UNITED STATES WASTE MANAGEMENT DIVISION
ENVIRONMENTAL PROTECTION J.F. KENNEDY FEDERAL BUILDING
AGENCY REGION I BOSTON, MA 02203
3EBV
WASTE
MANAGEMENT
DIVISION
1986
ANNUAL
REORT
FEBRUARY 1987
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Designed and written by Pam Cooper,
EPA Headquarters, Office of Management
Systems and Evaluation, with the
assistance of Region I Waste
Managment Division staff and managers
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To Our Readers:
If I had to characterize 1986 in one word, I would use the
word, change. There were several changes in the Waste Management
Division and in the laws we implement.
One major change was the reorganization of the Division.
Although the reorganization was effective in February, staff and
management had to deal with transitions throughout the year.
I am pleased that we did so, while still managing to keep the
programs going at an admirable pace.
The second change was, and continues to be, in our hazardous
waste regulatory program under RCRA. That program is in a transi-
tion from its older responsibilities to implementation of the 1984
amendments.
One additional change was necessary because we began the
fiscal year without the benefit of the reauthorization of Superfund.
Without Superfund legislation, funding was sporadic. The program
had to go from one focusing on as many Superfund sites as possible,
to one which could only try to maintain ongoing site activities.
The year closed with yet another change: implementation of
the Superfund Amendments and Reauthorization Act (SARA). We now
have a new bill, a new mandate from Congress, and nine billion
dollars to help us clean up Superfund sites.
This report presents where we’ve been in 1986. We’ve described
the waste management picture in New England, highlighted some of our
specific accomplishments, and explained how we see the challenges
for 1987.
We have made progress in the past year and the staff of the
Waste Management Division can be proud of all they have accomplished.
On behalf of the staff, however, I want to thank all those who have
helped us, including our State partners and the public. Special
thanks also are due the other programs and offices in EPA Region I
for their advice and cooperation in helping us make better deci-
sions, Finally, I want to thank our Regional Administrator and
Deputy, Mike and Paul, for their help and support during the year.
Merrill S. Hohman, Director
Waste Management Division
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Table of Contents
Driving Forces .............. .................•....... 1
EPA’S Waste Management Division
Growth of the Division . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Division Reorganization . . . . . . . . . . ..... .. .. . . . . . . . . 8
Overview of the Superfund Program
Site Investigation ....... ......................... 12
WhyDoes It Take So Long .......................... 13
Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Cannon’sEngineeringCase ......................... 15
Superfund Slowdown ...... ..... ..... ... ... ......... • 16
Overview of the RCRA Program
“Cradle to Grave” Management Process .............. 20
Permits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
HWSADeadlinesforPermitting ..................... 22
FacllityManagementPlann].ng ...................... 23
Enforcement ....................................... 24
Special Project Grants ............................ 25
Underground Storage Tank Program .................. 26
State Accomplishments
Maine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Vermont . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Connecticut . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Massachusetts ..................................... 40
New Hampshire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Rhode Island ••••••••••• •....... .... •1S•SSSS ••, •5s 48
Challenges for 1987
..............s.s........s..e.....
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Driving Forces
To understand the hazardous waste mandate assigned to EPA by
Congress and the accomplishments of the Waste Mangement Division
in Region I, we must first review the unique demographic and
economic characteristics of New England. A quick look at these
“driving forces” will help in understanding the challenges faced
by EPA’s Region I office.
New England is marked by contrasts. The southern States,
Rhode Island,’Connectjcut and Maséachusetts are among the most
urbanized in the country. The northern States of Vermont,
New Hampshire and Maine retain à largely rural character and
have relatively low population densities (populations range from
535,000 in Vermont to just over 1 million in Maine). However,
the northern States are growing quickly.
Figure 1 shows high growth rates (from 9% to 20%) over the
past 10 years in New Hampshire, Vermont and Maine. In contrast,
the southern States of the region were growing at close to 3%,
although the previous 15 years showed higher growth in these
States. This continuing growth in the northern states’ population
will lead to increasing stresses on the environment (e.g., more
people dependent on groundwater and disposing of their wastes),
whereas the population in the southern states has already produced
major stresses.
Figure 1
POPULA11ON GROWTH IN NEW ENGLAND STATES
1960 — 1985
SlATE
OIL II fl IT $ or DATA N,,Urwfl IS
T L SL O D I S N?I COLV $0 0US$. 1 105 P11 It
0$E O L0 $0101001 101 . WOT C I VUICT COSV*J0000 5.
