns
you have inquired about to the best of the agency's ability.
Comment ds One resident asked whether EPA would consider a
proposal to establish a resource recovery facility on-site
as a viable cleanup option. The facility, which would
comply with Federal and State regulations, would include on-
site ash landfills. In addition, the proposal would involve
excavating and containing all of the hazardous waste located
on the property in double-lined landfills.
EPA's Response! In accordance with the National Contingency
Plan (NCP) 40 CFR §300.68(1) and 40 CFR §300.430 Of the
Proposed NCP, EPA must select a cost-effective remedial
alternative that effectively mitigates and minimizes threats
to and provides adequate protection of public health and
welfare and the environment. However, EPA would consider
any good faith proposal made by a potentially responsible
party which is as protective or more protective than EPA's
selected remedy. If the PRP's proposal is acceptable but
significantly different from EPA's selected remedy, EPA
would, in accordance with 40 CFR S300.435 of the Proposed
NCP, publish an explanation of the differences or amend the
Record of Decision. In either case, an opportunity for
public review and comment will be provided.
Comment e; One resident asked if there is any guarantee
that hazardous waste will not migrate to nearby residences.
EPA's Response; Refer to Response to Comment A.2.C.
comment ft One resident asked whether there would be
restrictions placed on future use of the Site, and if so,
what they would be.
•*
EPA's Response; The proposed capping remedy will be
designed to meet New Hampshire requirements for the proper
closure of a landfill. The State of New Hampshire has
declared the entire Site property as a waste management unit
and as such has the authority, through N.H.R.S.A. 147-A:13
8
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and 147-B:1 and the Code of Administrative Rules, He-P
1905/08 (d) (1) (d), to restrict any activity at the Site which
would be harmful to public health and welfare, and to
prevent exposure of humans and the environment to harmful
quantities of hazardous wastes. Any proposed use of the
Site must receive State approval.
Comment at One resident asked whether or not there would be
any provision to ensure that buildings or other structures
are not constructed on the Site after each area is capped
and fenced.
EPA's Response; Refer to Response to Comment A.2.f.
Comment ht Whispering Pines requested that EPA reconsider
its preliminary recommendation of Alternative MM-2 and
Alternative SC-2 for the Site, and instead select
Alternative MM-3 and either Alternative SC-3 or Alternative
SOS.
EPA's Response; In reaching its decision for the selected
remedy, EPA was required to consider nine specific criteria
(see Section VIII-B of the Record of Decision). In addition
to community acceptance, EPA must also evaluate whether the
remedy:
• Is protective of human health and the environment;
Attains all Applicable or Relevant and Appropriate
Requirements (ARARs);
• Provides for long-term effectiveness and permanence;
• Provides for reduction of toxicity, mobility or volume;
• Considers the short term effectiveness;
• Is implementable;
Is cost effective and;
• Has State acceptance.
As discussed in Section XI-C of the Record of Decision,
Alternative MM-3 is considered equivalent to the selected
Alternative except that MM-2 is deemed to be more easily
implemented because it does not require any discharge
permits or interrounicipal agreements. As further discussed
in the Record of Decision, if the agreements necessary to
implement Alternative MM-3 can be obtained, then Alternative
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MM-3 may bet substituted for Alternative KM-2.
EPA agrees that both Alternative SC-3 and Alternative SC-5
would be protective of public health. However, EPA believes
that Alternative SC-2 also provides for protection of public
health and the environment and is substantially less
expensive than either SC-3 or SC-5.
Comment is Whispering Pines stated that they believe that
Alternative MM-3 is far better than EPA's Preferred
Alternative MM-2 for three reasons: a) many of the
contaminants measured in August 1987 were already at or
below levels whereby the water could be accepted by the
Londonderry and Manchester sewage systems, (Whispering Pines
also indicated their belief that a round of samplings in
1989 would expectably provide still lower concentrations of
contaminants); b) according to the technical report, the
aeration method is only 40% effective which would mean that
contaminated groundwater would be reintroduced to the
saturated and unsaturated zones; and c) the cost to
implement Alternative MM-3 is projected to be $1,000,000
less than to implement Alternative MM-2.
EPA's Response: When evaluated using the EPA Evaluation
Criteria, Alternatives MM-3 and MM-2 are very similar, with
the primary difference being the rating for "administrative
implementability". Alternative MM-3 received a lower rating
than MM-2 for this criteria due to the uncertainty of
obtaining permits and intermunicipal agreements which are
beyond the control of the EPA. If at any time during design
the necessary agreements between the Town and the Manchester
WWTP are reached, and it can be demonstrated that off-site
discharge would not have an adverse impact on local
wetlands, then MM-3 could be substituted for MM-2.
EPA agrees that many, but not all, of the contaminants
measured in 1987 were at or below levels typically accepted
by the Manchester WWTP. However, EPA was informed by the
Manchester WWTP that limitations for contaminated
groundwater would be set on a case by case basis and are
subject to review by the NHDES. The Manchester WWTP would
consider whether the contaminants proposed for discharge
would pass through the treatment plant without treatment,
interfere with the operation of the plant, contribute to
contamination of the sludge, or contribute to health hazards
in the sewers or at the treatment plant. In the event the
above-mentioned agreements are reached, the design basis of
the groundwater treatment system would also be modified to
reflect the effluent limitations specified in the agreement.
It would not be appropriate to assume that the discharge
agreement would allow discharge without pretreatment.
10
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Point (b) of the comment suggests that inadequately treated
groundwater will be discharged back on-site. This will not
happen. Under the proposed plan, treated groundvater will
not be discharged back on-site until the levels of
contamination are reduced such that they will not cause the
groundvater to exceed cleanup levels at the Site boundary.
Air stripping would be used in combination with other unit
operations, such as activated carbon, if necessary to meet
the target levels. It is also possible that another
treatment process could be substituted for this
representative process option based on information gathered
during Remedial Design.
Comment "\; Whispering Pines stated its preference for EPA's
Alternative SC-3 or Alternative SC-5. They said that unlike
EPA's Preferred Alternative SC-2, which would leave all of
the contaminated soil in place, these two alternatives
provide a "permanent and irreversible" solution to .soil
contamination at the Site. They stated that this
alternative would also require the least amount of time to
implement.
EPA Vs. Response; EPA agrees that Alternative SC-3 and SC-5,
which involve incineration, provide a permanent and
irreversible solution to soil contamination. However, EPA
believes that the removal actions, which occurred in 1986
and 1988 and resulted in removal of approximately 2000
barrels of material, also provided a permanent and
irreversible solution to soil contamination. Contaminant
levels which remain are in the range considered to be
protective of human health. Therefore, substantial expense
of further removing contaminants from soils and wastes which
are already protective of public health and the environment
cannot be justified.
Comment kt Whispering Pines urged EPA, at the very least,
to further review the test pit and soil contamination data
to identify those areas showing the highest levels of
contamination and to excavate and incinerate those specific
soil clusters, as part of soil remediation at the Site.
EPA's Response: EPA believes that implementation of
Alternative SC-2, capping is protective of public health and
the environment. Incineration of areas showing the highest
levels of contamination would provide minimal added
protection of public health while substantially increasing
the cost of the remedy. In accordance with 40 EFR §300.68
(i), EPA is required to select a remedy that is both cost
effective and protective of public health and the
environment.
11
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Miscellaneous Comments
Comment at One resident asked what risk potential exists
for archild under the age of 15 living within 300 feet of
the old town dump to develop cancer, and what the standard
risk factor would be for a child under the age of 15 living
near such a site to develop cancer.
EPA*« Responses The exposure route for a person living near
the Site, but not going on the Site, would be inhalation of
contaminated soil (in the form of dust). Incremental
carcinogenic risk for this exposure route was calculated
using a set of very conservative assumptions, including:
• dust concentration in the inhaled air would always be
at the National Ambient Air Quality standard (NAAQS)
for particulates (O.075 mg/nf);
• all dust inhaled would have originated at the Auburn
Road Landfill Site;
• the child would continue to reside at the Auburn Road
location for his or her entire life (70 years); and
• the exposed person would be home-bound (that is, at the
Auburn Road location 24 hours per day, 365 days per
year for 70 years).
Note that the assumption that the child would continue to
reside at Auburn Road is a conservative assumption. This
would result in a higher incremental risk than a scenario
which assumes the child is under the age of 15 and leaves
the area upon reaching the age 15.
Based on this conservative scenario, the incremental
carcinogenic risk due to inhalation of dust from the Site
would be 2 X 10-5 (2 incidents in a population of 100,000).
There is no "standard risk factor" for a child living near
an NFL site. The risk due to exposure to contamination at
an NPL site is always expressed in terms of incremental
risk, since EPA acknowledges that the carcinogenic risk due
to exposures unrelated to the Site cannot be quantified.
Comment bt One resident asked what the cancer risks would
be for an adult living within 300 feet of the old town dump,
and for an adult living near such a site.
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EPA's Response; The scenario developed in response to
Comment III.A.3.a. addresses this comment with a
conservative risk calculation based on a lifetime of
exposure. The incremental carcinogenic risk stated above
would be decreased by a factor of 10 if the exposed adult
resided at Auburn Road for seven years, rather than the
assumed 70 years.
Comment ci Several residents asked whether EPA has removed
all the barrels buried at the Site and expressed the concern
that all the barrels have not been removed.
EPA's Responset EPA has undertaken significant efforts to
determine whether and where barrels may be buried at the
Site. These efforts have included magnetic,
electromagnetic, and ground penetrating radar studies and
subsurface investigations. Short of total excavation of the
Town Dump, Tire Dump and Solid Waste Area, however, there
will always be a possibility that a barrel was not detected
and removed during the previous removal activities which
took place in 1986 and 1988. Still EPA believes, that,
because of the extensive amount of investigative work
performed at the Site during development of the Remedial
Investigation and Supplemental Remedial Investigation
Reports, it is unlikely that large numbers of barrels remain
buried at the Site.
Comment d; One resident asked if additional barrels on the
Site are found to rupture and spread contaminants 15 or 20
years from now, who would be responsible for the cleanup:
the PRPs or the Federal government.
EPA's Response; In accordance with the Proposed NCP and-
Section 121(c) of CERCLA as amended by SARA, if EPA selects
a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the Site, as will
be the case in the Auburn Road Landfill site, EPA shall
review the remedial action at least once every 5 years after
the initiation of such remedial action to assure that human
health and the environment are being protected by the
remedial action. If upon such review, EPA determines that
additional action is appropriate and necessary to protect
the public health or the environment, then EPA will either
initiate the appropriate and necessary action or direct the
PRPs to take such action.
Comment e; One resident asked whether any area of the Site
could be used for a new landfill.
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EPA's Response; Ac noted in the response to Comment A.2.f.,
any future use of the Site will be subject to State review
and approval.
r%
Comment f; The New Hampshire Department of Environmental
Services (DES) expressed their concurrence with EPA's
Proposed Plan, and offered their continued assistance to
EPA, the Londonderry Sewer Commission and the Manchester
Water Works in an effort to come to an agreement regarding
the discharge of water to the Manchester Publically Owned
Treataent Works (POTH).
EPA's Response; No Response Required
B. Summary of Potentially Responsible Party Comments
Six sets of written comments were received from PRPs,
including:
Peter A. Johnson and Grassy Knolls Associates (Peter
Johnson);
Work Place Systems;
the Town?
Sanders;
Xentex Company (Xentex); and
a group of nine PRPs, (BASF Corporation; Disogrin
Industries Corporation; General Latex and Chemical
Corporation; Peter Johnson; Sanders a Lockheed Company;
the Town; Waste Management of North America,
Incorporated; Workplace Systems, Incorporated; and W.R.
Grace - Conn) vho sponsored a report by Canonie
Environmental Services Corporation (Canonie).
In addition, one PRP representative offered oral comments at
the public hearing.
The main points made by each of these PRPs are summarized
briefly below. A more detailed summary of PRP comments is
included in Attachment B. The PRP comments are organized in the
following three categories; 1) EPA's Preferred Alternative; 2)
The Supplemental RI/FS; and 3} the Removal Action.
1. EPA's Preferred Alternative.
Comment at Work Place Systems stated that there is not
enough data available regarding the distribution and
migration of site contamination in the overburden and
bedrock aquifer to support Alternative MM-2.
EPA's Response; The groundwater collection and recharge
scheme presented for Alternative MM-2 is conceptual in
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nature and consistent with the level of design recommended
by EPA RI/FS guidance. The information collected adequately
supports EPA's conclusion that target cleanup levels are not
being met, and supports the selection of a remedial
alternative consisting of groundwater collection, on-site
treatment and discharge.
Water quality data acquired by the EPA is adequate to
characterize the distribution and migration of Site
contamination. While the EPA data is adequate, the agency
does recognize that further characterization of water
quality conditions will be necessary for Remedial Design.
The precise scope of the groundvater treatment system will
be determined on the basis of further data obtained during
the Remedial Design phase.
Comment b; Work Place Systems stated that Alternative MM-2
is not likely to remove ketones from the groundwater.
EPA's Responset Although the effectiveness of the proposed
treatment system on ketones is limited, it is reasonable to
expect that the system removal efficiency will be sufficient
to meet the cleanup goals. The only ketone for which a
target cleanup level has been established is 2-Butanone.
The design influent concentration of 2-Butanone will be
determined under pumping conditions during Remedial Design.
The development of the clean-up goal for 2-Butanone is based
on an EPA Health Advisory and as such is not a requirement,
but rather a consideration. If during treatability studies,
to be conducted during design, EPA determines that the goal
of 172 parts per billion (ppb) cannot be obtained with the
treatment system proposed, EPA will perform a risk analysis
to see if the levels which can be obtained fall within the
acceptable risk range (10"* - 10 ). If in order to fall
within the acceptable risk range, additional treatment for
2-Butanone is still necessary, EPA will evaluate heating the
groundwater influent. This has been shown to improve the
efficiency of an air-stripper in removing 2-Butanone.
Comment c; Work Place Systems, Peter Johnson, the Town, and
Canonie stated that it is unclear why flushing of the source
areas is proposed when it is not recommended in the FS
screening.
-*
EPAfs Response; The proposed remedy provided for returning
a portion of the treated groundwater to the Solid Waste
Landfill and to the section of the Tire Dump where the 1988
drum removal was performed. The intent was to try to flush
contaminants from the soils to the groundwater where it
would be collected and treated. This would be nothing more
15
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than accelerating the natural flushing which presently
occurs. However, in consideration of comments received
during; the comment period, and upon further review of
flushing techniques as applied to the Site, EPA agrees that
the effectiveness of flushing contaminants at the Solid
Waste Landfill is questionable, due to the types of
materials located in the area, the proximity of the debris
to bedrock and the difficulty in controlling leachate.
Accordingly, flushing of contaminants at the Solid Waste
Landfill has been eliminated from the selected remedy.
Flushing is still considered a viable option at the Tire
Dump, where none of the above concerns apply. However,
based on the most recent groundwater sampling conducted by
Canonie Environmental of Indiana, groundwater emanating from
the Tire Dump meets drinking water standards. There is no
longer a need to flush contaminates from the soils to aid in
groundwater cleanup. Therefore, flushing of soils at the
Tire Dump has also been eliminated.
Comment dt Sanders stated that the remedy proposed for the
Site nay not be effective and practical, and may even
exacerbate existing conditions at the Site.
EPA's Response; EPA disagrees with this comment. The
detailed evaluations of SC-2 and MM-2 presented in Section 4
of the FS demonstrate that these alternatives would be
implementable using proven technology and would result in a
remedy which is protective of public health and the
environment.
The reference to "exacerbation" of existing conditions was
specific to the proposed discharge of a portion of the
treated groundwater onto the source areas. As discussed,in
response IZl.B.l.d, flushing of soils at this Site is no*
longer being considered. As a technical matter however, the
adverse impact to which Sanders referred could only occur if
flushing water were applied at a rate that caused
contaminated groundwater from the source area to flow
outside of the influence of the groundwater collection
system. This will not occur if the collection system is
properly designed, and if the recharge and collection
process is properly operated.
Comment e: Xentex commented that due to a seriously
deficient and fundamentally flawed Supplemental RI/FS,
Xentex could not recommend a preferred alternative for
either groundwater or soil contamination. And, that since
the scientific and technical basis is inadequate, such a
selection would be whimsical and arbitrary. They urged EPA
to address the deficiencies before the Site ROD is signed.
16
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EPA's Response; EPA disagrees with the statement that there
are serious deficiencies or fundamental flaws in the
Supplemental RI or the FS. Minor errors or omissions have
been pointed out in the public comments, and these are
addressed in this Responsiveness Summary. None of the
errors or omissions significantly affects the
characterization of site conditions presented in the
Supplemental RI or the evaluation of alternatives presented
in the FS. The Supplemental RI and the FS were performed in
accordance with the latest EPA guidance (OSWER Directive
9355.3-01) and provide a sound basis for the selection of a
remedy. Moreover, the most recent round of data obtained by
Canonie on behalf of the PRP offering this comment, among
other PRPs, further confirms the validity of the scientific
and technical assumptions made in the RI/FS.
The Supplemental RI/FS
Comment a; Work Place Systems generally concurred with the
report prepared by Canonie.
EPA's Response; No Response Required
Comment b; Work Place Systems, the Town, and Peter Johnson
stated that the sampling data upon which much of the
preferred alternative was based is unreliable and that field
blanks were reported to be contaminated.
EPA's Response; The allegations that errors or anomalies
exist with respect to the sampling data are unsubstantiated.
There is a simple explanation as to why more analytes were
detected in the latest round of analyses than in previous
analyses.
In brief, most of the additional analytes "found" in the
latest round of analyses were detected at very low levels,
one part per .billion (1 ppb) or less, and were flagged with
a "J". The "J" indicates that the value is an estimate,
since the analyte was detected below the Contract Required
Detection Limit (CRDL) but above the Instrument Detection
Limit (IDL). The analyte identification is na£ questionable
in the least.
In the Contract Laboratory Program (CLP), there are
approximately 100 laboratories that have been inspected by
EPA and these are contracted to perform routine sample
analyses for Superfund sites. Since there are so many
laboratories in the CLP, standardized detection limits, i.e.
the CRDLs, were developed. These CRDLs must be achieved by
every instrument in every laboratory.
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In addition, every instrument has a particular instrument
detection limit (IDL) that is unique to that instrument and
time period. That IDL must always be below the CRDL. SiD££
each instrument has a different IDL for low pointK it is
quite reasonable for the latest set of Auburn Road analyses
to have more low level "contamination" detected than in the
previous analyses . Values between the IDL and the CRDL are
positive identifications of compounds; however, the
quantitation of these values can only be estimated. These
variances can account for insignificant differences between
laboratories and between samples. The comparisons are
therefore, invalid.
The allegations that "poor laboratory practices resulted in
•carry over* of high-level standards into the test samples,11
and also that "the blanks for the samples were similarly
contaminated," are totally unfounded. The PRP's own
consultant stated in her report that on the basis of the
information she reviewed, "carry over" of high-level
standards into the test samples could not be substantiated.
The CLP analytical methods, quality control procedures and
deliverables are the standards by which the rest of the
environmental chemistry community is judged. Ms. Stewart's
statement that "it is good lab policy to run a blank in any
chamber which has had a standard greater than 50 ppb" is
incorrect. The CLP methods do not require a blank to be run
in each of those chambers, nor would standards with
concentrations greater than 50 ppb be used in the CLP if
there was concern with routine "carry over."
The laboratories awarded contracts by the CLP are required
to have a rigorous in-house Quality Assurance/ Quality
Control (QA/QC) program. They must also undergo periodic
on-site evaluations by EPA and they are required to analyze
Quarterly Blind Performance Evaluation samples four times a
year to demonstrate acceptable performance. Even so, blank
contamination exists in every laboratory and can arise from
a multitude of sources. It is true that York Laboratory am
NANCO had blanks containing several low level contaminants.
Analytes potentially affected by blank contamination were
flagged on Table D-l with a "B" to alert the data user.
Comment ct Peter Johnson stated that the no-action
alternative was not properly evaluated.