L L
— ‘975—1915
Source; Census 01ureau, Bost Re. ona1 Office
1
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In addition to the changes posed by population shifts’, New
England is the nation’s oldest urbanized and industrialized region,
and, as such, often has environmental problems quite different
from other parts of the country. For example, the region lost its
original industrial base ‘to foreign competition during the early
and middle part of the century’.’ In an effort to écover these
losses, New England shifted to high—tech and service.industrles
faster than other rég ions.
Figure 2 shows that service—related industries now account
for almost one—quarter of the employment in the regiPn, with
another quarter ‘in’ manufacturing. Figure 3 further breaks out
the manufacturing industries and shows that electrical ‘machinery
and instrument irianufa’cturing employment make up 24% of ‘the total
manufacturing employment in New England. However, there area other
large employers that will’ also affect waste management in the
region.’ Paper and printing make up about 11% of the manufacturing
workforce, and chemicals,’plastiCS and rubber manufacturing make
up another 83.
Figure 2
Scurce areau of t.sbr Statistics, L’c,ztcn Off i -
The success.of -this shift in industry type is evidenced by
the fact that the overall economic picture for New England is
considered steady by economists. In 1985, the region’s unemploy—
NONAGRICUL11JRAL. EMPLOYMENT FOR 1985
NEW ENGLAND
— !RM4 . W I-
i 4.2%
nNAMc
2
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ment rate was 4.3% compared to the U.S. unemployment figure of
7.0%. In addition, all New England States experienced increases
in total employment over the year.
Figure 3
Source: &ireau of Labor Statistics, Boston Office
New England’s growth and shift to service in industry has not,
however, reduced the generation of hazardous waste. New England
industries reported generating 441,000, tons of hazardous waste in
1985. This amount is 30% higher than that reported in 1983.
Figure 4 shows the percent of hazardous waste each State in the
New England region generated in 1985. Industries in Connecticut
and Massachusetts alone generated 87.4% of the hazardous waste in
the region; this is slightly lower than the share they generated
in 1983 (89.9%).
Although New England States most often ship their hazardous
waste out”of the region (see, Figure 5), this does not make our
jqb easier. Westili,rnust educate and regulate a variety of
businesses ‘and industries in the Region, and encourage alternatives
‘to generation and treatment of hazardous waste (for example,
recyclin or reuse).
UST UB8D -
NEW ENGLAND MANUFACTURING EMPLOYMENT
1985 AVERAGES
—. 9.9%
u a_
FIJRP&/W000 ODUCTS ____
V
3
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Figure 4
NEW ENGLAND MANUFACTURING EMPLOYMENT
1985 AVERAGES
rflLhs T L — . M*tL
n$Nj OaD OO%CS
MIV rr rosc _/‘
S jrce: reeu of La r Stat,tetiCS, ostce Office
Figure 5
STATES RECDVNG NEW ENGLAND’S
HAZARDOUS WASTE 1983 AND 1985
I
bte: Prc1iz .z y ta n 1985
Scurce: 1983 4 1985 Bi m a1 I p0rt5
4
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Nor is the Region free from the effects of past hazardous
waste generation. New England has 58 sites proposed or listed
on the National Priorities List; all are in some phase of the
Superfund process. As shown in Table 6, many environmental media
are affected by Superfund sites. For example, 91% of our NPL
sites affect groundwater supplies, and 79% affect wetlands.
Through integration of our programs at EPA, we are addressing
these various media problems.
NEW ENGLAND’S SUPERFUND SITES
Table 6 Enviromtental Resource Number of Sites
Affected Affecting Resource
Groundwater - with the
potential for drinking 53
water contamination
Wetlards 46
Surface Water 39
* 46 of New England’s 58 Superfund sites
are in residential areas.
Source: Carl Deloi, Waste Manag nent Division
Figure 7 shows the number of drinking water wells affected
by both Superfund sites and leaking underground storage tanks.
Although these contaminated wells take a long time to clean up,
pump and treat systems (described in more detail in the New
Hampshire and Connecticut State sections), as well as other State
and EPA actions are proving successful at lowering the levels of
contamination.
Weter Supplies Affected By Superfund Sites
Table 7
or Leaking Underground Storage Tanks
Source of Ca muinity Water Private Water Supplies Out—of—Service
Contamination Supplies Affected Supplies Affected and Now in—Service
Superfund 20 112 4
Sites
Underground
Storage 13 410 4
Tanks
Note: 21 non—ccmununity supplies affected by Superfund sites or
leaking underground storage tanks are not included in totals above.
Source: Dave Chin, Water Supply Branch, Region I Water Division
Throughout this report, we have focused on Congressionally
mandated hazardous waste goals and our accomplishments toward
meeting those goals. In New England, we need to improve current
hazardous waste management, remedy the problems created by past
practices, and encourage the reduction of hazardous waste generated
in the future. If we succeed in doing so, we will indeed move
toward the goals of the waste management programs of EPA.
5
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Region I ’s Waste Management Division
Growth of the Division
The Waste Management Division in Region I has grown substan-
tially with the expansion of Federal waste management authorities:
the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund); and the Resource Conservation
and Recovery Act (RCRA - includes the Underground Storage Tank
program).
The passage of RCRA in 1976 brought six employees into the
Regional office to work on implementation of RCRA. This number
had grown to 17 by 1980 when CERCLA passed in December of that
year.
In 1982, the Region reorganized by dividing the Air and
Hazardous Waste Division and disbanding a separate Enforcement
Division. The new Waste Management Division. was created with
overall responsibility for both RCRA and CERCLA.
The Division has continued to grow to keep up with expanded
responsibilities. Figure 8 shows the Division has increased by
72% in the last four years, with the Superfund program doubling
in size. Contractor assistance also provides substantial support
to staff in both programs.
Figure 8
GROWTH IN PERSONNEL
IN THE WASTE MANAGEMENT DMSION
OTL Mia * IfS QA NUWfS$ wury
fSt f CAL
Source: Mary Grelish. Maste Mana ent Division
1985
FiSCAL YEAR
Leger d
— NCM
7
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Reorganization of the Division
During 1986, Region I ’s Waste Management Division completed
a major reorganization, designed to address the expansion in
staff and to focus on four specific goals of Division. management:
1) to address waste management issues within each State as a
whole, rather than as two distinct programs;
2) to focus on the unique nature of each State, and maintain
a balance among States;
3) to encourage staff to use the statute which best addresses
the problem (some sites may be both RCRA facilities and
Superfund sites); and
4) to manage activities at sites/facilities from an integrated
perspective; site managers and permit writers are no longer
separated from enforcement.
Chart 9 shows the current organizational structure. The
Division Is now organized in a unique geography—based structure.
.Each of the three Branches has responsibilities for RCRA CERCLA
and Enforcement. The primary distinctions among the Branches are
the state and program—lead responsibilities (i.e., RCRA, $upe.rfund,
Enforcement). We will continue to monitor the success of this
structure over the next few years and make changes as necessary.
(Superfund reauthorization will again lead to future changes in
the organizational structure to accommodate growth in that
program).
The New England Waste Management Organization Assoc. (NEWMOA )
With funding and staff support from the Waste Management
Division, NEWMOA was established as an association to provide in-
put to EPA on policy and regulatory decisions from the New England
States. Throughout the year, NEWMOA hosts State/EPA technical and
management meetings. These meetings bring together staff and
management from the two regulatory levels to exchange ideas and
information about environmental regulations and technical issues.
8
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Chart 9
WASTE MANAG 1ENT DIVISION
DIRECTOR: Marrill S. Hohman
DEP(IFY DIRECTOR: Patricia I.
Meaney
cr
Superfund
Section
Chf: Heather
Ford
Cr
Waste Regulation
Section
Chf:
John Hackler
ME
Superfund
Section
Chf: David Webster
ME
Waste Regulation
Section
Chf: Gerard Soto].ongo
MASS
Superfund
Sect ion
Chf: Richard Cavagnero
MASS
Waste Regulation
Sect ion
Chf: Gary Gosbee
IFIT*
VT, RI and NH
WASTE MANAGEMENT
BRANCH
(Superfund Lead)
Chf: Dennis Huebner
I I I
Cr and ME
WASTE MANAGEMENT
BRANCH
(Enforcement Lead)
Chf: Ira Leighton
MASS
WASTE ANAGE 4ENT
BRANCH
(RCRA Lead)
Chf: Linda Murphy
VT and RI
Superfund
Section
Chf: Richard Boynton
VT, RI and NH
Waste Regulation
Section
Chf: Mary Jane O’I)oi
nell
NH
Superfund
Section
Chf:
Daniel Cot hlin
Superfund
Support
Section
Chf:
Carl DeLoi
Waste
Regulation
Support Section
Chf: Cindy Gilder
*FIp = Field Investigation Team; contractor provided staff to carry out preliminary investigations
under CERCLA.