EPA's .Responses The No Action alternatives for source
control and management of migration were evaluated in
accordance with the National Contingency Plan and EPA
guidance on preparation of RI and FS. The propriety of
EPA's evaluation of the KM-1, No Action, alternative is
further discussed in response to Attachment B.3.i.
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Comment di Peter Johnson, the Town, Sanders, Canonic, and
Xentex all commented that the Supplemental RI does not
properly characterize groundvater at and around the Site and
does not define the nature and extent of currently existing
groundwater contamination.
EPA's Response; While EPA had characterized groundwater in
a technically acceptable manner at the time when this .
comment was offered, EPA acknowledged the value of having
further data in authorizing Canonic to perform additional
groundwater sampling. EPA still recognizes that current
site conditions will have to be further evaluated during
Remedial Design. This will include another round of
groundwater samples to characterize the current groundwater
conditions as well as additional surface water and sediment
samples.
Comment e; Canonic commented that the Supplemental RI/FS
proposes remedial alternatives which are unsupported by Site
investigations.
EPA's Response; EPA disagrees with this statement. The FS
presents a range of remedial alternatives for Source Control
and Management of Migration which were developed to address
specific conditions on-site and off-site. The alternatives
were evaluated in detail in conformance with the latest EPA
FS guidance (OSWER Directive 9355.3-01). While Canonie
evidently disagrees with the remedy selected, the substance
of the comments presented by Canonie regarding the
development and evaluation of remedial alternatives does not
support a departure from the chosen remedy for the reasons
specified below.
Canonie made numerous comments which suggested a basic lack
of understanding of the Feasibility Study process:
o Canonie repeatedly presented assertions that design-
level hydrogeologic investigations had not been
performed, indicating that it failed to understand the
distinction between FS and Remedial Design activities.
The FS evaluates and compares alternatives
conceptually. EPA requires that further hydrogeologic
investigations will be necessary during Remedial
Design.
o Canonie also questioned the "representative process
options" for capping and physical/chemical treatment,
indicating that it failed to understand the
representative process option concept and the
information presented in Figures 3-1 and 3-2 of the FS.
As stated in "Guidance for Conducting RI/FS's under
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CERCIA" (OSWER Directive 933.3-01):
One representative process option is selected, if
r possible, for each technology type to simplify the
subsequent development and evaluation of
alternatives without limiting the flexibility
during remedial design.
A clay cap as a source control alternative or
oxidation/reduction as a management of Migration
alternative were not eliminated but were not chosen as
"representatives" of a technology type.
The underlying assumptions in the cost estimates for
the Canonie alternatives differed so completely from
those in the alternatives in the FS, and were so biased
in favor of the Canonie alternatives, that no
meaningful cost comparison could be made. Examples of
this include:
• Canonie alternatives MM-4A and MM-5A were costed
based on a 30 gallon per minute(gpm) flow rate
operating at 24 hours per day. Alternative MM-2A
in the PS was based on a flow rate of lOOgpm
operating for only 8 hours per day. However, the
Canonie alternatives did not adjust the labor
hours to account for the increased operation time.
Canonie has not included any provision for removal
of metals. Canonie's text states that treatment
for metals removal is not necessary when
UV/peroxide technology is used. Manufacturers of
the equipment associated with this technology,
however, recommend treatment to remove iron if
iron concentration exceeds approximately 5 mg/1.
•
Canonie neither included a cost for an on-site
laboratory, nor increased costs to allow for off-
site analysis. The on-site laboratory cost
carried for Alternative KM-2 was $605,000.
Similar groundwater treatment facilities at
Superfund sites are required to conduct daily
influent and effluent monitoring for indicator
chemicals at a minimum. Canonie's cost estimates
thus fail to provide for the implementation of
this crucial method of determining plant
efficiency and compliance with clean-up standards.
The cost provided by Canonie for the treatability
study is equal to 10% of the cost treatability
study cost provided by Weston. This clearly
indicates a different scope of "treatability
20
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study" than costed for the other alternatives.
The cost estimates of all of Canonic's
alternatives are based on a labor force of one
person working an eight hour shift, five days per
week. Canonie's text, however states that the
alternatives were costed based on a total of two
full-time operators for the 30 gpm system and five
full-time operators for the 250 gpm system.
Neither the costs provided in Canonie's estimate
nor those suggested in the text are adequate. In
preparing EPA's cost estimates, Weston included
continuous coverage by two people, the minimum
allowable number of operators under OSHA, 29 CFR
1910.120(d)(2), 3/6/89, Final Rule, a regulation
specifically cites any cleanup required by a
government agency. Adjusting Canonie's estimates
to be in compliance with OSHA would result in an
overall increase to each of Canonie's alternatives
of approximately $3,000,000, as each of the
alternatives are specified as having 24 hour per
day/7 days per week operation.
o Canonie's statement in the text that certain off-site
monitoring activities should be eliminated would
jeopardize the remedial goals of compliance with ARARs
and protectiveness of human health and the environment.
Limiting the scope of residential well monitoring and
off-site surface or ground-water monitoring would
prevent EPA from verifying protectiveness. Canonie's
proposed KM alternatives would not meet OSHA ARARs.
Canonie's alternatives also may not provide compliance
with ARARs in the event that influent to the treatment
system exceeds the arsenic MCL.
o Comments regarding pretreatment limitations and
monitoring requirements assumed by EPA (for MM-3) imply
that the terms and conditions of a discharge agreement
should be negotiated at the FS stage prior to the
selection of a remedy. The feasibility study must be
based on conservative assumptions regarding these terms
and conditions.
Comment f; Peter Johnson commented that the Supplemental
RI/FS fails to properly consider or price the alternative of
excavating and placing the existing landfills into a state-
of-the-art cell with leachate collection systems.
EPA's Response: The excavation and on-site placement of
wastes into a state-of-the-art cell with leachate collection
systems was addressed in Chapter 3 of the FS report. This
21
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technology was developed into preliminary alternatives (PSC-
9, PSC-10, and PSC-ll) for each source area. Wastes
excavated from the source areas would be tested and, for
•one of the waste, treatment would likely be required prior
to placement.
As also noted in the FS text, the secure landfill process
option was retained for combination with other process
options into several of the site-encompassing Source Control
alternatives. As such, Alternative SC-4 and SC-7 both
include the complete cost of excavating and placing 240,000
cubic yards of material (the combined volume of the source
areas) in a RCRA-type landfill. The cost of implementing
only a landfill, with no allowance for the potential
requirement of treatment prior to placement, would be
approximately $18,000,000, as compared to a total of
$7,500,000 for the chosen alternative, which is also
protective of public health and the environment. This
$7,500,000 includes all present worth operation and
maintenance costs (groundwater monitoring, cap maintenance,
etc.).
Mr. Johnson1s comment also downplays the issue of air
emissions from the source areas and suggests that compliance
with standard health and safety provisions might be
optional. On the contrary, EPA's cost estimate for all
alternatives requiring excavation of source areas must
include, and did consistently include, an allowance for air
emissions controls, ambient air monitoring at site
boundaries, and equipment and supplies to protect personnel
from potential vapor emissions. Volatile organic chemicals,
including several indicator chemicals, have been measured in
ambient air at and near site boundaries. This data is
presented in Chapter 7 and Appendix G of the NUS RI. The
potential also exists for an unexpected release of
contaminants uncovered during excavation, and EPA must be
prepared to protect its workers, prevent emissions, and
document that these controls were protective during these
occurrences. In addition to potential emissions of toxic
contaminants, the emission of objectionable malodorous
organic gases is expected during excavation, and these
emissions must be controlled to prevent creation of a public
nuisance.
Comment o; The Canonie report observed that cost estimates
for the various alternatives are not always consistent. In
addition, the report notes that there is no explanation in
the Supplemental FS as to why different factors are used to
determine cost estimates for the various alternatives.
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EPA's Response; Canonie correctly notes two minor
inconsistencies in cost estimation contained in the FS
report. Both errors occurred in the costing of MM-3.
Specifics are discussed in Attachment 8, of Canonie's
comments. In response to these comments, the costs for KM-3
were recalculated and a new sensitivity analysis performed.
The new costs are as follows:
MM-3 MM-3A
Small system Large svstero
Capital Costs $2,460,000 $4,030,000
Present Worth/OiM 4,750,000 12,100,000
Total Cost 7,210,000 16,100,000
50% Confidence
Interval $6 - 8.4 million $13 - 18 million
As can be seen from a comparison of the above summary and
the cost summary in the FS (ES-9), the overall cost of MM-3
increased approximately $100,000, while MM-3A decreased by
approximately $100,000. A comparison of the numbers from
the old and new sensitivity analyses show no significant
differences in the costs.
In EPA's opinion, the minor errors which existed in the
costing of MM-3 did not prejudice the process of choosing a
preferred alternative. The new cost and sensitivity
analysis tables (Attachment D, Tables H-3, II-3-A, IV-2 and
IV-2-A) are attached.
Comment ht Sanders, Peter Johnson, and Canonie suggested
that another source of contamination may exist off-site, to
the north or northeast.
EPA's Response; The assertion that contamination at the
NUS-1 and NUS-2 well clusters is the result of an off-site
source is not corroborated by any of the previous studies
performed at the Site. Groundwater and plume migration have
generally been shown to be moving in a northerly direction.
The migration of contaminants from either the maintenance
shop or body shop at the Whispering Pines Trailer Park would
have to proceed perpendicularly to the flow of groundwater.
The leach fields at the trailer park are cross gradient and
down gradient of the NUS off-site well clusters, minimizing
the possibility that they might have caused the present
contamination.
On the basis of EPA's investigation, which was revisited in
light'of these comments, EPA has determined that the
possibility of significant sources of contamination other
than the four identified source areas is unlikely. However,
if any party has information or knowledge regarding the
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disposal of hazardous substances at the Site this
information should be provided to EPA.
The Removal Action
Comment at Peter Johnson stated that the barrel removal
operation and its limitations must be factored into a full
understanding of the Site.
EPA's Response; The "limitations" of the barrel removal
were considered during preparation of the RI/FS and
•election of a remedy. Specifically, Mr. Johnson's comments
question the quantity of hazardous materials actually
removed from the Site. It should be clearly understood that
all material removed from the Site required disposal at a
hazardous waste disposal facility. His assessment that only
"low levels" of contaminants were found is incorrect. The
composite sample from the seventeen drums identified as
liquid oxidizers had levels of 2-butanone, an indicator
chemical, approaching 25%. The quantity of 2-butanone in
those seventeen drums could contaminate the water beneath
the Town Dump to a concentration of greater than 70 parts
per million (ppm) , a value 400 times that of the clean up
level. This does assume that all contamination is released
at once; however, it is an illustration of what a "small"
quantity of drums containing high levels of contaminants can
do to a large quantity of groundwater.
EPA acknowledges that some of the drums removed from the
Site were empty or contained solidified wastes. However,
many of these drums contained hazardous substances and may
have contained liquids. Soils left in the ground could also
have been contaminated with leachable compounds. EPA
recognized that, despite the source reduction accomplished
through the removal of drums, remediation of residual soil
contamination had to be evaluated. Therefore, the Source
Control remedies evaluated for the Site included soil
treatment and containment alternatives.
IV. REMAINING CONCERNS
Issues raised during the public comment period that will
continue to be of concern as the Site moves into the RD/RA phase
are described briefly below, along with EPA responses.
~»
Comment a; Xentex stated that predesign studies are
necessary to refine and reassess data from the RI and to
develop design parameters for any remedy.
24
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EPA's Response; EPA fully agrees with this comment. Prior
to the final design of the selected alternative, studies
will be undertaken to define the design parameters of the
remedy with the necessary precision.
Comment b; Xentex requested that, should treatment of •
withdrawn groundwater be necessary, treatability testing
should be conducted to determine treatment processes to be
applied to recovered groundwater.
EPA's Responset Treatability testing of the process options
presented in the proposed remedy (air stripping/carbon
adsorption) will be accomplished during the pilot plant
phase of the Remedial Design. The cost of this testing was
included in the costing of each of the MM alternatives. If
this testing should show a serious deficiency with a chosen
process option, other process options would be evaluated for
use at the Site.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE
AUBURN ROAD LANDFILL SUPERFUND SITE
IN LONDONDERRY, NEW HAMPSHIRE
EPA has conducted the following community relations activities
at the Auburn Road Landfill Superfund site:
o October 1984 - EPA prepared a Progress Report
describing Superfund activities at the Site.
o May 1985 - EPA prepared a Community Relations Plan.
o October 1985 - EPA issued a report describing Progress
and Plans at the Site.
o March 28, 1986 - EPA issued a Press Release announcing
the barrel removal conducted by EPA as a removal
action.
o April 1986 - EPA issued a Summary of the Remedial
Investigation.
o April 30, 1986 - EPA held a Public Meeting to explain
the results of the Remedial Investigation.
o July 1986 - EPA issued a Summary of the Focused
Feasibility Study.
o July 24 - August 14, 1986 - EPA held a public comment
period on the Focused Feasibility Study.
«
o July 30, 1986 - EPA held a Public Meeting to announce
the results of the Focused Feasibility Study.
o August 6, 1986 - EPA held a Public Hearing to record
public comments on the results of the Focused
Feasibility Study.
o August 27, 1986 - EPA issued a Community Newsletter.
o September 17, 1986 - EPA issued a Press Release
announcing plans to install a waterline to homes near
the Site.
o October 7, 1986 - EPA issued a Community Newsletter.
o October 16, 1986 - EPA issued a Community Newsletter.
26
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October 22, 1986 - EPA issued a Community Newsletter.
f ^
October 31, 1986 - EPA issued a letter to residents
regarding a site tour and completion of the removal
action.
November 6, 1986 - EPA issued a Community Newsletter.
November 24, 19B6 - EPA issued a Press Release
announcing the review of the Endangerment Assessment.
February 23, 1987 - EPA issued a Press Release
announcing the Administrative Order.
September 23, 1988 - EPA issued a Press Release
announcing a removal action at the Site.
March 1989 - EPA prepared a Proposed Plan to describe
the cleanup alternatives and the Preferred Alternative
considered for the Site.
March 17, 1989 - EPA issued a Press Release announcing
the Public Meeting to explain the proposed cleanup plan
for the Site.
March 22, 1989 - EPA held a public meeting to discuss
the proposed cleanup plan.
March 22, 1989 - EPA issued a Press Release announcing
an additional public meeting to discuss the proposed
cleanup plan for the Auburn Road landfill site.
March 30, 1989 - EPA held an additional public meeting
to provide a second opportunity for the public to learn
about EPA's preliminary recommendation for cleanup of
the Site.
March 23 - May 18, 1989 - EPA held a public comment
period to provide an opportunity for public involvement
on the final cleanup decision.
April 17, 1989 - EPA issued a Press Release announcing
the change in location for the public hearing.
April 25, 1989 - EPA held a public hearing to record
public comments on the proposed cleanup plan.
April 25, 1989 - EPA issued a Press Release announcing
the extension of the comment period.
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ATTACHHENT B
DETAILED SUMMARY OF POTENTIALLY RESPONSIBLE PARTY COMMENTS
This Attachment provides a detailed summary of PRP comments
received by EPA during the public comment period. The comments
are organized in the following categories: 1) EPA's Preferred MM
Alternative; 2) EPA's Preferred SC Alternative; 3) The
Supplemental RI/FS; 4) the Overall Preferred Remedy; 5) the Site
Removal Action; and 6) Community Relations and the Public Comment
Period.
1. EPA's Preferred KM Alternative
Comment a; Work Place Systems stated that the RI/FS does
not provide data to support the placement and location of
deep bedrock extraction veils, because it is not known
whether such pumping would draw contaminants from the
overburden and contaminated areas into the previously
uncontaminated deep bedrock areas.
s Response; EPA agrees with Work Place Systems that the
location and depth of bedrock wells needs further refinement
in the Remedial Design phase of the project. A depth of 300
feet was discussed in the FS based on contamination known to
be present in bedrock wells greater than 200 feet in depth.
Additionally, according to the NUS RI, significant fractures
were found along the entire length of several of these 200-
foot wells and significant water bearing fractures were
found at depth. Therefore, the 3 00- foot depth was
conceptually chosen to provide a conservative drilling cost
estimate, representative of depths to achieve hydraulic
control and capture of contaminants.
Based on data contained in the Remedial Action Assessment
Investigation (RAAI) , EPA acknowledges the possibility that
bedrock contamination may be isolated in the top 15 to 20
feet of bedrock, in which case the well installation program
will be modified accordingly. As noted these determinations
will be made during Remedial Design.
Comment b; Work Place Systems stated that the overburden
extraction wells proposed to the north of the solid waste
landfill are not likely to extract the quantity of water
indicated in the FS because of the limited saturated
thickness and shallow depth to bedrock in this area.
s Response t While it is true that the area immediately
adjacent to the landfill has limited overburden saturated
thickness and high bedrock, this is not where the overburden
28
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extraction veils are proposed to be located. As shown in
Figure 4-18 of the FS, the conceptual groundwater collection
system includes extraction wells placed approximately 300
feet north of the landfill. It may be advantageous to
locate wells in weathered bedrock close to the landfill, but
this will require confirmation during Remedial Design.
The yield of the overburden wells was estimated based oh
hydraulic conductivity measurements collected during the
supplemental RI for wells in the area north of the Solid
Waste Landfill. Calculations for conceptual design pumping
rates from wells and trenches are provided in Appendix G of
the FS.
The placement of the wells to the north of the landfill
would not only facilitate increased pumping rates, due to
the increased saturated thickness, but would also help to
capture contaminated groundvater which has migrated to the
north of the Solid Waste Landfill. The monitoring wells in
the area of the proposed extraction wells contained elevated
levels of several indicator chemicals during the 1987
sampling performed by Weston.
Comment c; Work Place Systems, the Town and Canonie noted
that several of the primary contaminants at the Site are
ketones (such as 2-butanone and acetone) and that EPA's
Preferred Alternative MM-2 is not likely to remove them from
the groundwater. The Canonie report suggested two other
technologies as alternatives to treat ketones: 1) fixed bed
biological reactors, and 2) ultraviolet light with ozone
and/or hydrogen peroxide.
EPA's Response: As discussed in response to comment
III.B.l.c, EPA is fully aware of the limitations of the air
-stripping process with respect to removal of ketones,
specifically 2-butanone. However, EPA expects the proposed
process will be capable of attaining compliance with the
target cleanup levels. In any event, the Record Of Decision
specifically provides for the possibility that air stripping
could be supplemented by other technologies, such as
ultraviolet destruction, if necessary.
Comment d: Sanders, Canonie, and Xentex stated that when
selecting the remedy, inadequate consideration was given to
the following factors:
- aquifer thickness;
- contamination levels;
- groundwater flow patterns;
groundwater extractability rates;
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bedrock permeability;
- hydraulic gradients; and
• groundvater Bounding.
r _
Overall, commentors commented that the subsurface
environment has been inadequately defined and that
additional groundvater samples should be collected.
EPA's Response; The extensive subsurface investigations
performed at the Site provide sufficient information to
support the interpretations of subsurface conditions
presented in the RI, the Supplemental RI and the FS. The
concept of "defining11 the subsurface environment is
misleading, since no level of investigation can provide
absolute definition. Hydrogeologic investigations, by their
very nature, rely heavily on interpretation of a finite
amount of data and inference of site conditions between data
points within the study area.
Of the seven factors listed in this comment, two factors
(contamination levels and groundwater flow patterns) were
considered and evaluated throughout the RI/FS process, as
clearly indicated in the NUS RI, Supplemental RI and, the FS
Report. The other five factors are primarily relevant to
the evaluation of the No Action alternative (MM-1), and to
the design of groundwater remediation alternatives (MM-2 and
MM-3). Examples of tasks in which these five factors were
considered will be presented here, in the order presented in
the comment.