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WASTE MANAGEMENT DIVISION
DIRECrOR: Merrill S. Hohman
DEPWY DIRECTOR: Patricia L.
Meaney
I I I
er
Superfund
Sect ion
Chf: Heather
Ford
Chf:
ME
Superfund
Sect ion
David Webster
ME
Waste Regulation
Sect ion
Chf: Gerard Sotolongo
*FIT = Field Investigation Team; contractor provided staff to carry out preliminary investigations
under CERCLA.
Chart 9
I FIT ——
vr, RI and NH
WASTE MANAGEMENT
BRANCH
(Superfund Lead)
Chf: Dennis Huebner
cr and ME
WASTE MANAGEMENT
BRANCH
(Enforcement Lead)
Chf: Ira Leighton
MASS
WASTE MANAGEMENT
BRANCH
(RCRA Lead)
Chf: Linda Murphy
VT and RI
Superfund
Section
Chf: Richard Boynton
VT, RI and NH
Waste Regulation
Section
Chf: Mary Jane O’Dori
NH
Superfund
Section
Chf: Daniel Couqhlin
Superfund
Support
Section
Chf: Carl Deloi
LflCl 1
MASS
Superfund
Section
Chf: Richard Cavagnero
MASS
Waste Regulation
Section
Chf: Gary Gosbee
cr
Waste Regulation
Sect ion
Chf: John Hackler
Waste
1 gulation
Support Section
Chf: Cindy Gilder
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The Superfund Program in Region I
“‘remedial action’ means those actions taken...
in the event of a release or threatened release
of a hazardous substance into the environment,
to prevent or minimize the release of hazardous
substances so that they do not migrate to cause
substantial danger to present or future public
health or welfare or the environment.”
CERCLA, Section 101(c)
E2
q p
NFL RANKING/
LISTING
58 NFL Sites
3)
REMEDIAL
INVESTIGATION
I
4)
FEASIBILITY
STUDY
RI/PS at 38 Sites
Jr
5)
RECORD OF
DECISION
19 RODs Completed
‘
6)
CLEANUP PLAN/DESIGN
14 Plans/Designs
“p
LONG—TERM
CLEANUP
6 Cleanups Started
In passing CERCLA, or
Superfund, Congress charged
EPA with overseeing the
clean up of uncontrolled
hazardous waste sites to
protect human health and
the environment. The
following section describes
EPA’S program to meet its
charge and Region I’ S accom-
plishments in the program.
Figure 10 shows the steps
described below, and the
number of New England sites
in each stage of the Super—
fund process as of December,
1986.
THE SUPERFUND PROCESS
SITE
DISCOVERY
1381 Sites Discovered
“p
1)
INVESTIGATION
1160 Preliminary Assessments
289 Site Inspections
I
FIGURE 10
I
I
H
z
N
N
Source: Carl Delol, Waste Management Division
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Site Investigation
After a site is discovered, it is investigated, usually by the
State using funds provided by EPA (Step 1). In New England, we
have discovered 1381 sites. Investigation of a site involves two
steps, a preliminary assessment anda site inspection. The States
or EPA have conducted preliminary assessments at 84% of these sites,
and site inspections at 21% of the sites.
If the preliminary assessment and site inve tigation indicates
further action is warranted, the State or EPA then evaluates the
site numerically (Step 2) using the Hazard Ranking System that takes
into account:
O Possible health risks to the human population;
o Potential hazards (e.g., from direct contact, inhalatthñ,
fire and/or explosion) of substances at the site; -
O Potential for the substances at the site to contaminate
drinking water supplies;
o Potential for the substances at the site to pollute/harm
the environrnpnt;
The product of this ranking is the Hazard Ranking System Score:.
If this score indicates the site’s problems are serious, it will
be listed on the National Priorities List (NPL). Region Ihas 58
sites on the NPL (6.5% of the national total of Final and Proposed
NPL sites).
Listing on the NPL means the site is eligible for Federal
Superfund money and enables. EPA to continue the Superfund process
outlined in Figure 10.
Studies of Contamination
Next, EPA (or the State under an agreement with EPA) usually
conducts a remedial investigation (Step 3). The remedial investi-
gation (RI) assesses the extent of contamination, defines the con-
taminants that are present; and characterizes potential risks to
the community. Then EPA directs or conducts a feasibility study
(FS) which examines the feasibility of various cleanup alternatives
(Step 4). This entire process is known as the RI/PS. Region I
has started an RI/PS at 66% of the NPL sites in the region.
One strategy EPA has adopted for complex sites is known as
addressing a site through “operable units.” When we know that
cleanup of the entire site will take a long time, the “operable
unit” concept allows us, for example, to control the source of
contamination, first and then to address a groundwater problem at
a later date. We have started an RI/Ps for 44 operable units
at 38 NPL’ sites.
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Selecting the Remedy
After the RI/FS is completed, the EPA issues a Record of
Decision (ROD — Step 5) summarizing the alternatives evaluated
during the feasibility study and documenting EPA’S chosen cleanup
alternative. This document is issued to ensure the decision
process and the cleanup or remedial action are consistent with
CERCLA and other environmental statutes. Region I completed five
RODs in 1986.
Once the Record of Decision is issued, a specific cleanup
design (Step 6) is done and work is contracted (by public bidding)
to do the cleanup. Region I has started 14 of these final designs,
some at operable units, and has started remedial work at six sites.
Why Does It Take So Long
The time it takes to complete each of these steps varies
with every site.
The need for adequate data on which to make major cleanup
decisions means that the analysis of samples from the RI/FS in-
volves strict, and often time—consuming, quality control and
quality assurance checks. Region I has developed a management
system with laboratories under the Contract Lab Program to achieve
faster turnaround from these labs.
Although good management of the Contract Lab Program allows
us to identify and correct problems in laboratory work, the RI/FS
process is a multi—disciplinary venture requiring review and con-
sultation with a number of specialists. Hydrogeologists, public
health officials, chemists, engineers, economists, regulatory
officials, lawyers, and wetland biologists are often involved.
Further, these specialists are from a number of interested parties
including various EPA offices in Region I and nationwide, State
governments, local governments, the Corps of Engineers, the Fish
and Wildlife Service, and potentially responsible parties, in
addition to the public. While EPA’s job of coordinating the
efforts of these participants is essential to a balanced, quality
study, the coordination of the planning and review of the various
portions of the RI/FS is a time—consuming task. The RI/FS process
previously described often takes 2 to 3 years to complete.
Finally, preparing the engineering design for the selected
remedy may take 6 months to a year, and implementing the remedy —
the actual containment or removal of the waste — may take up
to 3 years. If groundwater contamination is involved the final
cleanup may take many more years.
Even after the initial construction has been completed at a
site, long—term operation and maintenance may be required until the
environment is “cleaned up.” For example, a system constructed to
pump and treat groundwater may need to operate for five years or
more before contaminants are removed. In this case, final cleanup
won’t be declared by EPA for many years.
13
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There are also several ongoing activities taking place during
the process described previously.
o Emer ericy Removal Actions . Periodic monitoring of site
conditions will indicate if a site becomes an imminent
threat to public health or the environment during the
normal course of an RI/FS. If this happens, work on the
RI/FS is halted and EPA may conduct an emergency cleanup.
Emergency removals may involve digging up and removing
leaking drums, fencing a site to prevent children from
entering the area, or supplying bottled water to residents
whose drinking water supplies are contaminated. In Region I,
this work is carried out by the Environmental Services
Division.
o Community Relations . During the course of the Superfund
process at a site, the EPA usually conducts two public
meetings. The first is an informal meeting to outline the
conclusions of the studies at a site and to answer questions
from local citizens and other members of the public. The
second is a public hearing to officially receive written
and oral comments from the public. Since EPAtS goal is to
select a remedy which adequately protects human health and
the environment, hearing citizen’s opinions regarding
proposed remedies Is a fundamental part of the process.
Following the public hearing, EPA bases its selection of a
remedy largely on the RI/FS and public comments received.
o Enforcement . Once a site is defined as an NPL site, EPA
undertakes a thorough investigation to identify parties who
may be responsible for the waste contamination problem.
This search for potentially responsible parties (PRPs) can
and often does continue throughout the RI/FS process.
Enforcement in the Superfund Program
The backbone of Superfund enforcement is the legal authorities
which empower EPA to compel those reponsible for pollution problems
to either clean up the problem or pay for the cleanup after the
fact. In order to conserve State and/or Federal Superfund dollars,
the Superfund enforcement program strives to persuade potentially
responsible parties (PRPs) to clean up Superfund sites wherever
these parties can provide adequate, effective, and timely action.
Where Federal Superfund dollars are spent, EPA seeks to recover
the costs of EPA cleanup activities.