Aquifer thickness (saturated overburden thickness) was
considered during interpretation of the subsurface flow
regime, during development of conceptual groundwater
interception and collection systems at the source areas, and
during development of the conceptual groundwater collection
and recharge programs. Aquifer thickness is depicted in the
RI in subsurface profiles (Section 5 and Appendix C) and the
overburden isopach (Figure 5-1). Thickness of saturated
overburden at various collection trench and overburden
extraction well locations is presented in the design
calculation summary in Appendix G of the FS.
Groundwater extractability rates were considered during
development of the capping alternatives (SC-2 and SC-3) and
the groundwater collection and treatment alternatives (MM-2
and MM-3). The rates were estimated using the Theis
equation. Hydraulic conductivities were based on pump test
data (RI Section 5 and Appendix D), hydraulic test data
(Supplemental RI Section 4 and Appendix F, and RI Section 5
and Appendix H), grain size analyses (RI Appendix G) and
literature values for similar soils. The other inputs to
the rate calculations were based on site-specific conditions
30
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and literature values, where appropriate. This level of
consideration is adequate to support remedy selection and is
not purported to be adequate for Remedial Design.
EPA interprets the term "bedrock permeability" in the
comment to refer to yields of bedrock wells under pumping
conditions. Bedrock well pump tests are not typically
performed during an RI, but rather are a component of
Remedial Design. Accordingly, bedrock aquifer testing has
not yet been performed at the Site.
Hydraulic gradients were evaluated based on seven rounds of
static water level measurements during the RI and the
Supplemental RI. Groundwater contour mapping was performed
based on each set of data. The conceptual groundwater
interception and collection systems at the source areas, and
the conceptual groundwater collection programs, were devised
based on theoretical calculations of pumping rates necessary
to control hydraulic gradients in areas of groundwater
contamination (Feasibility Study Appendix G).
Vertical hydraulic gradients, indicating conditions of
discharge to or recharge from overburden to bedrock systems,
were evaluated and discussed in Section 5 of the RI.
Vertical hydraulic gradients which influence the depth of
contaminant migration in the overburden are discussed in the
RI (Section 5) and the Supplemental RI (Section 4.2). The
conceptual overburden extraction well locations were
selected to intercept contaminants flowing at depth in the
overburden, in the location of the bedrock trough depicted
in the RI (Plate 4, Bedrock Contour Map, Appendix C
Crosssection D-D1, Figure 5-16, Inferred Toluene Contaminant
Distribution, and Figure 5-17, Inferred Trans-1,2-
dichloroethene Contaminant Distribution).
Comparison of hydraulic gradients between overburden wells
and adjacent surface waters was performed during the RI and
discussion of the significance of this information is
presented in Section 6.
Groundwater mounding considerations are relevant to design
of Alternative KM-2, wherein treated groundwater would be
discharged back into groundwater. Groundwater mounding
during discharge of water to the Solid Waste Landfill, as
discussed in the Response to Comment III.B.l.e, is no longer
a concern since soil flushing has been eliminated. Other
groundwater discharge areas vould be outside of the
contaminated areas and recharged water would meet target
cleanup levels. Thus, mounding would not jeopardize the
effectiveness of the remedy.
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With respect to the overall comment that further definition
of the subsurface environment is needed and that further
groundvater sampling should be performed, as noted earlier,
EPA fully recognizes the need for more detailed information
prior to the implementation of the remedy. Such information
will be obtained during the Remedial Design.
Comment et Sanders stated that the adverse impacts of the
proposed KM Alternative have not been considered, and
questioned why EPA would propose to treat groundwater that
has already reached target cleanup levels at the risk of
further or renewed environmental damage.
EPA• s Response; EPA does not propose to treat groundwater
which is already at or below target levels. Prior to the
implementation of any groundwater recovery and treatment
system, a comprehensive sampling program would be undertaken
to assess current groundwater quality. The effectiveness of
the remediation program would be assessed by periodic
sampling of the monitoring wells at or near each source
area. When groundwater at each source area achieves the
cleanup levels, the use of that particular portion of the
recovery system would be discontinued.
As currently designed, EPA anticipates no adverse impacts to
the environment at the Site due to implementation of the
proposed alternative. This would be confirmed during
Remedial Design studies and, if necessary, modification to
the proposed remedy would be made prior to Remedial Action.
Comment fi Sanders stated that the extent of bedrock
aquifer contamination has not been documented and suggested
that the effectiveness of groundwater treatment be
demonstrated before proceeding with numerous bedrock wel^s,
especially since bedrock aquifer cleanup has not been shown
to be feasible in New England, in the past.
EPA's Response; The extent of bedrock contamination will be
further evaluated in Remedial Design, as will the
effectiveness of the groundwater treatment system. Cleanup
of groundwater in bedrock may be facilitated on this cite
due to the preferential flow path associated with the
bedrock trough which extends across the central portion of
the Site.
.4
Comment o; Sanders commented that the treatment of
inorganic arsenic by metal hydroxide precipitation to a 50
parts per billion (ppb) level is probably not feasible.
EPA's Response; The effectiveness of arsenic removal, via
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precipitation, will be evaluated during Remedial Design
based on groundvater characteristics under pumping
conditions. Removal of arsenic to 50 ng/1 is feasible using
the treatment system described in the FS. Chemical
precipitation using lime has produced removal efficiencies
ranging from 25 to 99% (EPA 600/2-82-0010). Based on the
most recent groundvater sampling data in wells that have
levels of arsenic which exceed the drinking water standards,
the average concentration of arsenic is 126 ppb. At this
average concentration, the precipation unit would need to
remove only 60% of the arsenic to attain the MCL of 50 ppb.
Comment ht Sanders suggested that the feasibility of
discharging groundwater to a municipal wastewater treatment
plant should be considered since biological treatment would
be effective on many of the remaining compounds of concern.
EPA's Responset As discussed previously, in Attachment
B.I.a, discharge of groundwater to the Manchester WWTP would
be viable under certain circumstances. Biological treatment
would effectively remove certain of the indicator chemicals,
particularly toluene and 2-butanone. The level of
pretreatment required would be specified in the agreement or
permit regulating this discharge. It would not be
appropriate to assume that the agreement would allow
discharge without pretreatment.
Continent i; the Town stated that performance of a
groundwater treatment remedy based on target cleanup levels
that night be met before the remedy is implemented, would
conflict with the requirement in CERCLA, as amended by SARA,
that remedies be cost-effective.
EPA's Response: EPA has no reason to believe that
groundwater cleanup would occur naturally within two years,
the time necessary to implement the Remedial Action. The
selected remedy is cost effective because its cost is
proportionate to what it accomplishes. None of the other
alternatives evaluated achieve as high a degree of
protectiveness for less money.
Comment -\: the Town stated that EPA's preferred groundwater
collection methods do not appear to have been designed with
actual site conditions in mind.
EPA's Response; EPA disagrees with this comment.
Information presented in Section 4.3.2 and Appendix G of the
FS indicates clearly that hydrologic evaluation of site
conditions formed the basis of the conceptual groundwater
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collection systems presented. Approximate locations of
collection trenches and overburden extraction wells were
based on consideration of site-specific soil types,
hydraulic conductivities, saturated thickness, and other
variables presented in the Appendix G engineering
calculations. The yields calculated for these collection
systems are representative and appropriate for conceptual
cost estimation purposes. Final locations of extraction
veils and trenches and extraction volumes will be determined
during Remedial Design.
Comment let Peter Johnson stated that any proposed treatment
scheme must balance the time of constructing the treatment
facility with the speed of the ground-water through the Site.
Based on the speed figures in the Supplemental RI/FS, Peter
Johnson observed that nearly all of the pollution on-site at
the last round of sampling would have left the Site and
would be more than a mile away by the expected beginning of
actual groundwater treatment. Peter Johnson stated that, by
the time any proposed treatment plan could be in effect, the
data on which it is based would be 5 years old; and that it
is foolish to design a treatment plant in 1989 based on 1987
facts for implementation in 1992. It was also stated that
no analysis has been done as to where the contamination
might actually be in 1992.
EPA's Response; EPA recognizes that groundwater quality
conditions will have to be evaluated during Remedial Design.
The statements made by Mr. Johnson with regard to
contaminant transport are based on a gross
oversimplification of the groundwater flow regime. The
statement that groundwater treatment will be based on 5-year
old data is incorrect. Groundwater conditions will be '
evaluated throughout Remedial Design and treatment on the
basis of ongoing sampling.
Comment l! The Canonie report recommended that:
surface water monitoring is not necessary at the Site;
monitoring of residential wells to the west and
northeast of the Site is not necessary; and
* that any off-site monitoring program should focus on
volatile organic compounds.
EPA's Response; The proposed environmental monitoring
program for the Site must insure that the proposed remedy is
protective of public health and the environment.
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Although limited studies to date have not indicated
contamination in on-site streams and Whispering Pines Pond,
contamination due to runoff is a possibility and therefore,
monitoring is warranted. In addition, Cohas Brook is
considered to be the ultimate receptor of overburden
groundvater flow from the Site.
The monitoring parameters were determined based on the types
of contaminants found in the on-site wells and the source
areas. Chemicals representing all HSL categories (VOA,
semivolatiles, pesticides, PCBs and metals) were found on-
site. Although, as pointed out in many of the comments,
many of these compounds are not very mobile, they can
potentially be carried by the more mobile constituents.
Comment m: The Canonie report stated that there is no need
for an active inorganic treatment system at the Site and
that only those inorganic compounds that precipitate as a
result of changes in groundwater chemistry in the treatment
process should be removed.
EPA's Response; The inorganic treatment system would remove
inorganic compounds which would otherwise clog the air
stripping and carbon adsorption units. The FS report states
that the treatment system would be optimized for arsenic
removal. Arsenic was detected at concentrations exceeding
the target level in several wells downgradient of source
areas, as presented in the RI. Therefore, in keeping with
FS guidance, treatment of arsenic was evaluated.
Comment n; Canonie suggested that extraction wells pumping
at rates of 200 to 250 gallons per minute (gpm) would seem
to exceed the amount of water available on the Site, and
stated that further hydrogeologic studies be done on the
Site.
EPA's Response; EPA agrees that a flow of 200 to 250 gpm
may exceed the amount of water available on-site. A flow of
250 gallons per minute is only possible if the off-site
wells north of Whispering Pines Pond and the wells at the
north property boundary are included in the groundwater
recovery system. The yields and drawdown curves for
extraction wells placed in these areas were calculated using
the Theis equation. Hydraulic conductivity data used as
input was collected during the supplemental RI. Information
obtained during a short term pumping test of the Whispering
Pines Pond Well concurred with the calculated yield and zone
of influence.
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As shown in Appendix 6 of the TS, the extraction rate
calculated for the wells and trenches surrounding the source
areas is estimated at approximately 20 gpm.
r_
EPA agrees that further hydrogeologic studies are necessary
prior to the implementation of the Remedial Action. During
Remedial Design, aquifer testing, including pump tests., will
be performed.
Comment et The Canonie report stated that in the cost
estimate for Alternative MM-2, a total of 1,800 linear feet
of extraction trench is proposed. In the cost estimate for
Alternative MM-3, only 800 linear feet of trench is
proposed. The text of the Supplemental FS (Weston, p. 4-
147) indicates that the extraction system for Alternative
MM-3 "would essentially be the same as that described for
Alternative MM-2".
EPA's Response; Canonie is correct in pointing out that the
collection trench in MM-3 should have the same length (1800
feet) as Alternative MM-2. The costs (and corresponding
tables) for Alternatives MM-3 and MM-3 A have been revised,
and the tables are attached to this Responsiveness Summary.
The difference in cost is insignificant compared to the'
overall cost of these alternatives and therefore would not
affect EPA's choice of a remedial alternative.
Comment pi The Canonie report stated that, concerning the
liquid phase activated carbon system, the text of the
Supplemental FS states "The contactors would each contain
20,000 pounds of carbon, and vould require replacement
carbon cartridges every 4 months." (Weston, p. 4-140). This
implies that liquid phase activated carbon usage would range
between 60,000 and 120,000 pounds per year depending on the
interpretation of "replacement carbon cartridges". This is
inconsistent with the 37,400 pound per year carbon usage
proposed in the cost estimate for Alternative MM-2 (Weston,
Appendix D, Table II-2). This additional carbon usage would
add between $463,000 and $926,000 to the present worth of
Alternative MM-2 for the low flow (30 gpm) case. It is not
clear from the Supplemental FS report whether this same
omission of a substantial operation cost applies to the high
flow .(275 gpm) case of Alternative MM-2.
EPA's Resoonaet The costs presented in Appendix D for
activated carbon usage are the result of calculations using
actual site conditions projected flow rates, and vendor
information. The discussion of carbon usage presented in
the text was meant to be descriptive and was not based on
calculations. The operation and maintenance costs presented
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for activated carbon in Appendix D, Tables II-2 and II-2-A,
are appropriate, and there is no "omission", as referred to
in the comment.
Comment p; The Canonie report noted that summary costs
presented (Weston, Appendix D, Table II-2) for Alternative
KM-2 do not agree vith the summary cost presented in the
sensitivity analysis (Weston, Appendix 0, Table IV-1). In
particular, the detailed cost estimate presented early in
Appendix O as Table II-2 states the cost for "Groundvater
Recovery System" as $790,000 and for "PW O&M Cost" as
$4,878,801. However, Weston used a cost of $365,000 for
"Groundwater Recovery System" and a cost of $5,009,902 for
"PW O&M Cost" in the sensitivity analysis. The values in
the detailed cost estimate and sensitivity analysis for
these items should be the same. Canonie stated that these
inconsistencies render the sensitivity analysis of
Alternative MM-2 useless. In addition to these
inconsistencies, there is a second sensitivity analysis also
identified as Table IV-1 {Weston, Appendix D, Table IV-1)
which is wholly inconsistent vith any of the detailed cost
estimates presented in Appendix D of the Supplemental FS.
This nay be related to an alternative that was eliminated
from further consideration during preparation of the
Supplemental FS report.
EPA's Response; Canonie is correct in that Table IV-1 and
Table II-2 of Appendix D do not agree. However, the numbers
presented in the text for the sensitivity analysis of MM-2
(FS, Table 4-9, page 4-39) are based on the correct
sensitivity analysis. A former version of Table IV-1 was
mistakenly placed in Appendix D. A corrected version is
attached to this document and will be included in the
Administrative Record. Despite being slightly different
from the corrected version, the version of Table IV-1
available to the public was still very useful in showing the
variability of MM-2 to various stresses, as the upper and
lower limits of the 50% confidence interval differed by no
more than $200,000.
Comment q: The Canonie report stated that the capital cost
estimates for Alternative MM-2 are based on a service cost
factor equal to 90 percent of the value of installed
equipment while the estimates for Alternative KM-3 are based
on a service cost factor of 125 percent. There is no
explanation in the Supplemental FS why different factors'are
used in the various alternatives.
EPA's"Response; Canonie is correct that a different factor
was used for services cost in MM-3 than in MM-2. The
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correct service cost factor should be 90% of the value of
installed equipment as presented for Alternative MM-2. The
costs for KM-3 have been recalculated and, as mentioned
previously, corrected versions of the cost and sensitivity
analysis tables are attached. The difference in cost is
insignificant compared to the overall cost of the
alternatives and in no way would have affected EPA's
decision making process.
Comment r; The Canonie report stated that while the
Supplemental FS estimates that it will cost $605,000 to
establish an on-site laboratory, an on-site laboratory
equipped with a GC/MS unit (a GC unit would be sufficient)
would not cost more than $200,000.
EPA's Response; The cost of an on-site laboratory is based
on vendor supplied information for a mobile laboratory with
the necessary equipment for analysis of all indicator
chemicals for the Site. EPA feels a GC/MS is necessary to
accurately identify and quantify the indicator chemicals at
the target cleanup levels. Performance of the analysis on-
site would be more cost effective than off-site for all
alternatives except Ho Action (MM-1 and SC-1), SC-6, and
MM-3.
Comment st The Canonie report noted that the Supplemental
FS report projected activated carbon usage rates for the
high flow (275 gpm) case of Alternative KM-2 to be eight
times the carbon usage rates for the low flow (30 gpm) case
of Alternative MM-2. This is roughly the ratio of total
treatment system flow rate. The Supplemental FS report has
failed to account for the fact that as the groundwater
extraction system is extended to larger areas and the total
extraction rate is increased, the concentrations of
chemicals in the extracted water will decrease dramatically.
These decreased concentrations will allow a greater
treatment rate as expressed in gallons of water per pound of
carbon and therefore, simply taking a ratio of flows is not
an accurate method of predicting carbon usage for the high
flow case.
EPA*a Responsei Canonie is correct in that the ratio of
carbon usage per volume of water treated was calculated for
the average characteristics of contaminated groundwater, and
did not allow for dilution caused by pumping uncontaminated
water'. EPA also agrees that as the ground water extraction
rate increases, the concentration of chemicals in the
extracted groundwater may decrease allowing a greater
treatment rate in terms of gallons of water per pound of
carbon. However, chemical concentrations under pumping
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conditions cannot be determined until pump tests are
conducted during Remedial Design. Therefore, estimating
activated carbon usage based on groundwater flow is a good
conservative estimate in the face of uncertainty which can
only be clarified during Remedial Design.
Comment t: The Canonie report stated that on the comparison
of Alternative MM-2 and Alternative MM-3, using a
sensitivity analysis, the present worth cost is essentially
the same because of the overlap of the cost ranges for the
two alternatives (Weston, Supplemental FS, p. 4-165). This
comparison does not account for the similarity of the two
alternatives and the fact that the same permutations that
will increase the cost of Alternative MM-2 will also
increase the cost of Alternative MM-3. Therefore, costs
associated with these two alternatives cannot be assumed to
vary independently as is assumed in the random cost
sensitivity analysis. Based on these cost estimates,
Alternative MM-3 will always be less costly than Alternative
MM-2.
EPA's Response; This comment is premised on a misconception
of the inputs to the sensitivity analyses of MM-2 and MM-3.
Although on the surface, it appears from the sensitivity
analysis tables that similar cost items were varied for
these alternatives, one must look at what comprises each of
the "similar" cost groupings. For instance, a variable
evaluated in both analyses was equipment and supplies cost.
However, a review of cost components for each alternative
shows that MM-2 has the cost of carbon units ($288,000)
whereas MM-3 does not (assuming carbon treatment would not
be required). The cost of extension of a sewer to the Site
could vary considerably depending on the design
requirements. This would also cause the cost of MM-3 to
vary independently from MM-2. The sewer use fee included as
part of the O&M cost ($400,000 present worth) could also be
significantly different from what was estimated in the FS;
it might be set higher or lower depending on the terms and
conditions of the discharge agreement. In summary, there
are several expensive items which differ between MM-2 and
MM-3 which would cause the alternatives to vary
independently of one another. EPA expects each alternative
could vary within the 50% confidence interval range
presented in the FS.
Comment u; Sanders, the Town, and Xentex stated that
analytical data suggests that concentrations of inorganics
(including arsenic and lead) in the groundwater are
generally below target levels and that such levels as do
exist, result from natural background levels. Because of
39
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this situation, treatment for inorganics is not required
under SARA, would be inconsistent with the cost-
effectiveness requirements, and would not be in accordance
with law.
EPA's Response; Although it is true that the average of all
samples analyzed for arsenic is less than the cleanup goals,
six out of the 17 samples collected were above the cleanup
goal of 50 parts per billion (ppb) for arsenic. The
majority of these wells exceeding the cleanup goal are
within the area defined as the "Central Plume11 by Weston.
One cannot simply use an average of the whole Site to
determine if cleanup is in fact necessary. Compliance with
target cleanup levels must be attained at the established
compliance boundary. It is EPA's intent to clean up
separate areas of the Site and, as individual wells attain
the target cleanup levels, discontinue pumping from those
wells.
The statement by conunenters that the levels of arsenic
observed above target levels represent "background11
conditions is not supported by the data. Eleven out of the
seventeen wells sampled contained arsenic concentrations
below the cleanup goal. In fact, four of the samples had no
detectable arsenic.