Although EPA is willing to negotiate with private parties to
encourage their undertaking the cleanup, we have the authority to
legally force those responsible to take specified cleanup actions
or recover government costs expended in cleanup. CERCLA also con-
tains a very strong tool known as “joint and several liability”
which empowers EPA to designate one entity (or company) as a PRP
and therefore liable for the cleanup. The following example
shows the effort required in identifying PRPs.
14
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Cannon’s J!nforcement Case
The Cannon’s Engineering Cornoration enforcement case Involves
four sites and airnroximatelv F(V) PRPs. The tour sites, located
in two states are: Cannon Engineering cornoration in both Rridqe—
water, and Plymouth Harbor, Massachusetts; and Tinkham’s ( araqe
and Sylvester’s in Mew Hamnshire. In 19R6, letters were sent to
all. PP1) 5 notifying them of their status as notentlally resnonsihie
for contamination at the sites. The first meeting with the 6 fl
PRPs was belA in May, l.qR6, EPA had to discuss findinris, intent,
and suggest a manner of dealing with this large grcxir, of PRP5,
In addition to the large number of PRPs involved In this case,
Region I is considering EPA’s first “de minimus settlement” in the
nation. This means we will settle with the small contributors and
absolve them of liability or an anpronriate share of the investi-
gation and remerly ccict. This will leave us free to work with the
large contributors at the site.
The number of PRPs involved in the Cannon’s case forced
Region I staff to develon new annroaches to PRP searches. We n
have canorehensive management olans for those sites with large
enforcement cases and u e caiinuters to facilitate the search and
manage the seemingly unmanageable thousands of nages of information
Fran the connanies involved.
PRP Team
To assist with these large and complex cases, our 1986 reorg-
anization included the establishment of a special team to focus
on searching for, identifying and notifying PRPs. Because PRP
searches are the foundation for any enforcement action in Superfund,
and are often very complex, team members help site managers plan
PRP search efforts. In some high priority or complex cases with
numerous PRP5, the Responsible Party Team may take the lead in
managing government contractors who conduct the search for PRPs.
The Team was established as a focal point for PRP work under-
taken at all NPL sites and is developing a Regional approach for
doing PRP work which ensures consistency in the PRP identification
and notification process at all Region I Superfund sites. Present
policy dictates that we identify PRPs as early in the process as
possible, and the establishment of this team will assist us in
meeting the goals of this policy.
Costs of Cleanup
The complex and detailed studies to determine how best to
clean up each Superfund site and the actual cost of the remedies
selected are expensive.
Table 11 shows the dollars spent in each State in New England
to address Superfund sites (both remedial and removal actions) and
the percent of monies spent in relation to the number of Superfund
sites in the State. Massachusetts has the largest number of
Superfund sites and 45% of the monies spent have been spent on
Superfund sites in Massachusetts.
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TABLE 11
Superfund Expenditures on NPL Sites
in New Er 1and States
N xnber of• Percent of ‘Ibtal Fund
State NPL Sites ! .tnies Spent tbllars Spent
Massachusetts 21 45 % $ 33,627,400
New Hampshire 13 33 24,955,300
Rhode Island 8 11 8,498,200
Maine 7 6 4,883,100
Connecticut 6 2 1,748,000
Vernont 2 2 1,489,900
* June 1986 Figures.
Source: Th th Leabi an, Waste Manag nent Division
Superfund Slowdown
In the 1980 CERCLA, Congress authorized a $1.6 billion,
5—year program for cleanup of Superfund sites. Figure 12 shows
the amount Region I used from fiscal year 1983 to fiscal year
1986. These funds are used for:
1) Program contractors, who do much of the Superfund work such
as sampling and construction for selected remedies;
2) Inter—Agency Agreements, which allow EPA to use other
Federal agencies such as the Corps of Engineers or the U.S.
Geological Survey for work at Superfund sites; and
3) Cooperative Agreements with the States, which allow EPA to
provide funds to the States on a site—by—site or multi—site
basis to assist us in addressing Superfund sites.
The Act, and funding, expired in December 1985 (early fiscal
year 1986). Examination of Figure 12 shows that Fiscal Year
1986 was a very different funding year for Superfund. Until
then, we received an “allowance” twice a year. We knew how much
(in dollars) we would be receiving at six—month intervals. This
allowed us to plan for use of funds at different sites. We could
move funds around to address particular site problems, if needed.