2. EPA's Preferred SC Alternative
Comment a; Sanders, Work Place Systems, the Town, Peter
Johnson, and Canonie questioned why EPA proposed soil
flushing as part of the overall cleanup remedy when the FS
does not recommend it because it would exacerbate
contamination of the aquifer. Work Place Systems stated
that flushing may be ineffective because water will tend* to
leach out of the sides rather than downwards through the
wastes. Sanders questioned why EPA proposes to flush soil
when target levels have already been met, especially at the
risk of further or renewed environmental damage, and why the
adverse impacts of this remedy have not been considered.
the Town stated that the FS itself confirms that a decision
to implement this part of the remedy would be arbitrary,
capricious, and inconsistent with the National Contingency
Plan. Peter Johnson stated that soil flushing cannot be
accomplished with limited on-site groundwater; threatens to
destabilize previously stable landfill areas; assumes that
Mr. Johnson would permit the pumping of off-site chemicals
onto his land for treatment; and would not likely meet with
success since it is an unproven technology and the column
leachate test was ineffective under laboratory conditions.
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EPA's Response; Previous responses III.B.l.d and III.B.l.e
also address the topic of discharge of a portion of the
treated groundwater onto the source areas. As explained in
response III.B.l.d, this practice should not be confused
with soil flushing which has been eliminated from the
remedy.
Sanders' comment with regard to compliance with target •
levels is addressed in responses Attachments B.l.f and
B.3.b.
The statement that the column leachate test was "ineffective
under laboratory conditions" is incorrect. In fact, the
column test demonstrated that contaminants present in soil
from the source areas were leachable using simulated rain
water.
The primary limitation of the tests was that the samples
obtained did not contain some of the volatile organic
compounds listed as indicator chemicals for the Site. The
data obtained therefore could not support contaminant
transport calculations for the indicator chemicals, as
originally intended. The tests did provide useful
information about the leaching characteristics of some of
the contaminants present at the Site, including certain
indicator chemicals. These observations are reported in the
Supplemental RI.
Comment b: Xentex stated that EPA's source control
alternative of a multi-layered cap would not provide any
reduction of infiltration of precipitation into the source
areas because, after several years of uncontrolled
infiltration, the concentrations of contaminants leaching
from the wastes are expected to approach a practically
irreducible concentration. But, stated Xentex, a cleanup
benefit could be achieved if the source areas are covered
with a simple soil cover at the beginning of the remedial
action phase.
EPA's Response; The proposed method of closing the
landfills with a simple soil cover would not comply with the
relative and appropriate requirements of RCRA part 264 or
State closure requirements. The implication that the NHDES
would approve of such a method of closure for other similar
landfills is without basis. The construction of a multi-
layered cap, as proposed by EPA, is a proven technology for
reducing infiltration of rain water.
Comment c: The Canonie report noted that placing collection
trenches around the perimeter of the solid waste landfill
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will be ineffective and that infiltration, which is the only
transport mechanism of importance, can be effectively
controlled by additions to or repair of existing caps.
EPA * sr'Response t The groundwater collection trenches around
the Solid Waste Landfill and extraction veils were designed
to capture infiltration, groundwater beneath the landfill,
and groundwater which had migrated beyond the source
boundaries. As depicted in Figure 4-18 of the FS, the
trench along the eastern side of the landfill is
discontinued in areas where overburden thickness is not
sufficient.
EPA agrees that infiltration is an important transport
mechanism, but horizontal groundwater flow beneath and
around the Solid Haste Landfill can not be dismissed. Based
on interpretation of test pit observations, topography and
groundwater elevation data, the overburden beneath the solid
waste is saturated. In some locations, solid waste is in
direct contact with groundwater.
The comment also suggests that the partial cover in place at
the Solid Waste Landfill could be converted to an effective
cap. This comment is addressed in response to Attachment
B.3.O. below.
3. The Supplemental RI/FS
Comment at Work Place Systems, Sanders, and Peter Johnson
stated that the sampling data upon which much of the remedy
was based is outdated, unreliable, has QA/QC problems, and
no correlation of the data can be made with respect to the
Site. Peter Johnson stated that no important decisions
should be based upon this data and no valid conclusions pan
be drawn from it. Sanders suggested updating the Site data
base with a groundwater contaminant analysis, and Peter
Johnson suggested a new round of samples with appropriate
safeguards.
EPA's Responset Although the data used by EPA in preparing
the Supplemental RI and FS was obtained in 1987, EPA does
not agree that the data is unreliable or had QA/QC problems.
From before the issuance of the proposed plan, EPA has
recognized that further sampling data must be obtained prior
to the implementation of the remedy, so that the design of
the groundwater treatment system is appropriate to current
site conditions. In addition, in July of this year, EPA.
entered into a Consent Order with (11) PRPs which authorized
the collection of a complete round of groundwater samples.
Sampling and analysis was performed by Canonie Environmental
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under contract to the PRPs. A report of the sampling
results was presented to EPA on August 14, 1989. The data
contained in the Canonie Report indicates that the average
concentration of groundwater contamination across the Site
has decreased since EPA's last sampling round, but that
unacceptable levels of contaminants still exist in the
groundvater and that the treatment conceptually envisioned
by EPA is still appropriate and necessary.
As to the reliability of EPA's data and the sufficiency of
EPA's QA/QC procedures, Canonie's assertion that significant
amounts of compounds not previously found at the Site were
found in the trip and field blanks collected by Weston in
1987 is completely unsubstantiated. Of the eight VOCs
identified in Weston blanks, all were found at or below the
CRDL and all but two compounds (tetrachloroethene and
toluene, each found in one sample) were flagged with a "B"
qualifier indicating laboratory and not field or trip blank
contamination. All of the compounds detected were also
found in at least one on-site well. Two semivolatile
organics (di-n-octyl phthalate and benzo(a)pyrene) were
found in trip or field blanks. Various phthalates were also
found in many on-site samples. Benzo(a)pyrene was not found
in any other groundvater samples. Neither of these
compounds are indicator chemicals. Various metals were
found in the blanks, including the indicator chemicals
arsenic and lead. The levels found were between the CRDL
and the IDL.
Although levels of indicator chemicals not attributable to
laboratory contamination were found in trip blanks collected
by Weston, all but one compound (tetrachloroethene) was
found at levels much lower than the target levels. The
level of PCE found is very close to the target level, but
since other samples showed the presence of this compound.at
levels up to ten tiroes the target level, it should not be
presumed that the bottles or distilled water used during the
sampling event somehow contributed to false positive
readings. Further more, only one organic compound,
benzo(a)pyrene was found in only one field blank collected
by Weston. This established that field QA/QC procedures
such as decontamination were followed and that cross
contamination of samples did not occur.
Canonie's assertion that field methods were not included in
the Supplemental RI indicates a less than thorough reading
of the report. Sampling methodologies, including
preservation and preparation methods, are included in
Appendix A. As stated in this appendix, groundwater samples
collected for metal analysis were field filtered prior to
shipment to the CLP laboratory.
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comment bt Sanders, Canonic, and Xentex stated that the
information in the RI indicates that most of the
contaminants in the Site groundvater may have already
reached prescribed target levels and that natural
attenuation nay be occurring, thereby obviating the need for
aquifer remediation. Xentex suggested an additional round
of sampling to determine if a trend toward improvement is
occurring.
EPA*s Pesponset The various commenters are correct in
noting that the RI discusses a decreasing trend of indicator
chemicals. However, trends do not suggest that the
contaminant levels would have decreased to below target
cleanup levels in the last two years since sampling and in
fact, groundwater data presented in the Canonie Report
indicate that target cleanup levels have not been met. See
also the discussion of the No Action alternative for
Management of Migration in Section 4.3.1 of the FS.
Prior to the implementation of the Remedial Action, in the
Remedial Design phase, another sampling effort will be
conducted to assess current site conditions. EPA does not
intend to pump and treat groundwater which has achieved
cleanup levels.
Comment ct Sanders, Peter Johnson, Canonie, and Xentex
commented that the RI report contains a technically
insufficient amount of data to indicate the existence of a
plume of contaminated groundwater, that data does not show a
correlation between off-site contaminants and those
occurring on-site, and that, because there were few
monitoring wells or test results from the postulated
location of the alleged plume, these few data points do not
provide enough information to indicate a plume. Sanders.
suggested that the plume be defined and, if possible, the
sources of contamination be identified.
EPA's Response: EPA disagrees with the comment that data is
insufficient to indicate the existence of a plume of
contaminated groundwater. EPA has shown, via water quality
data acquired during three rounds of sampling of the
numerous monitoring wells, a strong correlation between the
waste disposal source areas and the plumes. EPA believes
that the data collected by Canonie Environmental also
supports this correlation.
w
The large number of contaminants detected in the Town Dump
area moil and groundwater is indicative of the complex
nature of this source. Multiple rounds of samples
consistently indicate the presence of contaminants
associated with this source both beneath the source and in
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veils north of Whispering Pines Pond. EPA's latest round of
samples (1987) confirms the interpretation of deep
contamination movement dovnslope of the bedrock surface in
the area north of Whispering Pines Pond, as depicted in the
cross-sections in Figures 5-16 and 5-17 of the RI. The
cross-sections indicate that the contaminants moving in the
deep overburden and shallow bedrock may converge with the
central plume in the bedrock trough downgradient of the
Site.
The central plume associated with the Solid Waste Landfill
is supported by groundwater contours, groundwater quality
data, and subsurface information. The bedrock trough
between the source and the contaminated wells G2-9 and NUS-1
apparently acts to confine the plume. The soil
characteristics would also be expected to limit dispersion
transverse to the direction of bulk groundwater flow. EPA
notes that the direction of groundwater flow from the Solid
Waste Landfill toward GZ-9 and NUS-1 is not in dispute,
based on the contours and plumes presented by Canonie. The
only question is whether the contaminants detected at GZ-1
continue to flow downgradient or, for some reason, become
attenuated in the soils in the vicinity of GZ-1.
Comment d; Sanders, Peter Johnson, and Canonie commented
that there are a significant number of contaminants off-site
(on the north side of Whispering Pines Pond), which have
never been found in six years of on-site sampling. Sanders
suggested that there is evidence to support the concern that
other sources may be contributing to groundwater
contamination. Peter Johnson requested an explanation for
this situation and noted that no serious effort has been
made to determine the quality of groundwater flowing from
the trailer park area and that no soil samples have been
taken to assess whether this property is a potential source
area.
EPA's Response; The contention that the trailer park is a
source of contamination is discussed and dismissed in the
response to Comment B.2.h in Section III. An examination of
the groundwater data collected by Weston in 1987 shows no
evidence of volatiles, pesticides, PCBs or metals in off-
site wells which were not present in on-site wells or soil
samples. The presence of compounds in Western's sampling
round which were not found in previous studies is discussed
in the response to Comment III.B.2.b.
Comment e; the Town stated that the Supplemental RI does
not include the analysis of source area data which, they
said, is a necessary prerequisite to accurate decisions
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about tailoring a remedial alternative to each source area.
EPA's Response* EPA disagrees that the Supplemental RI did
not include an analysis of source area data. Summaries of
groundvater and soil data for each source area are contained
in Chapter 4 of the Supplemental RZ. Additionally this data
is summarized in Chapter 1 of the FS (Tables 1-1 through 1-
20 and Figure 1-7). Source areas were considered
individually in Section 3.2 of the FS where representative
process options were combined into preliminary alternatives
for Source Control of each source area.
Comment fi the Town said that any choice of a preferred
alternative based on the inadequate and outdated information
contained in the RI would be arbitrary and capricious under
CERCLA, as amended, and inconsistent with the National
Contingency Plan, as amended.
EPA's Response! EPA disagrees with the statement that the
information contained in the RI is inadequate and outdated.
The data is adequate to describe the Site conditions and to
demonstrate that source areas have resulted in degradation
of groundwater quality at site boundaries, and off-site,
with contaminants exceeding ARARs. The evaluation of the No
Action alternative for Management of Migration concludes
that these conditions will continue for decades without
active groundwater remediation. Thus, the argument that the
three rounds of groundwater data collected over the last
five years are "outdated" is unpersuasive and the suggestion
that the remedy is arbitrary is contradicted by the facts.
Comment a; Peter Johnson stated that the groundwater
elevation, direction of flow, and rate of flow have never
been properly and consistently determined, and that no
consistent and organized data exists which would allow for
the necessary understanding of the Site hydraulic
characteristics.
EPA's Response; EPA disagrees with this comment.
Interpretation of water level data acquired by the EPA, and
confirmed by Canonie, has consistently shown that
groundwater flows in a generally south to north direction,
that is, from the source areas towards the Whispering Pines
supply wells, Whispering Pines Pond and Cohas Brook. EPA
has assessed flow rates on the Site by means of a pump test
and by slug testing of monitoring wells on the Site. Both
the RI/FS and the supplemental RI/FS addressed groundwater
flow. Flow rates are consistent and within anticipated
values expected for the strata tested.
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Comment h: Peter Johnson stated that the Supplemental RI/FS
fails to properly consider or price the solution desired by
most .abutters: excavating and placing the existing site
landfills into an on-site state-of-the-art cell with
leachate collection systems. Peter Johnson stated that, in
the absence of undue EPA regulatory requirements such as
air-monitoring, this could be accomplished at a cost less
than the preferred alternative. Peter Johnson stated that,
moreover, this could be accomplished without endangering the
environment or displacing abutters. Moreover, a lined
landfill, which is greatly needed in the area, would be
created.
EPA's Response: The excavation and placement into a
containment cell of all source area material without
treatment is discussed in the response to comment B.2.f of
Section III.
Comment i: Peter Johnson and Xentex commented that the no-
action alternative for groundvater contamination was not
properly evaluated; specifically, that the evaluation failed
to address groundwater near the source areas separately from
groundwater to the north of Whispering Pines Pond.
EPA's Response: As stated previously, the No Action MM
Alternative was evaluated in accordance with applicable
guidance. An overall No Action MM Alternative (MM-1) was
chosen as the No Action alternative required for evaluation
by CERCLA. As it is EPA's interpretation that the on-site
and off-site groundwater belong to the same flow regime and
that the chemicals found in the off-site wells are there
because of on-site activities, there was no reason to
evaluate on-site and off-site No Action alternatives
separately. Additionally, No Action to off-site water is
included in the evaluation of the other MM Alternatives.
Both MM-2 and MM-3 were evaluated and costed based on two
separate scenarios, pumping only on-site water and pumping
on-site and off-site water.
Comment j: Peter Johnson and Canonie observed that Table D-
1 reveals anomalies; specifically, that contaminants which
had never appeared on-site in six years of testing suddenly,
in 1987, appeared in high concentrations in off-site wells
north of Whispering Pines Pond. Peter Johnson stated that
it is,gross professional negligence not to have sought
confirmation of unusual results and to have failed to
examine the original test records as complied in the CLP
package.
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EPA*s Response; The first point of this comment, that
contaminants which had never appeared on-site suddenly
appealed off-site in high concentrations, is incorrect for
two reasons. First, as discussed in the response to comment
B.3.d, only one compound detected in off-site wells, 4-
nitroaniline, was never detected on-site. This compound is
not considered an indicator chemical for the Site, was;not
present in a concentration exceeding a chemical-specific
ARAR and is not subject to a target cleanup level, thus its
presence has no impact on the remedy selection process.
Second, the compounds detected in "high" concentrations in
off-site wells are the same compounds which have been
consistently detected on-site throughout the years of
groundwater monitoring at the Site, namely 2-butanone,
toluene, trans-l,2-dichloroethylene, 1,2-dichloroethane and
trichloroethylene.
The second point of the comment regarding the authors'
responsibility to confirm the "unusual results" is based on
the invalid presumption that the results were unusual.
Furthermore, the data was developed under CLP program
quality assurance and quality control procedures at an
approved laboratory, and the data package had been
independently reviewed by qualified chemists prior to being
presented to the authors. The confirmation of results and
examination of original test records compiled in the CLP
package had therefore already been performed by qualified
professionals prior to the use of the data. The authors
followed the usual and customary practice of relying on the
expertise of other professionals to provide quality data in
support of the authors* task of preparing the Supplemental
RZ and the FS. Further discussion of the laboratory data is
presented in response to comments ZII.B.l.b and B.3.a.
t
Comment k; Peter Johnson stated that, according to the
report of Ms. Nancy Stewart, the CLP work done by York
Laboratory of Connecticut was all done on one day on one
single machine and that poor laboratory practices resulted
in the carry over of contaminants onto the test samples and
the blanks for the samples. Ms. Stewart's report indicated
that the lab analyst did not clean the autosampler chambers
because the test records themselves show that there was
insufficient time to do so. Blanks were not run in the
individual chambers which had been utilized to run the
Standard analysis.
EPA's Responset Response to this comment was presented in
Section III.B.2.b.
Comment 1; Peter Johnson reported that a review of the test
results from Nanco Labs indicated that methylene chloride
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and acetone were found in most of its samples and that a
review of the method blanks proved that there was a
laboratory contamination problem with these two
contaminants. The trip blanks and field blanks associated
with NUS 10 and KUS 12 show the highest levels of
contamination.
EPA's Response: EPA fully agrees that methylene chloride
and acetone were found to be laboratory contaminants in the
samples analyzed at Nanco Labs. In fact, these compounds
are common laboratory contaminants. Weston, in writing the
FS, understood this and factored it into the assessment of
the Site. This was especially significant in the case of
nethylene chloride, which was classified by PRC as an
indicator chemical at the Site, based on previous site data
but was only reported with the laboratory blank
contamination qualifier in the most recent sampling program.
If collected by the groundwater recovery system, methylene
chloride would be treatable using the representative process
options presented in the FS. The presence or absence of
methylene chloride in the influent to the groundwater
treatment system would not affect the choice of treatment
technology or the capital or operation and maintenance cost
of that treatment system.
Comment TO; Peter Johnson and Canonie recommended that the
property to the north of the landfill site be examined to
determine if another source of contamination exists on the
Whispering Pines property, because the test results from
wells on the Whispering Pines site are far higher than the
test results for wells actually on the Auburn Road Landfill
site. Canonie and Peter Johnson postulated that there is a
second source of pollution coming from the north or
northeast of the Site.
EPA's Response; As previously stated in response to comment
B.3.d of Section III, while data does support the presence
of four waste disposal source areas and associated plumes,
data does not support the contention of an off-site source.
The water quality data in the Supplemental RI shows
contaminant levels at higher concentrations downgradient of
the Site, which is the logical result of multiple discrete
releases of contaminants occurring over time, such as might
originate from buried, leaking drums. The removal of drums
from the Site should have stopped the majority of these
releases.
•^
Comment n; Peter Johnson stated that, for the analysis of
groundwater contamination to be correct, one must assume
that;
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a massive slug of contamination left the three disposal
areas between 1980 and 1985, travelling in perfect
laminar flow toward the wells on the north of the pond;
contamination does not decrease as the distance from
the source increases;
- slower moving contaminants must have been released
first and the faster moving contaminants released
later; and
• contaminants from more distant sources would have to
have been released before more nearby contaminant
sources.
EPA*s Responset Mr. Johnson's assumptions oversimplify
transport and fate of contaminants in the subsurface
environment. There is no reason to expect each contaminant
to be more concentrated in wells near the Auburn Road source
areas than in wells remote from the sources. This might be
expected for a particular contaminant if the source would
continuously release the contaminant at a constant rate. For
this Site, however, this is an unrealistic assumption. The
contaminant distribution observed at the Site is typical for
a site in which numerous discrete releases, as from barrels
containing a wide variety of chemicals, occurred over an
extended period of time.
The reference to "laminar flow11 is apparently a reference to
the shape of the central plume of volatile organic
contaminants, as presented in Figure 1-7 of the FS. This
shape is interpreted as the result of confinement of the
plume by a bedrock trough, and of the low transverse
dispersivity in the sandy soils within the area of the .
plume. "Laminar flow" is not necessarily a requisite for
this observation.
The references by Mr. Johnson to a "massive slug of
contamination leaving the disposal area between 1980 and
1985", and other references to the timing of releases of
contaminants by no means describe the necessary conditions
for the observed contaminant distribution at the Site. As
stated earlier, discrete releases from multiple sources
could account for the Site contaminant profile currently
mapped.
.*
Comment 01 Canonie stated that the Supplemental RI/FS
implies that the current caps on disposal areas are
deficient and fails to assess the sufficiency of the cover
material over each disposal area with regard to ARARs.
Canonie stated that the assumption of cap deficiency is
50
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unsupported by site data and would result in the
implementation of a remedial alternative not justified by.
public health or environmental concerns.
r_
EPA's Response; EPA evaluated the existing "caps" on the
disposal areas during the RI/FS process, and determined they
had serious deficiencies. The present cover, where it
exists, is thin and improperly graded. There is no evidence
of cover material which would be considered impervious, and
there has been no serious attempt to establish a vegetative
cover. Section 4.2.2 of the FS provides a description of
the improvements which would be required.
The cap design described in the FS would be appropriate for
closure of a RCRA landfill, would be likely to obtain NHDES
approval for appropriate closure of a municipal/industrial
waste landfill, and is representative of good engineering
practice. The cap design is conservative, particularly with
regard to the 30" drainage layer above the impervious layer.
It is conceivable that a drainage layer of as little as 18"
may obtain approval, but this would certainly not be a
conservative approach.
With regard to the issue of obtaining material from on-site
to construct the new cap, it would not be appropriate for
EPA to presume on-site material could be obtained at no
cost. EPA estimated that as much as 50,000 cubic yards may
potentially be available. In preparing the cost estimate,
the unit cost for subbase construction (intermediate cover),
including materials and grading, is $4.00 per yard. This
cost reflects the possibility that some of the 50,000 cubic
yards of intermediate cover could be obtained at a reduced
cost, for instance through use of on-site materials.
The basis for selection of a composite cap (with an HOPE
liner) as the representative process option is presented' in
the FS. The final selection of materials for construction
is a Remedial Design function, in accordance with the RI/FS
guidance.
Comment p; Canonie said that the Supplemental RI/FS stated
that the drum removal is at least partially responsible for
the declining concentrations of chemical constituents in
groundwater, but that there is no evidence in the report
which correlates analysis of excavated drums with
contaminants in groundwater.
,t
EPA's Response; A "correlation" between those constituents
found in the drums and those found in the soil and/or
groundwater cannot be expected. Many of the drums removed
were empty, indicating that unidentified chemicals had been
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released. The likelihood also exists that liquid wastes or
solidrwastes with leachable constituents were disposed of
directly on the ground in the source areas. Nevertheless,
EPA is certain that the wastes removed from the Site
decreased the magnitude of the source. EPA is confident
that the removal is at least partially responsible for lower
concentrations of indicator compounds in soil and
groundwater. Data from the composites samples of material
shipped off-site for disposal during the drum removal
confirms that the following indicator chemicals were
present:
Volatile OrganJest
Methylene Chloride
1,2-trans-Dichloroethene
Trichloroethene
Tetrachloroethene
Toluene
2-Butanone
Seroivolatile Oraanics;
Benzo(b)fluoranthene
bis(2-ethylhexyl)phthalate
Fluoranthene
PCBs
Metalst
Cadmium
Lead
Although these analyses were not performed by a CLP
laboratory, the data is considered useful for the purpose of
indicating the presence or absence of a given compound in
the samples. The fact that some of the indicator chemicals
were not found in the composite samples does not necessarily
mean they are not present as a source at the Site and were
not contained in some of the barrels which were removed from
the Site.
Comment at Xentex stated that it is not clear why
pretreatment would be required for discharge of pumped
groundwater to a sewer, with treatment at a publically-owned
treatment works (POTW). Specifically, Xentex commented that
the design of the proposed systems seems unreasonable,
complex, and expensive.
EPA»a'Responset As stated in previous responses, discharge
to the Manchester WWTP would be subject to the terms of an
agreement and/or permit with the discharge limitations being
determined on a case by case basis. In developing the cost
estimate for MM-3, it was reasonably assumed that
pretreatment to remove volatile organics would be a minimal
52
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requirement of this agreement. Treatment to remove iron and
manganese would be required prior to the volatile organics
removal unit operation. The resulting treatment system is
not considered unreasonable or overly complex given these
conditions.
Comment r; Xentex stated that the geophysical surveys for
plume definition did not usefully identify conductive
plumes, but relied heavily upon the water-quality data for
the geophysical interpretation of plume definition.
Conversely, the ground-water quality sampling results relied
heavily upon the geophysical for plume definition. The
characterizations of the water-quality and geophysical data
were reviewed separately and are not adequately conclusive.
When combined, these evaluations also do not provide a
reasonable level of confidence concerning plume definitions
to indicate the presence of contaminants.
EPA's Response; The preponderance of data demonstrates the
presence of multiple plumes on the Site. The use of all
available data (i.e., geophysical and water quality data),
in a complementary manner, is necessary to develop a valid
interpretation of subsurface conditions. Groundwater
quality and geophysical data are generally mutually
supportive of the contaminant distribution presented in the
RI. No one investigative technique was relied upon to draw
conclusions. Rather, the characteristics of Site conditions
were concluded based upon multiple studies over time using a
variety of techniques.
Comment si Xentex commented that the models developed for
the RI are inconclusive and that serious deficiencies are
noted for each of the models. The data obtained from the
models cannot be viewed with any degree of confidence or as
a decision-making tool.
EPA's Response; This response will address Xentex comments
regarding modeling efforts described in the Supplemental RI
and the FS.
I. ROCEM Model
The contaminant transport modeling performed by Weston for
the Supplemental RI employed the "ROCEK" model. This model
was developed by EPA in 1985 for use in evaluating the
relationship between soil contamination and potential,
resultant downgradient groundwater contamination.
Xentex correctly points out that the ROCEM model does not
simulate contaminant transport at the Site along actual
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groundwater flow paths, predict the distribution of
contaminants within the aquifer at the Site, or represent
continuous contaminant influx at the various source areas.
However, as stated in the Supplemental RI; "the purpose of
the modeling effort was to provide quantitative estimates of
the potential maximum levels of contaminants that can be
expected in groundwater at downgradient compliance
boundaries." As such, the ROCEM model was intended not to
simulate present site conditions, but rather, to assess the
relative groundwater contamination potential associated with
the reported levels of residual soil contamination found in
the three source areas. As originally developed by the EPA,
the ROCEM model was intended to provide a reasonable, worst-
case scenario of the groundwater contamination potential of
a waste site.
Accordingly, the model is based upon several conservative
assumptions. The additional text provided in Appendix 6 of
the Supplemental RI provides an overview of
diffusion/dispersion phenomena, and model development, and
clearly highlights the limitations inherent in this simple
analytical model.
Xentex correctly suggest that the model results "are not
appropriate for the design of the remedial alternative."
The results of the model were not used for this purpose.
The results were among the factors considered when
evaluating the No Action alternative, and were not
supportive of implementation of this alternative.
II. Javendel Model
In general, the comments made by Xentex regarding the use of
the Javendel Model in the TS address semantic discrepancies
in the FS text. Xentex also suggests that some of the
selected input values may be varied to yield different model
results. Certainly the input parameters may be varied and
indeed they were, and different results obtained. However,
the effort conducted by Weston was undertaken to yield
conservative, yet realistic results. Conservative values of
input parameters, where appropriate, were utilized (e.g.
retardation factor of "1", simulating maximum transport and
minimum retardation of contaminants).
The results of the effort were considered unrealistic. A
lack qf information about the source areas, specifically
dumping history, hampered attempts to obtain realistic
results from the model. Therefore, the application of the
model was limited to the evaluation of the No Action
alternatives. The results of the model were not used as a
decision making tool for the design of a groundwater
remedial system, contrary to what Xentex suggests.
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In response to specific points made by Xentex:
«•_
1) The model requires an assumed "input year", at which
time the source begins to release contaminants. Weston
used the last year that each source area was known to
have been in use as the "starting date" of
contamination input in the model. The input describing
the source is not representative, since numerous
independent releases would have occurred throughout the
active life of each source area, and failure of waste
. containers could have resulted in discrete release
events after landfill activity ceased. Clearly, as
stated in the FS, input of one "starting date" would
not be descriptive of the sources at the Auburn Road
landfill.
2) The model input used by Weston was conservative with
respect to the decay constant and the retardation and
biodegradation of contaminants.
3) The model inputs which did not allow solute decay or
retardation, and which provided a limited depiction of
the source (see comment (1) above), resulted in the
"frontal wave" observed. A similar phenomenon was not
observed at the Site.
4) The values used were applicable to the plume migration
pathway inferred for individual source areas. The
dispersivity values selected for use in the model were
based on literature references (Walton, 1984) and were
compatible with hydrogeologic values measured at each
source area.
5) Weston defined variables used in the equations as •
follows:
R « retardation factor of the solute « 1
« radioactive decay constant or decay constant of
the solute « 0
a * decay constant of the source
•0.15 yr~1 for the Tire Dump and Solid Waste
Landfill
- 0.30 yr for the Town Dump
The decay constant of the solute was used to simulate
degradation of the solute or contamination. The decay
constant of the source was used to simulate "decay" of
the source.
6) The quote referenced does not refer specifically to the
retardation factor in Weston's report but was taken out
of context. We agree that the retardation factor does
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not influence the maximum concentration and the report
did not state otherwise.
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III. 'Leaching Model
Xentex requested that the equations used for the leachate
model in Appendix A of the TS be presented. The following
is a step-by-step presentation of the actual method used,
including all assumptions and units:
1. Estimate initial mass of given contaminant in the
source:
Assumption: Contaminant is uniformly distributed at
average level found in test pit samples.
» C . * T
w *
Where: M,, » initial mass of contaminant in
source, g
Cs{ • initial concentration of contaminant
in source, pg/kg
TM(B » total mass of source area, g
2. Estimate Kj , the source material/water partitioning
ratio:
By Definition:
Where: koe * organic carbon/water partitioning
coefficient, ml/g
foe « fraction organic carbon, dimensionless
3. Estimate leachate concentration, C (pg/1):
Assumption: Water and source material attain
equilibrium
Cl - c. * i
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4. Estimate mass of contaminant leached per year, M.
(g/yr) :
Assumption: Specific gravity of leachate is equal to
unity.
cm 10
Where: I « infiltration rate of rain water, cm/yr
A » Area of source area, cm
5. Estimate soil concentration after year of infiltration,
(Mg/kg)
c.i*i - (M.i - Mt) * _1_ *
kg
6. Repeat Steps 3, 4, and 5 for as many years as required
for the model application for each contaminant. Total
organic mass and/or concentration can then be plotted.
Comment t: Xentex asked why benzene was not identified as
an indicator parameter in the EA, and why the FS fails to
address why benzene was added as an indicator compound after
it was eliminated from the EA.
EPA's Response; As explained in Chapter 4 of the
Endangerment Assessment, benzene was not chosen as an
indicator compound because, during the NUS RI, benzene was
found in only one soil sample and eight of the 60
groundwater samples at relatively low concentrations
(approximately 12 ppb or less. During preparation of the
Supplemental RI, benzene was detected in 19 of the 51
groundwater samples taken as concentration ranging from 0.2
to 43 ppb. Because of the increased number of occurrences
and the higher concentrations detected, EPA decided to
include benzene as an indicator compound.
Comment u; Xentex observed that it was not possible to re-
evaluate the groundwater target cleanup levels since two
crucial tables (FS, Appendix A, Tables A-l and A-2) were
omitted from the Site Administration Record.
EPA's Response: Xentex noted that Tables A-l and A-2 were
not included in the FS. This was acknowledged by EPA, and
the tables were distributed and placed in the Administrative
Record during the public comment period.
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vt Xentex observed that if the groundvater
extraction system impacts low-lying areas which are
classified as wetlands under New Hampshire law, compliance
with New Hampshire Wetland Board, RSA 483-A and RSA 149-8A
would be required.
EPA's Response! EPA agrees with this comment.
Comment vs Xentex commented that the public health risk
values presented in the Weston supplement to the
Endangerment Assessment conducted by PRC are misleading,
poorly documented, and do not follow EPA guidance. Both the
risk ratios and the carcinogenic risk may be over-estimated.
It is necessary for the risk ratios and carcinogenic risk to
be recalculated. Further, it is unfortunate that inadequate
explanation and documentation in the supplement make this
critical portion of the EA difficult to evaluate for its
adequacy and use in the FS.
EPA* s Response; This comment summarized pages 41 through 45
of the comments presented by Xentex. Several important
misstatements were included on these pages:
• The Weston calculations presented in Appendix B of the
FS are intended to supplement the EA prepared by PRC,
and not to replace Section 8, as stated by Xentex. The
calculations presented are not intended to be an
independent endangerment assessment.
• The calculations performed by Weston to determine
noncarcinogenic risk ratio and incremental carcinogenic
risk, conform to the methodology specified by the
Super fund Public Health Manual. The Manual suggests
that in certain cases it may be appropriate to divide
chemicals into groups according to toxicological end-
point, however, this additional effort is not typically
requested or performed.
• The equations used to calculate the noncarcinogenic
risk ratio and incremental carcinogenic risk are
presented on each Lotus 123 spread sheet presented in
Appendix B of the FS.
• Xentex incorrectly assumes that the groundwater and
cleanup levels are strictly risk based. In fact, none
of the levels are based on calculations presented in
Appendix B of the FS. The reference for each of the
target cleanup levels is provided in Table 2-6 of the
FS. The calculations in Appendix B were performed as
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part of an evaluation of the adequacy of the target
cleanup levels.
r_
• Xentex states that "the post-cleanup risk ratios and
cancer risks are too high, because they include
compounds which have not been identified in
groundwater". This statement is incorrect. The
compounds in question are indicator chemicals and,'as
such, are included in the Appendix B tables. Since the
compounds have not been detected in groundwater, and
are not expected to be present in groundwater, no
groundwater target cleanup level was established. The
cleanup level reported in the tables is "NA" for each
of these compounds, and the calculation of risk ratio
and cancer risk did not include these compounds.
• Xentex states that, based on its comments, it is
necessary to recalculate the noncarcinogenic risk
ratios and the carcinogenic risk. The values were
recalculated for all scenarios presented in Appendix B
of the FS, in order to determine whether the changes
recommended by Xentex would result in a change in
calculated risk which affect the remedy selection
process. The recalculated carcinogenic risks were all
within one order of magnitude of the risks reported in
Appendix B. Therefore, Xentex1s recommended changes to
the risk calculation would have no bearing on the
remedy selection process.
In addition to the above major comments, the Xentex report
also presented other minor comments.
• EPA acknowledges that fluoranthene is not typically
considered carcinogenic. This compound was removed
from the carcinogenic risk calculations prior to
recalulation.
The use of a ^relative potency factor" for various PAHs
is not currently recognized by EPA.
• The cleanup level presented for lead is 50 ug/L, not
50 MG/L as stated by Xentex. The basis for the cleanup
level is the MCL for lead, as stated in Table 2-6 of
the FS.
• The cleanup level presented in Appendix B for
diethylhexyl phthalate was not adapted by EPA for the
Site was therefore dropped from the table prior to the
recalculation described above.
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qomment xi Xentex requested that the alternative of off-
site treatment of groundvater via a sewer to the POTW be
considered in further detail. Administrative requirements
that feould be imposed on discharge to the sewer by the
municipalities of the Town and Manchester, and by the State
of New Hampshire should be determined. Limitations on
chemical parameters of the discharge must be determined in
order to assess the need for pr«treatment; these limitations
oust be consistent with all other users of the POTW and also
consistent with New Hampshire regulations. The costs
presented in the TS for the POTW alternative have been
grossly exaggerated due to the inclusion of an extensive
treatment system.
EPA's Responses Alternative MM-3 was evaluated to the
extent necessary under the Feasibility Study process.
Administrative requirements and pretreatment limitations
were assumed without filing permit applications on behalf of
the PRPs and entering into permit and agreement
negotiations. In the event a discharge to the Manchester
WWTP is selected, the pretreatment limitations would not be
determined by EPA. The issue of consistency of limitations
with regard to other dischargers of contaminated groundwater
to the Manchester WWTP or other New Hampshire POTWs must be
addressed with the permitting agencies.
The costs presented in the TS for MM-3 and MM-3A have not
been exaggerated, as suggested by the comment. Explanation
of the basis for the treatment system is presented in
Section 4.3.3 of the FS and discussed in previous sections
of this document.
Comment vi Xentex stated that the possible applicability of
a no-action MM remedial action which approaches a "no-action
under CERCLA" alternative must be considered in further
detail. This alternative should include the SC measures of
capping of the landfills in accordance with state regulated
capping requirements for municipal landfills, which would be
required if the Site had not been listed on the NPL. In
addition, the no-action alternative should include a routine
groundwater monitoring program to evaluate groundwater flow
and quality conditions upgradient and downgradient of the
landfills. The monitoring program in this case would serve
as an on-going detection monitoring program and would be
used to identify future groundwater quality both upgradient
and downgradient of the landfills.
EPA's Response; The so called "no-action under CERCLA"
alternative that Xentex proposes is for all intents and
purposes the same as SC-2, the chosen Source Control
alternative in combination with the implementation of a No
60
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Action MM Alternative. The no-action alternative for the
management of migration alternative, (MM-1), does not
address contamination currently in the groundwater or which
may continue to be released from the source areas. EPA has
determined that active restoration of the groundwater is
appropriate for this Site. As discussed in Section X-B of
the Record Of Decision, EPA considered its Ground Water
Protection Strategy and the Agency's draft Guidance on
Remedial Actions for Contaminated Ground Water at Superfund
Sites in reaching its decision on groundwater remediation.
Comment zi Canonie questioned the approach of sampling and
analysis of groundwater at the Site. In particular, they
questioned why wells located in the "central plume" (A-30,
GZ-3, GZ-6 and MW-9) were not sampled during remedial
investigation. They also saw no objective to the analysis
plan for the wells.
EPA's Response; The sampling and analysis plan for the
supplemental RI was designed to obtain a representative view
of the Site, with limited available funds. Well A-30,
originally slated to be included, was found to be damaged.
Again, with the analysis plan, only a limited number of each
parameter were allowed; therefore, a representative
distribution was selected. As the groundwater monitoring
performed during the supplemental RI was a confirmatory
study, the standard parameters previously analyzed were used
again.
4. The Overall Preferred Remedy
Comment a; Sanders suggested that, on the basis of the
sampling results, EPA prescribe a remedy which will
effectuate further contaminant reductions.
EPA's Response; EPA believes that the remedy proposed in
the Record Of Decision will effectuate further contaminant
reductions.
Comment b; the Town said that the choice of a remedy based
on the FS and not tailored to the principal contaminants at
the Site would be arbitrary, capricious, and inconsistent
with the National Contingency Plan.
EPA's Response; Refer to Atachment B.l.k.
Comment c; Peter Johnson stated that, to the extent the
public has spoken, the public has found the preferred remedy
61
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inappropriate.
EPA*g Responsei While it is true that, for the most part,
the public (i.e. local residents and potentially responsible
parties) has expressed concerns that EPA's proposed remedy
is inappropriate, the reasons for those concerns are quite
different. Local residents do not feel EPA is going far
enough with its clean-up efforts, while potentially
responsible parties feel EPA is proposing a clean-up effort
which is too extensive. In choosing a clean-up remedy, EPA
aust evaluate nine specific criteria which include community
acceptance. Ultimately, however, EPA must choose what it
believes is a remedy which is protective of public health
and the environment and cost-effective.
5. The Site Removal Action
Comment a; Peter Johnson commented that EPA has
consistently attempted to mislead the public as to the
amount of hazardous material removed from the Site, by
stressing the large number of barrels discovered at the
Site, when little hazardous waste was found and air
monitoring indicated no measurable increase in contaminant
levels.
EPA's Response! Mr. Johnson's perception that EPA has
attempted to mislead the public regarding the amount of
hazardous material removed from the Site is understandable,
given Mr. Johnson's status as a potentially responsible
party, but it is inaccurate. During the removal operations,
EPA issued weekly newsletters informing the public of the
removal activities which were occuring. Newsletters were
also issued to the public as materials were shipped to
various disposal facilities.