During Fiscal Year 1986, while awaiting passage of a new
Superfund law, we were able to use “carry—over” funds for the
first part of the year. We received money several times during
the year thrQugh interim measures from Congress, and although
these funds kept the program going, we could not do any planning.
No new remedial designs or remedial actions were started in 1986.
16
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Funds went only to those sites that already had studies or actions
underway. These funds also had strings attached;, the funds often
had to be obligated or spent by the end of the month they were
allocated.
Figure 12
Essentially, the available funds were used to continue
ongoing projects. Contractors were forced to slow down work at
sites because they were unsure of continued funding. Receiving
funds from Congress in this manner also created more paperwork
for the Regional office and more meetings with contractors and
site managers to coordinate activites.
At any Superfund site, the State is required by law to match
EPA’ expenditures by 10% or 50%. In Fiscal Year 1986, we asked
States to provide an “advance match t1 . Massachusetts was able to
provide their match at the front end of the process, which
allowed work to continue while Congress debated the amendments to
Superfund.
In October, 1986 Congress passed and the President signed,
the Superfund Amendments and Reauthorization Act of 1986 (SARA).
SARA established an $8.5 billion, 5—year Superfund program
extension. At the end of 1986, Region I was awaiting receipt of
new funds to begin to move our sites through the process once
again.
SUP 1JND EXPENDI11JRES IN 0N I
1983 — 1986
DII .
110
L
1903
1904 1985
FiSCAl. AR
SOurcE: Colnptreiier’a Office. !egien I EPA
17
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The RCRA Program in Region I
The Resource Conservation & Recovery Act (RCRA), passed by
Congress in 1976 and amended in 1984, was designed to improve the
way industry handles hazardous wastes. Specifically, the goals
set by RCRA are:
o Protect human health and the environment
o Reduce waste and conserve energy and natural resources
o Reduce or eliminate the generation of hazardous waste as
expeditously as possible
To achieve these goals, RCRA established a “cradle to grave”
management system for the safe handling of hazardous wastes. The
Act also established a permit system for hazardous waste treatment,
storage and disposal facilities (TSDFs), authorized State programs
to operate in lieu of Federal programs and provided strong enforcement
authorities to EPA.
In 1984, RCRA was amended
by the Hazardous and
Solid Waste Amendments
(HSWA). These amend-
ments established time
tables for issuance of
RCRA permits, required
that permits also address
any release to the environ-
ment (corrective action),
established a special
permitting process to
encourage alternative
treatment technology and
required EPA to begin a
process of barring certain
untreated wastes from land
disposal. The amendments
also established a Federal
program to address the
growing problem of leaking
underground storage tanks.
Snure : EPA RCRA Orientation
M iuuuj1
19
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The “Cradle to Grave” Management Process
The RCRA process starts with generators of hazardous wastes
(See Figure 13, number 1). It is the generator’s responsibility-
to determine whether their wastes meet RCRA’s definition of a
hazardous waste (ignitable, corrosive, reactive, toxic). More
than 450 chemicals and other wastes are automatically considered
hazardous. Generators are regulated when they produce more than
2,200 pounds (1,000 kg) of wastes each month. Certain highly
toxic compounds, such as arsenic and some discarded pesticides
are regulated in small quantities (2.2 pounds or 1 kg). Generators
of between 100 Kg and 1000 Kg of hazardous waste in a calendar
month are also under the purview of the law. The Waste Management
Division and New England States are responsible for regulating
8210 hazardou,s waste generators.*
RCRA allows generators to store their own wastes onsite
for up to 90 days without a permit. Some facilities that store
hazardous waste have chosen to limit the amount of time they
store the wastes in order to avoid being considered a management
facility.
When wastes are to be shipped off—site, the generator prepares
a “manifest” (number 2) which describes the wastes and identifies
the transporter and the facility to which the wastes will be
shipped. Wastes from large generators (as opposed to small
quantity generators) may only be sent to facilities with RCRA
permits or operating under interim status. Permits are issued by
States authorized by EPA, or by EPA.
Transporters (number 3) of hazardous wastes are required to
carry the manifest prepared by the generator and must follow all
applicable Department of Transportation safety regulations,.
Treatment, storage and disposal facilities (TSDFs) receive
the waste from transporters (number 4) and are required to return
the manifest to the generator (number 5), thus completing the
“cradle to grave” hazardous waste management system. All TSDFs
are required to have RCRA permits, as described later in this
report. As of December, 1986, these were 506 TSDFs in Region I.