Although each barrel excavated was sampled, individual
samples were not analyzed, as the cost of this analysis
would be prohibitive. Rather, all samples were mixed or
composited and the composite samples analyzed. Results of
the composite analyses showed the presence of hazardous
substances. This may not be the procedure Mr. Johnson would
have followed. He was asked to perform each of the barrel
removal operations, however, and declined both times.
Comment bt Peter Johnson stated that abutters to the Site
do not believe that EPA has found all of the barrels of •
waste on the Site.
EPA's Response; Refer to Response c in Section III.A.3.
62
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comment ct Peter Johnson stated that over 95% of the
material removed from the Site was non-hazardous, non-
regulated solid waste, and that this is what would be found
in arf old landfill and left there. Peter Johnson calculated
that less than 40 gallons of actual undiluted hazardous
material was removed from the Site.
EPA's Response! Mr. Johnson's comment that over 95% of the
material removed from the Site during the 1986 removal
action was non-hazardous, non-regulated solid waste is
correct with respect to the manner in which the material was
shipped off-site. The term "Non-Hazardous, Non-Regulated
Waste" is from the shipping manifests and refers to
designations used for Department of Transportation purposes.
This material did contain hazardous substances. Based on
the 1986 manifests, 704,080 pounds of material designated
Non-Hazardous, Non-Regulated Solid Waste was removed from
the Site. In addition, 8,860 pounds of PCB waste, 21,400
pounds of Hazardous Solid Waste, and 3,560 gallons of Liquid
Hazardous Waste was removed from the Site. Mr. Johnson's
calculation that less than 40 gallons of actual undiluted
hazardous material was removed from the Site is unexplained.
However, 40 gallons of undiluted waste could conceivably
contaminate as much as 20,000,000,000 gallons of groundwater
so as to exceed EPA's clean-up goals.
Comment d; Peter Johnson suggested that it is appropriate
for the agency to tell the public the truth as to the small
amounts of contamination uncovered and removed from the
Site. And, that it is unfair to solicit comments based on
intentionally misleading information distributed by EPA.
EPA's Response; EPA has attempted to keep the public aware
of the seriousness of conditions at the Site. Although the
amount of material removed from the Site, as stated in the
above response, may be small to Mr. Johnson, it is a
substantial figure to EPA.
Relations and the Public Co^^ent Perj
Comment a; the Town and Canonic would like to meet with the
State of New Hampshire and EPA to discuss further activities
and comments of the PRPs, and to facilitate such a meeting,
renew their prior request for a 60-day extension of the
public comment period.
EPA's Response: On June 21, 1989, the PRPs were permitted
to present their comments orally to EPA. This
responsiveness summary takes into account all the PRPs1
written and oral comments. Regarding the PRPs1 request for
63
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a 60-day extension to the public comment period, EPA
evaluated the PRPs' request when it was first submitted and
determined that a 60-day time extension was unreasonable in
light of the original 35-day comment period allotted. EPA
did, however, agree to extend the comment period by 14 days.
The revised comment period ended on May 18, 1989.
Comment bt Peter Johnson stated that the failure on the
part of the public to attend the final public comment
hearing is indicative of the frustration the public feels
towards EPA's performance at the Site.
EPA's Responses EPA disagrees with Mr. Johnson's
observation that the failure on the part of the public to
attend the final public hearing is indicative of the
frustration the public feels towards EPA's performance at
the Site. The two informational meetings held prior to the
public hearing were each attended by 30 to 40 people. As
explained during the informational meeting, the public
hearing is only a forum at which people who wanted to
comment on the RI/FS or EPA's proposed plan could do so and
the comments would become part of this Responsiveness
Summary. The lack of attendance at the public hearing only
means there were few people who wished to express oral
comments.
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ATTACHMENT C
r_ ~~_~^
TRANSCRIPT OF THE APRIL 25, 1989 INFORMAL PUBLIC HEARING
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCV
PC-STON PE5IOM
1 «-. *• K a H a +• *• e ~ •-. r •
8 I
Londonderry Middle Echool
r.emiTicth Road
Londonderry, New Hampshir
uesday
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II
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To
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The e.bove-5-titied hearing came on for riearing pu^suar-
Noti:e at 7:^0 -.m.
B'EFQRE; CHESTER JANOWSKI, Chairman
Remecial Project Manager
Environ.Tiental Protection Agency
I.r.r-.. Federal Building
Boston, Massachusetts, 02203
APEX REPORTING
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Cl-.erter J.-r,: -v
W 1 1 1 - 5 T ^ *T S 9 . **
Alan Sim*r±
Richsrd Pesse
Rspcrters
«'ol*:» 426-3077
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• ~ : <*0 ;••• "•• '
»*'=. HJEE'^E-".: "'= 1-ii'S1 to tr.a.n!- YOU r.ll for
coming this e"er.ir.c;. f^y -.5-2 1= tE".~i= H-.iebri&» . I'm
the Chi--* of the New Hampshire anc! Rhode Is lane Waste
Management Branch in EPA in Region One.
'"iy staff and 1 are responsible for the
implementation of the Superfund program st the federal
level, both ir, the states of New Ks:Tipshire and Rhod =
Island.
With T.e ton.c'r.t, and they're going to serve
or the panel for Thi = near ire that's coir. 2 to be
Chet i= the site manage" for ERA on the
project. To his left is Art Cunningham. Art is the
consultant. He is from the firm of Roy F. Weston
Engineers. To his left is Dan Cough1in. Dan is the
section chief cf the New Hampshire section.
Dan is the person that does all the
Superfund worl in the State of New Hampshire supervisor
in EPA. To his left is Richerd Rease. Richard is from
the New Hampshire Department of Environmental Services.
The purpose o" *•?•••..= ffi»?tir..r! r.r hea.rin-r.
tonight is to formally r ••"•?£"" •••'''-•••' comments on the
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SC.VT. Road remedial ' nv/g=r. - ... i. i....
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":• dr.t? TPA Ne« .-.: r.cji., rted tw-:- public
i--f •:'*m*ti :nr. ! mestin-E or the PI~5 sni -he ?r.:.p-:ss?tf
pi&n. Tr:e -first one war helc on Wedn«sdav, ^!^rc^ 21; .
i*5?, the ss-conc :-ne on Thursds,, ^arch SC-. l'?S'r. in
which we presented the in* oration in the RIF5 and the
proposed pis.r. to you anc spent e> fair amount o*f time
respondinc *:• questions ana comrrients that were raised
c.- •-•:.!. IT. rt-.* oi.-±i = nce.
The public comment perir-i sessn or.
KarcK 21. 1989. 3n Arril 12*h *.nc 12r^., l*.«t wec4 . EB
receiveci two rscy«sts to extend tne public comment
period an additional £0 days.
ECA. in writing this past week, agreed to
extend tne public comment period an additional tw:-
I believe that there is a press release
over here on the table for those of you who wish to
picl' up a copy c-f that incii catirtg what I verbally have
just told you
fevissd comment ;>er:ort wi 3 1 now run
=r. ' '.' *- . l~, 1'rc'r. Thot uill
APEX RZc'0"T!
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consist of s total of *•••:• dr./s.
S* &•'":•'• e.- te.-..":: nr.i nr,, I - ••-.id li».e -t:. ies •: ••:. se
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tc >••:••.' the f*-'-mat fo" th = r.ec^-n:;. Esser.tic-l I> , rr.c
e-'-'er.iT'H i? ::;•;.:•;:; t: bs rtrv.itv."s-ci as f:-lic'ws:
"^^5:- -first thin: I? rr. g:'in- t: dc is ssl CNe
jsn:-w=l:i, WHO'S tv:e EPA site manager, to stand V.D hers,
s-.rci what ue's going to C-: :.s p^essnt £. sum ma -y c f the
proposed plari to yoi.1..
following his presentation, ue will =CCE?T
sny oral comiTier.ts you. may wish to mal:e for the record.
Tho== r "f •-ov. vishir-r: :c ;orr..Tier:t sNoulci have a!.- = =rv'
indicated vo'.1' desire to do so by filling ov.t the card
that are or. tNis table to my right.
If you ha.ve.Vt already done so -- is there
anybody else -- so far, we've got three people' that
have indicated a desire t:> comment, offer some "-"al
comments.
Is triers anybody else that has decided to
do so right now? If you have, raise your hand, and we
will make sure you get a card.
Okay. I'm going to call on those of you
wishing to make a statement in general in the order in
which vou signed up.
Wf'er: I call ypon yo>.-, I ask you. to c :•(!••=• to
PHV RE
Profes
sional Reporters
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the fv:>nt of tNs rooir.. w» i'sve r- microphone set up
3 li
I here. Comment direttiy 3 r.to The mi crophc-ne..
I .-:«•: troug'.t atjout, a.-.ti cipatir.c « i».-per
5 jrc-up. that ws tr-, t:- lirr.it tf.e •: -..a-fnfrntE tc- IS min-.-.*.»£
6
is grin:: to be necessary.
ovld only ask thst you t*.» s into account that ! was
- — ----•• -onsicerinc * 15 rr.inute period.
I was going to ask you to summarire if you
i
felt thet you had to go longer thar. the 15 minute
'' period of time. I don'- res-.lly think that's necessary
to limit y: .. r.t all this ever.ir.g.
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13 ' The te::t. in tw'£ entirety, is going to be
14 '
I transcribed. There's a Court Reporter that's here this
15
evening. !t will become part of the hearing record,
Following your comment, I or another member
of the panel thet are v.p here, e*e going to have the
opportunity to ask you some questions, if we desire to
19
do so, to further clarify something that you have
20 stated.
Afte- all the comments have been heard,
I'll close the hearing. If you wish to submit
additional written comments, and I encourage you to do
so. thess must be postmarks,;1, no Ister than lay ic,
23 !9C9, ?.nd .Tailed t: ov.r office in Boston.
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f.
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appropriate address can tf- found or- the
3 [ proposes pi».r.. It's or. Pijf.- I1. '••^' ve ?•:••! .-ropier of
i
the p-c-oser plar. over :.c--e :•:-. tr-e t-.tle. ^'a> e sure
that .ou I:-now wrtat the ro'rect mailing acdress IE.
At the conclusion of the hearing, please
7 see an/ of the cPA representatives here Tonight if you
have =.:T/ questi:-ns or. the process for making comments.
9 All oral comments we Deceive tonight, and
those we receiving in writing during the commen
11 period, will bs responded to in a responsiveness
*'2 ' summary which EDA is required to prepare.
'
13 ' The summary will be included with the
decision document which we refer to as s. record of
15 decision that EPA prepares at the conclusion of the
16 comment period.
1/ Does anybody have any questions about the
format that we're going to use to conduct the hearing
this evening?
20
(:NO response. )
21 MR. HLJEBNER: Okay. Chet. would you please
22 give a summary of the proposed plan?
23 MR. JANOWSKI: Thank you, Dennis. • I'll
24
briefly go over EPA's proposed pl = r:. I kr.ow most
•.•ou he.ve -- if not all of yov., have ccT.e to at least
APEX RHD2PT!NG
Registered Professional
C 617:^20-307"
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•:•-»= •:••? f.s rv.ii-lic meetings
has pf svac JE 1 > -
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jr rr.e-" C-'s. ..
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at*:; tMs *.s the towr d'.'fir area. This n tNe tire
&re?.. This is tNe £•:• lad weste ».rev.
t'-s* EF'A is pi- •:•?••:•£ inc is, S*5ic*.lly, * twc--
ftcproach. Th« first p^ase will consist of
o •!-•:• uno water «-trac*icr. and gi-c-vncwrter trsa*mer,t.
w^.?t rhst will cC'Tsist :f is installing a
T.i?7ib5~ •: - E ,; tr; r *:i :•- -js'.ls. ~'5E5 vill bs wellr --
wr.i.t ws call wsl 1 -- s.r. overburier.ed well and a tscrccl
well ass-: listed wif e?.:r. ;-!--.
~r:ȣe will 5: in at th* dc-wncraiing end.
downgrading side, of each of the source areas. The
ground-water flow is moving in t!-iis direction towards
-•:•:•. =.s S'r:..:.r, w.t:ito.u. is out r.e;-e.
So these wells will go in. In aodition,
there will be extraction wells put in jsnerally along
here which is about the property boundary line, and
then to get off site migration, some additional wells
will be put in on the north side of the Whispering
R-5c:iStered Professional Reporters
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there will be so^e trenches installed in the tire sump
area -- I me=-r. th=- town dum- £.-£= i.ntf t'.e sclid wests
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ares to collect the- shallow g'oundwet-rr -flow w-r-n.ir.- of*
G.S. rr. ,-. * +• *-, JE s -r- >.'" c e s ^ e r. ?.
5rc".«ndwe*er -fr-r-rr. thes» areas will be
gallons per minute, to a t-ertmerit facility located
generally in the center of the site down here.
This treatment facilitv is going to consist
of metal precipitation, air stripping where ths
'.•olatils organic cor.r:-::-'.r.i = , which are contaminating the
cr r'undwster, would be ta.V-'sn out <~ * the -- out of the
water, movec into an air stream, collected.
That air ctrssrr. will be passed thrcugh
activated carbon where it would be cleaned up, and then
the air would be discharged back to the atmosphere.
The ground water coming o-ff o^ the air
stripper will then, if needed, if additional treatment
is needed, will be discharged again to an activated
carbon unit .for further cleaning.
The intent here is to get groundwster --
the groundwater cleaned up to a degree where it meets
driving water cjuality.
T-'-t groundwate". :-nc» it romes out o* the
—' ez. f •" cr ^ is y o P P ••* ("i T «a it sr * .*. *•• s ^ K' i- ^,". i' A- ca ?" ct
v-t • » — — »»• i w . •-,__• v „ _
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il. tacl wi
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rarto" units, will te .;:_:'•£•• >-2
•a::.? c/fr t r-pr, •:-,=•£ l:.:^-.iS :•- k.
rms -,•-,''•-•• - -. v .M
« 'I »• • . fm. I •• . • • • • •• — •
tc- ±5 '.=£-± •!•- -::'.! = r: oi.i* cc-rtsmin-r-'ts
cuir.~ and then aaai~ r-srs ar trie solic!
*••>«• tir
area.
Tieli
this, being th
ilsar.--.tp for
?.t e c-r-st of ?.ppr ; -.ii
million
That cost includes £.11 costs to ccnst^.tt ths
facility and to operate it for that ten year period.
The whole intent of that groundwater clean-
up is to hold back the ground-water contaminated plume
which is migrated off site, take the contaminated
gr :-v.-.d--»5.te~ wnich is on site, clear- it up so that at
this point, along the property boundary, as the water
moves off, the grov.nc!w£>ter moves o^f, at this pcint it
now meets drinking water quality.
Dr.ce that is fttr.ined, the second phase
will be implemented, *-ici what bhat will consist- cf is
A=>EX PHPCR-irJG
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i =•:••...-• :c area?.
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' t!-.r.t you r,.--- sec- urv.l- be E" sided, cvt : -. t-.e cite and
r. r ? p 5: a :&-' -. .•e*- t r =..*..
7r,&re is a sm= 3 1 warte tnound '.e-.;t TO the
-- '.;p here. 7Nst would be moved over onto the solid
entire area w:-ulcJ be capped.
~'.'. 111 -1 ays"ec; cs.p. There will be a co'-'er layer put
"••'"' "• - "•---e ."v. ~v -•as;ra.i'-. .: . s '.•£•- i« C^T, JL : . _~
a-/ h-le= .-r pot hcles the.t are contained or the sits
now, followed b/ £ =^rc; laysv =2 a sub-base for z.
svr.thetic cap.
The synthetic material would be placed
down. There would be a drainage net placed over that
to collect any drainage coming down from the top of the
cap that would be redirected along the plains of the
synthetic cap, itself, to drainage trenches and carried
off.
Thet, again, would be -- would be jv.st
clear drain water as it came down. Above the synthetic
rap i r the drainage ] r?ye-r we.. • 1 d be =•. sand fill lays'
Registered Fr- ,-. f ess -ior.s 1 Pep:-rte.*s
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cap. and :r. t-:= cf that wo-. Id be * ioamed arec. thst
wO'..Ii svpyort vegetation.
r
-r.c .-. .... •„•-.-• vici :•? seeder -c- relp -- *•:• :el;
5 irr.prr-vs i-.-; 1 *«*r; :•- dovr *-••-;.•.-- here s: thst u
6 - - - en_.
Tr.at -- again, that wo-.-.ld be -- that cap
would be instal. I.es o~.ie rr-.s jrc-vncwrter ils?.:—.:;
g
teier, place. T'-.s estimated cost for that is seven and
10 f hal-* Tiillic-r. d:-I Is.rs, so tr.s r:t&l cost that we're
11 tali-inc; about is sccewSe-s in the vicinity cf 2-
12 riill.on ioll&rs f:.- boc-, rhases.
13
M=:> H'jEETisB; n'.;ay. y.ank you, wT.«t.
no*1 uC:ir;5 to tejin to stsr-
15
from the audience, end, in jenerai, .'m
16
order that people signed up.
1< The 'irst- z>ersc«n is William Stearns, III.
15 MR. =~=fiRr-J£: 5:-od evening. I thinv -- I.
19
wasn't prepared to r.al:e a statement this earl> into
20
this evening's pro;
21 I guess Ifr; a resident of Auburn Road.
22 live ner-.t to ths former tour, landfill that's indicated
•on the map>.
I co have soc.s iorr.mer.ts torii;r.t. I hope
* - - ' - •• -- - «• "- • . _ JT « _ _ ^ ... ^ - . i n jj i v ; d v a 1 E that » ? - i ~
ApCV STrn"?^ T ».'l?,
^^ > mm _ W I X « mJ
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this ".:-:-r ••'epvesentz-.c the va'ic.us stste and •?*?. = ?si
I
wr.at's bsiin-z Dvoposec r.ers thir everinc. T-. = -s =-e e
nursr-p!- c-f rees-r-ns why.
I thir.J. I'll just keep it to what I feel
a-e proratly •:!••£• roo-*e significant reasons. ! tr.inr,
first, I've t.az &. lor.r time to review all the r.is-ory
:.f this site zating back TO 257*, all the way th^:.u?h
Wh?t !"'-•? ^sviewed is nc-t included i":
public ±:-.:i.iiT.snt= that have been available at the town
library, bvt also the ru.Tiero'.-s news articles ths.t -sre
published on t^is. sits and the various statements tr.at
were made over the years by various public officials on
both the local level, the state level and the federal
level.
Consistently, with all these statements
that were quoted, they've underestimated the size and
the scope of the problem at this site.
Starting back with Tom Sweeney's quotes,
back in the early part -- latter part of 1979, where he
was qv.c-t2d in th'e newspapers as saying that barrels
cc-r.tr-in <-•: !v = z = -d-".:= waste. Just s rubbery-] ik =
APEX R
Registered P*ofessional.
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s *frs :•! -tel y
,t. 3?
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t^le*.'5 n:-t ths- -&:
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**•«/* W*'
ot leir,-.. Tods, w»
t:i£*e were some
?£.:'-.
tr!;, v.'-er. -tr.ey
ir, April :
_ .- — . ,..t| , 1 .J w
=.»rrel£ taker C'.-
f • B£ . the resice--t= vs-s
tc io the ev csviti :•-. •:••? t
.^ t = k . :••-•— Ti.-"i.i*' -, — H * "• '
. ?t least, ts'-sr. c---.t
= •:• it-s s little h.a'd -:•* me t:- r.rrept tf.e
•fact th&t I'vg been tolcJ today that we -fsel we.'ve
gotten the majority of the tarrels out of the^e.
I C.:TI? t oslieve ycu'vs taken ths majority.
sf the barrels -:-v.t of tSe s:-lii wsste landfill ares..
Common sense w;.«.-.ld tell you that you've indicated that
the highest -- the plume thet h*s the highest
concent Cation of hazardous wa=te is the one that's
emitted from the solid waste landfill, but yet you took
tt-.s least r.v..Tb2^ :•* barrels ;,at. of that ?"e£> so ! .;-.!St
•- I ?.:-'*• i?e --'.sre the least rvr-rsr c f r-5-Tls tw.?t
d Professional ^
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•&;• . and the- rlum-
The two .:f their. .;-.;st ::,.-, 't -,;,:*. u-rii.
ror.sidering the fact that y^.. t :..;•' 1 . 2-:"!- t?.--.-c-l= :-..t : '
the clti town landfilJ.
7>ie procc-tBi ffiethc-cJ fo' cisaninc; trie
ndw5.ter is assuming that you do have the barrels
t.u.s g-.-:.'.!-.±.
Now, I toot: pictv.r=E o-f the barrels e.s they
cioir~ tK?t wort.-, =-.r.± th= quslitv •:•- =:me c--* tf--:--2-
r.frrsls th;.t wer= cosine ov.t •: -' the g'cv.r.d uer= ir
?r = tt.' c::0=! condition so if ;.';...••«•« still cot b=.T- = l= in
the ground anywhere in there, in either the so'! id waste
landfill or the tire dump, the^ -'hr.t yov do over the
next ten years is not going to guarantee that those
barrels r.avsn't deteriorated ar:d that the hazardous
waste has been er.itte- to the groundwate^s supply.
I-f it hasn't, you may go through this whole
process and then 13 or 20 years frorr. now, you may have
those barrels rupture, and y :•:.•.' re going to sts-'t the
process sll ove-> again with t1---? c'l-undwator ":=:--
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rj =~ wit:-. «f»i*tfs fre.-iC • .-I'Z-.-'BS.
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- •*
* T v. r s p* :•-.-:. i ir-
are*. Tc ms. tr:5t's ^ini c^
c'v.sr '.ir.'dr t.N^ r-.i.
t : ?v.* e ;*.p ever
tNff »?v.ivaler.t •:•*
It's f "«.'.Etr3tir.5 tr &»e that you* we -- vou
".'~.= r-,5- zuicElir.ss that if ,•:•>. dc e,.cav*te
there, you have- t: treat TSe soil. and that's
dr. liars T-: ir- s.-'trv-ti:- arss cortainmert and icv.tls-
lined landfill to 30 or 40 r.illion dollars, but if you
go tack to the history of the sits, the town had
received a preliminary feasibility study frotr 5IA ±e.:l:
on April 25, l?StT, =:• that's fou.- years to the da/,
iniirating what its options were.
One of them did include to do excavation
and containment. Now, under the old HFA guidelines
that were in force at that time, prior to the
reav.tho'i = 5tior art :- 1SSS, 1 balisvs that would have'
been an acceptable mcthcc.
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is ?-inc tc- c.1^?.- v.p tf-e
believe it's unr,e:es = £r
which dossri't. 5- -ar erov-j
tSs^e. E-''e.nJ:
s---.r-reit5.nt. &~c
.t tSe seme ti.T.s.
s se
srms.r.er.t ly sclve rr.e
i^s ±or-.e e:^d t-.s.t t^-= Fr= should -=.y -"or that.
Now. if the soils have to bs treated, then
*
it's my opinicr, the E?A should have to pay for tri?.t
because ^a-r necotiatior.s baer. done 5 little bit better
ir^ the r,isr:.-y :~ this SITS bar'- i~ 15=-•'•, the t:-wr. cav
have well te = r. able to have continued with its
•*e.^ — - u,- i •; *•.• — —.,.a,, i.i. .,j. ^ i. .,- - _<-,__ .,; 4.w. n:~A - - *•>• =
(&..•«*.«.'•»• V > S V ^% hj f *r • ! C. * 1 to W Cf. = U •' « P< ^ •» i W . . M ^_ f^ C. .• *• I ' S
time, and that clean-up option could have been
ev.E"ciE-ed- under the old Euperfund acts-, and it cannot
APEX cnpncTING
?*"-~-^
{?!;iion8-.l
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•-..;:. P'l'i^ss go -r for ter •:•
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"vies c '£ sting rr.c.nged b>' t*ic
.&;.--i an-r .-^.c ^-*s to z
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^ L ^ ^,«fc.
. i-t „.•.•_•.
eri or the er.vironmer.tfliEtE whc- thir.t th*t
tr,f>t were enactew in "So. I've come to tNe sad
conclysior that tr.c-ze new laws -- the or.lv thing
they've done is they've eilc-.'Si two soectrums, either
f-.:.-r. ;:sr, 'ir?- :«* 1 1 y unacceptable clean-ups or * lc--
cost :;tic-: which reelly doesr.'t s-r-lve the prctlerr..
I think realistically •':•»• *. let of these
site* in the coystry the only r-eslisTic v«y to h*-.ile
these sites is gri-.g to be c!o excavation, containment
anc! dout'le-linei landfill.
Trer.tirig these soils is probably never
going to bs a realistic option, at least probably in
our lifetirr.es.
I don't believe what is g-r-ing to be
proposed here tor.ifht is going to adequately handle the
problem over the long term because of these issues that
I've br-^v.-j'-.t up tonight.
I fr-r'I that vhc.t . : v are pr:-posir.-- he's, if
APEX REBDFTIN3
~r.' — i cr t £• 's i P :*C1 f ss r i onr- ^ Pf?•"• -r11* t £•" 5
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.- . .-(-. .— - -. K «i .i J ,,.*k .* _..»_. _._ .-.. ^- K c- ^ -. — •—--•• - -
- _ w. r - i'.. i S sr _ •>.«>. - . f ,.-.•»& K. = » v.ic r- ___._.. .-.
,'.?.*: a-. I go ing :••:• C: wz.tr. .T.-. -.r :.;..,.- {v.
I
I' c , etser:^; " " ,. , 51-1 ng t :• have .- '-.=.--'-
.':.ste dump abutti-.g r:v propertv whirh i= g---r,g t: ts:
re nterri Ti?.nt= csn come onto my p"c-pe!"T/, ancf what i :• 1
i-i: £.t-:-_t t^.ft wSs-. I c-.pprc-ecK either o bvye-. s selle.'
c-r what civ I dc- when ! go to s. fcan'r.: and S=K "for
mcr tcc.ce ier.cir.z"1
I've (-.si a 3-:-t of time to research that --
those i = = '.'.es. «.~.i ^'!~'£7 *' ~. c^ttiriC ^izht now *"-i'fr ti*.5
••'£ r i T"'j. s i rs t i tut ions is not ?. verv cood &ns>JB^.
So, esssr.tialiy, yov.'re going to leave r.e
with =•. pv-rtieif: wr.ic!. i= .-•:• longer a short term problem
which is what was quoted to us, I think, bacl: in the
hearings we had in '=•£, but is a permanent long term
problem for ms to ceal with, and given the Statute of.
Limitations or. New Hampshire laws, it would appear the
only choices 1'fT- going to have for me to consider at
this point is to take legal action cgainst the DPP'=
because I only have a six year time frame in which to
take that action because if you do go ahead with this
action, do the clean-s'.p, and you don't '_=>p that =-,tc-
for te-i yerrs •:-.- bstts-:-, I've got 5 piece :.f property
Pegistered Prof BEH ior.r- ] °sp-->- te-s
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- _ • . i . _ i i • _ . . i. _ . . _ . • . k. —
. - . » « I •_• . . |T ... w . .» I • r v . i?T
- D
*.?vs t:- i •-••?: .-if t1--! ^-ssltr ar-i sir.-'e*/ c-f t»-:S
s-vir.:-nr«Brt. I'r Ir** u-i*' ?.=.vin-? to deal wits the
s : : r. :-.T. i : p- •• -:-r 1 S.T.S .
I will deal u-itJ-i those economic problems
wM:hev«r vs I hs.ve tc. r.r.i my options sre fairly well
A-air.. . don't relieve w'.s-.t yov. re
-••':•?•:•!• ir- h.B'-e is z: in-- t: s:l^s the problems in the
lo-.j 7 = r-T. ;E;S/. =5 ;- what T'^e stated, and I hope the
E=- =ar find so.-e -a- t: vesolve tr.is with the PRP's
that -'ill handle it rrv.ch better long term for both
environment and safety cf the health of the residents.
MR. KUHBNH0: *han',-. you. Before you --
William, befogs >•:•'.•. leave, does anybody have any
questions"1
•:T4o response. •'
MR. HUEBNEF:: Oi:ay. The next person that
ir-.t^'.f-^-s- thet they wished t-. spsai... and please svcv.se
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.1-'.. SlrARI: I'IT. A!,.-;-. £i(T.c--.-c. I'r, or,. .: -
tr* :•-Tiers -f Wr.isp= . ••.• r'i~«i '-'.'i-le Hon.=- vi; :*:•£•
•~"•::.:!•' is or 't^iS r,ivt^. -~~ tt'.e sij:&.
We a.lso C.'-T. -- we C-V.TI c- tc-tsl o-f r-iC« &cr=s
*:• -he nc-rtr. onr tr.e ess* •:•* 1^-5 A-jturr P-:-a± lane-fill,
and tSsrs's 2£3 resiier-ts t.Sat live there, =•:• we have a
lot •:- corrs-r. a±..:••-•.t tr.s clsan-up at ths Aub-.'.rn F.-oad
I ion'- as^es-, either, that the
p.'-rpc-sed s:l-ti:.r. 52-2, n-irlv the Htoraas of tl-.s
har»rc!ou£ riaterial t!-;ere, is a solution.
I -feel tr-.at r.'.-.cb better sclutior. is t^s
incineration -•? ->-,= waste, SC-5. I -feel that SC-2 is
Just going to -- in the -future, we're going to have
more proMe.TiS. We're going to be back in the same
situation we hsve ~:0'~'.
Al=.o, a= far as the grouncJwater clean-up?
we want tcth the soils anci the gro-undwatsr to be
cleaned up on and off site, and we feel that Mh-2
bringing =. sewer line in and disposing o-f the water end
= :-,./ TI = te" i ?' r- ir \ t. -'0".'.]d bE' ? r.ors effective solution
DTp.-iri>'-T Kjr:,
ss-i£te:- = d Professional Peporters
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ji •••-_......._.
( •_•-"•---•' s-
6 .,. .a,f.,.,r,se. ,
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li EP- snd tNe state TC-- giving me the opportunity *•• mal'«
^1 !' - . _, _i
|j - v=r reer- deE;.gn:-.Ted *s spo
-.-...rz-=- :- tw:* ps."ti*a wr.-:. s"c- sllsged t> E=A t: b
13 '' pc-SBrtis-ll. i-ssprrsitle -Ir clea-iina up ths A-..bur
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Services Cr-rpcrstic-n, £ nationally r*nc
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2-
Oivr.•=.-.-= ----:nst ?.-.•: ! • 1 us1" i-.-c through tne
te areas Decs-use it would =• • 5 re-"t-r-V= • r~-t
!•;=• £**• P-. r:: lei a&•:.•-•*. wS-.- tr.e p^iT-r-Su-i
The serond point is be-"o~e an-/ rc-nedv- ;s
selected, additional aroundweter r.-onitorinc must be
done be;£..'.£= the data relied upon r>- r?~ i= at least
two years eld an; Ss-:5use ^uch of the pertinent ca~5 is
"he plu.T.s, as described i~ the report, is
rather on a sporadic and isolated high points.
Before effective remediation can take
place, the plume must be accurately defined. The
extraction wells which are presently propcsed did not
app=~r to te intersecting the contaminant plume as
defined in the report.
When available groundwater data is plotted,
clean-up target levels appears to be already met on the
sits. Therefore, we question why EPA proposes to treat
-•-•-••.'-•cw-r.t--- a~d soil flush v:her= taraet levels e--2
Pejir t ::--.-ed' ?r.: f essional Pepovte-'z
-------
12
13
U
'.5
16
17
13
19
20
21
*
22
23
24
25
14
""•:&.'?. sir-: azses-r t- .-*• £ cipnj-'icart
«i« '
• - -' --• - - '.pli-ig. TS«- date -f^ils to JT-.O'
I
i
5
6
7
8
9
10
r z-if :-&lat 10-. U'&r-'ee- t''ese off-Lite ::. ntaminants c.r.d
e on tr.* Sit& at sny time.
rie e-'.-ff-ctafci Ji^-y r-f the grovndwate" rfro«r,
i the cv®ris'.!>'cer 5nd -"rorr. bedroc!. must be determined
rrior to initiation •-•* remedial action.
In othe^ New England Super-fund sites.
ted^ocl. aquifers were net treated te:ause of the
's:o:-.ire= -"-..tilit, of tr/inj to cr-ve'-' jro'jr.aws.te^ -"o.*
H/irogev;.o;ic data mv.= t be pres-snted
show tr.rt ths re:ov«ry OT g-rv.ndus.te- -frofr, tSe
is feasible — I mean, I should say recovery and
treatabi'lity.
The EPA's p^eTerrerl alternative sugjests
that the co*.;ulatior anci precipitation unit i« being
desianed specifically for arsenic removal.
At least two concerns should be raised.
Target or bad-ground levels for arsenic appear to be
already rcet and, more importantly, the viability of
3-Tenii ":. 4T.**>=-t iD'-'Els VZ.V tMs prizess is dov.Ptfv.l
"-.5-rB*:'e. the fc-i-sibility c~ cossyletior,
-------
a.T;d cr ecisi tat i -.- .: r met*. 1 fv.-dr::, •.. : tie pre-:.: r: t~ t ic .-.
6
25
~;.- vhe-.- review should be cc-r-:r with ~5-spe:t
tc rt.fe-
c-vncwite"* t: sewer i»ns s.---. tension.
*--•- *• >• —— concerns are the "esult -r-* ov.:
8 pr-s lir.ir.ary review, anc further points may be
identified as our experts continue their ongoing review
10 of the reports.
11 Th« Serious-ness of these concerns
"2 demonstrates the r,=ed f:>r a more incepth techr.i :al .
I
i
i
14
15 "*>•£- = •• --rs, v,-5 believe additional time f:-r
16 public comments is necessary.
Thank you.
;e I ' r.P.. HL'EBNER: Thank you, Jim. Any
19 questions''
*° (Mo response. >
21 I " MS. H'JEBNER: Thank you. Did anybody else
22 I wish to make a statement that's here this evening?
23 Richard Pease, from the State of New Hampshire?
-itu. the h.'ew Hampshire Department of Environmental
APEX REPORTING
-< : _ a. _ v. _ j D „ ,-. •£ s, ? e ^ ,-, - ? i p e p.;, r t 5 r T
-------
!!
- »l
10
v, ,
13
15
16
17
13
19
20
21
•t
22
23
24
25
I
I
I
I —
VS'-.-E tss- ;-:•.:: "err ir. -he.. - : c,r&r £.1:
*".:-.:. r •*•"•'-= -'•"- fr.»n*gp'i*3 ar zir t*".cc-f -:nd :•'."
at^a.rtiT»ferit r.ar "eviewed the -feasibility -it-.tdv and
sv.3n.it res comments t-:« the -feasit-i lity study.
"""'IP dsp? "*ir.ert concurs with the EPA
p.-c-'-'seS clsr.. We ers willira to provide »r.y
as£iEt£.T::= nergsssry to tfie Town of Londonderry Sewer
Cc-Tissic-" o" t^-s n^rlc^estev• Wate" Worlds to "further
~Z'ir,* to *' i&rresmenT -:-r. Sistherge t:- the "Isnc'-.ester
C~-T-/. g-r -='11 rontinue to provide etaistar-oe t-o the
H"- t: ev2.lusts that »! ternetive.
r:R. H'JEBNEP: Arv questions of Riih
o resporss. '.'
f' at t'.e hydrogeology :•* ths
-------
9
10
11
15 I
16
IT
IB
19
23
21
-t
22
23
2J
25
1 '
i
site, espe-:ie.llv where tl.r.-:~t -=3' *•''•?• ~ *rs-t !••••-• --.'el's
( .... g. ...'.,..<._-.- .« «.. .-•
5
6
7
6
rck welc in trie
e>-£5 rnc; thsir yiel£, y•:•:.• 're 3-:in; tc see t^l^.•t -- I
u-c-v.le say that. 95 percent c*f the arc-'.inc
come from an o^f-site location and that the -- I'm not
really sv.re what w= hope to accomplish by putting these
-- well sites on lins.
^urthsr. I ror.'t !-:r,ow if-there's &.-.> other
i
13 ' ± = ts t: show that >ou car. ever PUT.- 20C-, 25v gallons a
minute with ths s:< cepticr. c-f locating in the bedrock
e off the site.
So the point I'm trying to make here i=
we're predicting pumping rates of 200, 250 gallons &
minute, and yet the hydrogeolocy of the site and the
extraction wells on the site are very limited as to
where you're going even be able to get that amount of
water.
I just seem to thinl: here we're putting the
cart before the horse in the study. We're making
pr5±i:tirr.E on 'how much we're going to -•'.-.11 out or" the
g-.'O'.incvs.ter before *ny feasibility is done s.= far = =
-------
i '
w*te>- cff site, w1.- - e'$ y•;•••: Dumping it all the way --
why dor/*, .-ou t-est IT c.ff site"1 Why are wa bringing
it 5.1! the w*v bs:i cr the site"
! think a lot of work needs to be done in
the hydro gee logic feres- before we go ahead and move
'° -"->£d with r-.r.y tvps o* pTSC-sel of pumping and treating
11 or. the engineering basis.
12 Tha.ni: ,•:,..-.. r-iSvbe I shc-cld put tr.at in the
form cf s. question. Is -hsre something that will
w Eubstar.tiate thi
"'' Mr. HL'EBr.E?:: Well, let me ask, was the
16 statement -• did he hear what you were saying
17 ::-~r-ct:y, ChetT Dks.y. -h«.t is something that we will
18 address.
19 We're not going to try to respond to it
20 right now. Does anybody else wish to comment?
21 '!No response. !'
22 MR. H'JEBNSRi Dkay. This concludes the
23 public hearing. I thank you for coming. EPA staff
will -eiTisin here *cr 5 few n.inutes..
25 T-" ar/ <-<•? you wish to talk to someoro, I
APEX F.EFDP*ING
-------
5
6
7
E
9
10
11
12
13
14
15
15
17
IE
19
20
21
22
• j
23
24
25"
enc•:•'.'.-e ?=• y•'•>.• t:
~ r i & ri V •, •'• u.
I
".£ cbcve matter WSE c-r-ncluded.)
APEX REPORTING
Reelsts'^eci Prcfe£ = i'-"ial Repc-rters
-------
in tr:e H.atte»- •;•*:
5
A'JS'JRK RDAI' S'JPSRrUND SITE
9
10
11
12
13
14
IS
16
17
18
19
20
21
22
23
24
6
Place: Londonaerry, New Hampshire
Date: April 2S,' '19BS
rrcT:r:E4"!'E QF R£P3P*5F AND TRANSCRIBER
wers held as herein Appear=f and thet this is the true,
accursTe e.nc complete trans:ript prepared -from the notes
anc/or recordings taken, of the above entitled proceeding.
V. Rasmussen 5/2/83
Reporter Date
S. Hayes 5/2/B9
Transcriber- Date
APEX REPORTINS
Registered Professional Reporters
<£ 17'i 425-3077
-------
ATTACHMENT P
RESPONSE TO COMMENT
. 2 . « of SECTION III
-------
II-)*
live •urtwr: m-U
llvei CrouidMter C*tleetten/Vl*Ch*r*«
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tree tor fee (1011
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ilnterlnt AttalnUtrMlen (1111
.tet.l
it'i^wicy (twl)
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HM. AX1HM1IM OOtf
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-------
Table Nuntwr: 1V-2
Alternative Nurtxr: HM-3
Alternative: Ground«ater Collection/Discharge to Sewer
Site Nurtoer: 386
Site Name: Auburn Road
COST'COMBINATION PERMUTATIONS
1
1
(EOUIP/SUPPLIES/INSTALLATION
[SERVICES COSTS
|GRUUND«ATER RECOVER" SYSTEM
|rw O4H tO 5 1 INlcKtSt RATE
1
1
i
1
1
1
2
2
3
3
4
1
1
1
S
1
6
1
7
2
1
1
1
8
2
1
m
1
9
2
•
1
10
3
1
i
11
3
•
1
m
1
12
3
«
13
1
•
i
•
i
14
1
«
1
15 16 17 18 19 20 21 |
1222333)
ESTIMATED COSTS AND PERCENT VARIATION
Item
1. EQUIP/SUPPIIES/INSTALLATION
2. SERVICES COSTS
3. CROUNDUATER RECOVERY SYSTEM
«. PV O&M COST INTEREST RATE
Cost
198,Z«2
178,418
720,000
sx
Max*
2SX
2SX
100X
3X
NinX
25X
2SX
SOX
10X
COMPUTED RANGES
Item
CMt
Max
Min
1. EQUIP/SUPPLIES/INSTALIATION
2. SERVICES COSTS
3. C80UNDWATER RECOVERY SYSTEM
4. PU OSM COST INTEREST RATE
198,242
178,418
720,000
247,802
223.023
1,440,000
148,681
133,814
360,000
4,746,228 6,051,616 2,910,550
STATISTICAL PARAMETERS
{MAXIMUM COST
(MINIMUM COST
(STANDARD DEVIATION
(COEFFICIENT OF VARIANCE
(UPPER LIMIT (SOX)
(LOWER LIMIT (SOX)
9.720,790 |
4.696.255 |
1.756,096 I
0.24 |
8,393,169 |
6,022,440 I
-------
ber: 1V-2
ve Nuter: NN-3
vtt CroundiMter Colleetlon/OUihiirge to
100.000
H.'.M M»I 4£Q ago
7«V:i'« 720*000
1.*-.*.*W 1.656.660
1 .V ,W. 1 165.666
1'-V./, \ 165.666
?V.,W | 248.499
?. ?'.4.i71 1 2.236.491
i 't.V.9 1 223.649
| J.4/.".l«0 | 2.460.140
*,«*.??•« 4,746.228
| r.?%,)41 I 7,206.368
2
247.802
223.023
100.000
460.000
1.440.000
2.470.825
247.082
247.082
370.624
3,335.614
333.561
3,669.175
4.051.616
9,720,790
3
148.681
133.814
100,000
460.000
360.000
1.202.495
120.249
120.249
180.374
1.623.368
162.337
1.785,705
2.910.550
4.696.255
4 5 4 7 8 9 10 11
198.242 198.242 198.242 247.802 247.802 247.802 148,681 148.681
178.418 178.418 223.023 178.418 223.023 223.023 178,418 133,814
100.000 100.000 100.000 100.000 100,000 100.000 100.000 100.000
460,000 460.000 460.000 460.000 460.000 460.000 460.000 460.000
720.000 1.440.000 1.440.000 720.000 720.000 1.440.000 720.000 720.000
1.656.660 2.376.660 2.421.264 1.706,220 1,750,825 2.470.825 1.607.099 1.562.495
165.666 237.666 242.126 170.622 175.082 247.082 160.710 156.249
165.666 237.666 242.126 170.622 175.082 247.082 160.710 156.249
248.499 356,499 363,190 255,933 262.624 370,624 241.065 234.374
2.236.491 3.208.491 3.268.707 2.303.397 2.363,614 3.335.614 2.169.584 2,109.368
223.649 320.849 326.871 230.340 236.361 333.561 216.958 210.937
2.460.140 3.529.340 3.595.578 2.533,757 2.599.975 3.669.175 2.386.543 2.328.305
6.051.616 6.051.616 6.051.616 4.746.228 4.746.228 4,746.228 4.746.228 4.746.228
8.511.755 9.580.955 9.647.1*3 7.279.965 7.344.203 8.415.403 7.132.771 7.066,533
COST ITENS
/SUPPLIES/INSTALLATION
CES COSTS
AilllTY STUDY
HOOKUP
tOUATER RECOVERY SYSTEM
)1AL CAPITAL COST
rector Fee (10X)
1 Feet. Licensing, Pewit • OOt)
neerlnf AdalnUtretlon (15X)
01 AL
INCCNCY
\l CONSTRUCTION COSTS
UN COST i
AL PRESENT UORTN ! j
PUT
..; . .,
l.iV, ".1
I'.S.VA
?:'M;£
| /,'. "0,140
| 4.. 6.Z78
I r.;-*.i68
12
148.681
133.814
100.000
460.000
360.000
1.202.495
1120,249
120.249
180.374
1.623.368
1 162.337
| 1.785.705
4.746.228
| 6.531.933
13
198.242
178.418
100.000
460.000
720.000
1,656.460
165.666
165.666
248.499
2.236.491
223.649
2.460.140
2.910.550
5,370.690
14
198.242
178.418
100.000
460.000
360.000
1.296.660
129.664
129.666
194.499
1.750.491
175.049
1,925.540
2,910.550
4,834,090
15
198.242
133.814
100.000
460.000
360.000
1.252.055
125.206
125.206
187.808
1.690.275
169.027
1,859.302
2.910.558
4,769.852
16
247.802
133.814
100,000
460,000
360,000
1.301,616
130,162
130.162
195.242
1,757,181
175.718
1.932.908
2.910.55*
4.143,44*
17
247.802
223.023
100.000
460.000
360.000
1.390.825
139,082
139.082
208.424
1.877.414
187.741
2.865.375
2,918.550
4,975,925
18
247.802
223.023
100.000
1.440'.000
2.478.825
247.082
247.082
370.624
3.335.414
333.541
3.469.175
2.910,550
4.579.725
1*
148.681
133.814
100.000
460.000
360.000
1.202.495
120.249
120.249
180.374
1.623.368
162.337
1.785,705
6.051,414
7.837,320
20
148.681
133.814
100.000
460.000
1.440.000
2.282.495
228.24*
_ 228.249
342.374
3,081.368
308.137
3.389.505
4.051,414
*,441,120
21
148.681
223.023
100.000
460.000
1,440.000
2.371.704
237.170
237.17*
355.756
3.201.800
320.180
3.521.980
6.051.616
9,573,596
-------
Table Number: IV-2A
Alternative Nuifcer: KM-3A
Alternative: Grounduater Collection/Discharge to Sewer
Site Number: 386
Site Name: Auburn Road
COST(COMBINATION PERMUTATIONS
1
(SERVICES COSTS
|GRQUNDWATtR RECOVERY SYSTEM
Jrw ultM COST INTEREST RATE
1 1 2
If 3
1 «
(• «
1 «
1 2
(4 M
1 2
3
4
«
1
5
•
6
7
1
1
8
1
9
1
10
1
11
1
1
12
1
13
«
•
14
15 16 17 18 19 20
19 9 9 Y X
21
ESTIMATED COSTS AND PERCENT VARIATION
Iten
• * <••
1. EOUIP/SUPPLIES/INSTALLATION
2. SERVICES COSTS
3. CROUNDUATER RECOVERY SYSTEM
4. PW 04M COST INTEREST RATE
CMt
524.215
471,794
900,000
sx
Max X
25X
25X
100X
3X
MinX
25X
25X
SOX
10X
COMPUTED RANGES
Iten
1. EOUIP/SUPPLIES/INSTALLATION
2. SERVICES COSTS -
3. CROUNDWATER RECOVERY SYSTEM
4. PW MM COST INTEREST RATE
Cost
Max
Min
524,215 655,269 393.161
471,794 589.743 353,846
900,000 1,800,000 450,000
12,104,469 15,433,644 7,422,876
STATISTICAL
tti.U5.Tft. |
21 i
2-. ;
(KAXIMUM COST | 21.176,156
(MINIMUM COST | 10,421,101
(STANDARD DEVIATION | 3,817.397
(COEFFICIENT OF VARIANCE | 0.24
(UPPER LIMIT (SOX) | ' 18,489.399
(LOVER LIMIT (SOX) | 13,335.913
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tor: IV-2A
Ive NMber: NN-3A
Ivet firoundMter Collectlen/DIschmi« to
ber: 386
e: AUburn Read.
COMBINATION COSTS
SEMSItlVITT ANALYSIS
Octet 23-Jun-89
15:51
COST ITEMS |
APPLIES/INSTALLATION
S COSTS
WHY STUDY
WOKUP
UATER RECOVERY SYSTEM
AL CAPITAL COST
ctor fee (10X1
Fee*, licensing. Permit • |10X>
•erlnt Attalntitrctlon (15X)
rAL
4GENCV
CONSTRUCTION COSTS
* COST
PRESENT UORTN
1"" |
vuo,mi-i
,•». .'!».«! »9
*')/] «I1
V/A|V»I
|1'., 140. 7|J
1 2 3 4 56 7 0 9 10 11
524,215 655,269 393.161 524,215 524,215 524,215 655.269 655,269 655.269 393,161 393.161
471.794 589.743 353.846 471.794 471.794 589.743 471.794 589,743 589.743 471.794 353.846
100,000 100,000 100,000 100,000 100.000 100.000 100.000 100,000 100.000 100.000 100.000
722.000 722.000 722.000 722.000 722.000 722.000 722.000 722,000 722.000 722.000 722,000
900.000 1.800,000 450.000 900.000 1,000,000 1.000.000 900.000 900.000 1,000.000 900.000 900.000
2.710.009 3.067,011 2.019.007 2.710,009 3.618.009 3.735.958 2.849.063 2,967.011 3.067,011 2.586.955 2.469.007
771.801 386.701 201,901 271.801 361.801 373.596 284,906 296.701 386.701 258.696 246.901
271.801 386,701 201,901 271,801 361.801 373.596 284,906 296,701 386.701 258.696 246.901
407,701 580.052 302.851 407,701 542,701 560,394 427,359 445,052 580.052 368.043 370.351
3,669,312 5,220.465 2,725.659 3,669,312 4,884.312 5,043.543 3,846,235 4.005,465 5.220,465 3,492,390 3,333,159
366.931 522,047 272.566 366.931 488.431 504.354 384.623 400.547 S22.047 349.239 333.316
4,036.244 5.742.512 2.998,225 4.036.2U S.372.7U S.S47.897 4,230.850 4.406.012 5.742.512 3.841.629 3.666.47S
12.104,469 1S.433.6U 7,422.876 15.433.6U 15.433.6U 1S.433.6U 12.104.469 12.104,469 12.104.469 12.104.469 12.104.469
(16.140,713 21.176.156 10.421.101 19.469.887 28.806,387 20.981.541 16,335.327 16.S10.481 17.846.981 15.946.098 15.770.9U
COST I TENS
VSUPfllES/INSULUTICM
ICES COSTS
1ABUITY STUDT
• HOOKUP
MDUATER tECOVERT SYSTEM
»»f;E
V*.»"t
'. . '• . ."-•.
• .:• 'VI
; .-/ru
Wl.Oifl
12
393,161
353,846
100,000
722,000
450.000
OTAl CAPITAL COS1 1 \.-".W> | 2.019.007
raetor Ft* (10X)
il fen. llcemlm. feral ti (10X)
ineerlng AdulnUtratlen (15X>
TOTAL
UNCEMCt
AL CONSTRUCTION COSTS
OM COST
2/1. nu
2/».»««i|
4or,7ni
1.".v.U2
•y..v«
'..rw ?'.4
lt'.l ••..-,•••*
201.901
201.901
302.851
7,725.659
272.566
2.998.22S
17.104.469
'AL PRESENT UORT« ~ |1A.un,/t3 1 1*. 102.694
13 14 IS 16 17 IB 19 20 21
524.215 524.215 524.215 655.269 655.269 655.269 393,161 393.161 393,161
471.794 471,794 353,846 353.846 589,743 589,743 353.846 353.846 589.743
100,000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000
722.000 722.000 722.000 722,000 722.000 722.000 722.000 722.000 722.000
900.000 450.000 450.000 450.000 450.000 1.800.000 450.000 1.800.000 1,800.000
2,718,009 2,268.009 2,150.061 2,281.114 2,517,011 3.867,011 2.019,007 3.369.007 3.604,904
271.801 226,801 215.006 228,111 251.701 386.701 201.901 336.901 560.490
271,001 226.801 215.006 228.111 251.701 386.701 201.901 336.901 3fc0.490
407,701 340.201 322.509 342.1*7 377.552 580.052 302.851 ""505.351 *0.736
3.669.342 3,061.812 2.902.S82 3.079.504 3.397.96S 5.220.465 2.725.659 4.548.159 4.866.620
366.931 306.181 298,258 307.950 339.797 S22.047 272.566 454.816 486.662
4.056.244 3.367.994 3.192.840 3.387.455 3.737,762 5.742.512 2.998.225 5.002.975 5.353.282
7.422.876 7.422.876 7.422.076 7.422.874 7.422.076 7.422.076 1S.433.644 1S.433.6U 1S.433.6U
11.459.119 10.790.069 W.415.714 10.010.331 11.160.630 13.16S.38B 10.431.069 20.436.619 20.706.926
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ATTACHMENT E
RESPONSE TO COMMENT
1 . x- . of ATTACHMENT E
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Tiblt Ninber: 1V-1
Alternative Nunbcr: NM-2
Alternative: Croundwtter CoUectiorv/On-Site Treatment
Site Nurber: 386
Site Name: AiJbum load
COST COMBINATION PERMUTATIONS
1
(M08/DEM08/SITE PREP
(EQUIPMENT AND SUPPLIES
|rW UtH bU»i. INIcKtal RAIt
1 1
1 1
Im
1
»•
1
(•
1
2
2
3
3
1
5
1
6
1
T
2
1
•
i
A
2
1
9
2
-------
wrt IW-1
*t Nurtwr:
vet CroundMttr Collection/'*
en 386
: Auburn Row!
TrmtMftt
COHRtNATION GMT*
SENSITIVITY ANALYSIS
.«•!•: 23-Jun-89
\\m: 15:33
COST ITEMS ' t «SE
IPPLIES/INSTM.UTION '•"•,-•08
; COSTS '•"•,"•07
IIITY STUDY Hirt.WM)
lARORATORV *"*«,«IOO
MER RECOVERY SVfTEN '".HflO
1
416.208
174,587
100,000
A05.000
790,000
2
520.260
468.234
100.000
605.000
1,580.000
3
312.154
280.941
100.000
605.000
395,000
4
416.206
374,587
100,000
605.000
790,000
5
416.206
374,587
100,000
405,000
1.560.000
6
416.206
468,2)4
100,000
405,000
1,560.000
7
520.260
374,587
100.000
405.000
790.000
I
520,246
446,234
100.000
405.000
790,000
9
520,266
468,234
100.000
605.000
1.500.000
10."
312.154
374,587
100,000
405.000
790.000
11
312.154
280.941
100.000
405.000
790,000
L CAPITAL COST
2,*85.796 3,273.495 1,693,097 2.285.796 3.075.79* 1.169.443 2.369.648 2.483.495 3,271.495 2.181.744 2.086.097
tor FM (101)
llccmlni.
(10X)
Administration (15X)
226.580 327,349
226.580 327.349
342.869 491.024
169.310 228.580 307.580 316.944 236.985 248.349 327,349
169.310 228,500 307.580 316,944 238.985 248.349 327,349
253.965 342.669 461.369 475.416 358.477 372.524 491,024
218.174 206.610
218.174 206.810
327.262 313.215
QENCY
).H65.824 4,419.218
306.582 441.922
2.285.661 3.085.624 4,152.324 4.278.747 3.226.294 5.352.716 4,419.218 2.945.354 2.816.931
228.568 308.582 415.232 427.875 322,629 335.272 441,922 294.535 281,893
CONSTRUCTION COSTS
COST
1.J7*.*07 I 1.394,407 4.841.139
V-'ft.MM I 4.878.801 6.220.651
2,514,249 3,394,407 4,567,557 4,706.622 3.548.924 3.687,989 4.661,139 3.239.889 3,100.624
2,991.848 6,220.651 6.220.651 6.220.651 4.878,601 4.876,601 4.676.601 4.878.801 4,878,801
PRESENT WORTH
| *.?-V07 | 6.273.207 11.081.790 5.506,097 9.615.057 10.786.207 16.927.273 8.427.725 •.544.798 9.739.940 6.116.490 7,979.424
COST ITEM
RASI. |
12
13
14
15
14
17
16
19
21
/SUPPLIES/INSTALLATION
CES COSTS
MILITY STUDY
E LABORATORY
OUATER RECOVERY SYSTEM
ITAL CAPITAL COST
••••l.. tH)
it t.CMO
312.154 414.206
280.941 374.587
100.000 100.000
405.000 405,000
395,000 790,000
1.A93.097 2.285.794
414.208
374.587
100,000
405.000
395.000
1,690,794
416.208 520.260 526.260 520.260 312.154 312.154 312.154
280.941 280.941 466.234 468.234 280.941 280.941 466.234
100.000 100.000 100,000 100.000 100.000 100.000 100.000
405.000 405.000 405.000 405.000 405.000 405.000 405.000
395.000 395,006 395.000 1.580.000 395.000 1,580.000 1.580.000
1.797.149 1.901.201 2.086.495 3.273.495 1.493,697 2.878,097 3.065,390
rector Fee C10X)
l Fee*. Ltccnslno. Ptmlts C10X)
Administration (15X) )
169.310 228.580 189.080 179.715 190,120 208.649 327.349 149.316 267.810 306.539
169.310 228.580 169.080 179.715 190.120 206.849 327.349 169.316 287.810 306.539
I 253.965 342.849 263.619 269,572 265.160 313.274 491.024 253.965 431.715 459..809
OTAL
IN6EMCV
1.or .P?l I 2,285.461 S.085.624 2.552.574 2.424.151 2.544.421 2.819.448 4.419.218 2.265.481 3.885.O1 4.1^.277
228.548 308.562 255.257 242.615 254.442 281.947 441.922 228.546 386.543 413.626
L CONSTRUCTION COST*
UN COST
| I.1-H.M7 I 7.514.249 3.394.407 2.807.832 2.646.744 2.623.263 3.101.414 4.661.139 2.514.249 4.273.974 4.552.105
| | 4.P/H.-M | 4.878.801 2.991.646 2.991.646 2.991.646 2.991.646 2.991.646 2.991.848 4.220.451 4.220.451 4.220.451
\L PRESENT WORTN
| «.7n..-'«; J r. TO,0*9 4.364.255 5.799.666 5.440.414' 5.615.131 6.693.242 7.852.987 •.734.699 16.494.424 16.772.755
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ARPENDIX B
STATE CONCURRENCE LETTER
-------
ROBERT W.VARNEY
COMMISSIONER
State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
OFFICE of the COMMISSIONER
6 Hazen Drive. P.O. Box 95, Concord, NH 03302-0095
603-271-3503
FAX 603-271-2867
GEORGE A. MOLUNEAUX. P.E.
ASSISTANT COMMISSIONER
September 26. 1989
Mr. Paul Keouqh
Acting Regional Administrator
USEPA. Region I
JFK Federal Building
Boston*, MA 02203
Re: State of New Hampshire Concurrence Letter
Record of Decision (ROD) (September 1989)
Auburn Road Landfill Site
Londonderry. NH
Dear Mr. Keouqh:
The New Hampshire Department of Environmental Services has reviewed the
above referenced Record of Decision (ROD) and 1s 1n agreement with the
recommendations therein. The ROD 1s also consistent with the rules and
Regulations of Applicable or Relevant and Appropriate State Requirements
(ARARs). Furthermore. 1f the pro.lect utilizes the trust fund, the State will
provide a 50 percent match (public site) and operational support for the
pro.lect 1f state funds are available.
Sincerely,
Rob-ejt W. Varney.
Co/wnss loner
RWV/MMP/.1d/,08490
cc: Michael A. S11U. Ph.D.. P.E.. DES-WMD
Carl W. Baxter. P.E.. DES-WMEB
Geoffrey M. Huntinqton, NHAGO
Chester Janowski. USEPA-Reqion I
William Walsh - Rogalskl. Esq.. USPEA-Reqion 1
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ARRENDIX C
ADMINISTRATIVE RECORD INDEX
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