State Authorization
As with many environmental laws, RCRA provides for the States
to take over the -program. In order to be authorized to run the RCRA
program, States must demonstrate that their laws and regulations are
at least equivalent to, and consistent with, Federal regulations.
States must continually update their programs to keep them consistent
with Federal requirements. Vermont, New Hampshire and Massachusetts
received RCRA authorization prior to 1986. During 1986, Rhode Island
was granted authorization. In Maine and Connecticut, EPA and the
States are working closely to develop State programs adequate to
receive authorization. Decisions are expected in early 1987 for
these two states.
20
* Preliminary numbers from the
1985 State biennial reports.
-------
RCRA Grants to States
Because the RCRA program is carried out largely by the States,
EPA issues grants to the States to help implement RCRA. Figure 14
shows the amount of RCRA grant monies EPA has issued to the States
since fiscal year 1980. The grants include funds for permitting,
inspections and enforcement. EPA reviews State progress regularly
to ensure that the State programs meet the goals negotiated in the
grant documents. The State is also required to add 25% to the
grant as a “State match.”
Figure 14
RC A FEDERAL BASE GRANTS: 1980 — 1987
1300 -
000
,ooo
s0o —
Legend
ffl .i
1001 PtM.
ss.
F 4
0 M• El C0*tC11CUT
1980 1981 l 82 1983 984 185 1986 1987
ASCAL TEAR
l te: Iries ont inc1 State
atd or b ruses
S jrce: Ken ehaberg. l st.e anag Tent Division
RCRA Permits
As noted earlier, all treatment, storage and disposal facilities
are required to have permits issued by EPA or an authorized State.
However, Congress recognized that all facilities could not be per-
mitted immediately and so established a procedure whereby facilities
in operation prior to November of 1980 would receive interim status
and; be allowed to operate pending issuance of the actual RCRA permit.
Under interim status, facilities must comply with general operating
conditions established by EPA regulations.
• Facilities granted interim status under RCRA were tO continue
to operate in that mode until EPA or an authorized State called in
their permit application (so—called “Part B”) and issued or denied
the. permit. •
21
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Treatment, storage and disposal facilities must develop con-
tingency plans to protect health and the environment, and prepare
closure and post—closure plans if they intend to cease operations.
A financial requirement was established to assure that funds are
available to pay for closing a facility and to compensate for
post—closure care at disposal facilities. In addition, the owner
or operator of a facility must obtain liability coverage to com-
pensate individuals for bodily injury and property damage caused
by accidents related to the facility’s operation.
In addition, land disposal facilities (landfills, waste piles
and surface impoundments) are required to install groundwater moni-
toring wells to detect any leakage from the site and to take measures
to control such leakage if it is detected.
Loss of Interim Status
Under the 1984 Hazardous and Solid Waste Amendments (HSWA),
interim status land disposal facilities were subjected to addi-
tional requirements. These facilities were required to certify
compliance with all groundwater and financial responsibility
requirements, and to submit a final permit application. If
facilities could not comply by November 8, 1985 they lost interim
status and were required to cease operation on that date. During
1986, Region I had to review these certifications and, where indi-
cated, take enforcement action (see discussion on RCRA enforcement).
At the start of 1986, Region I regulated 137 land disposal facilities.
By the end of the year, the number wasreduced to 109 as a number
of these facilities initiated closure activities rather than seek
operating permits.
HSWA Deadline for Permitting
In HSWA, Congress established a schedule for completion of
RCRA permitting. Facilities operating under interim status must
either receive a permit or cease operation under the following
schedule:
Type of Facility Permit Issuance By
Land Disposal November, 1988
Incinerator November, 1989
Storage and Treatment November, 1992
Encouraging Alternative Treatment Technologies
The 1984 Amendments to RCRA allowed for issuance of a permit
to encourage the use of alternate treatment technologies for
hazardous waste. These “Research, Development, and Demonstration
permits allow facilities to employ innovative and experimental
technologies. To expedite review of these permits, EPA may waive
the usual permit requirements, with the exception of financial
responsibility and public participation. Several of these permits
are currently under review in Region I.
22
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Corrective Action
The 1984 Amendments to RCRA mandated corrective action at
RCRA facilities. Corrective action permits or orders will be
issued to RCRA facilities that have released hazardous waste
constituents that threaten human health or the environment.
Through these orders or permits, facilities are compelled to
clean up contamination that has occurred due to operation of
the facility. This will most often apply to contamination of
groundwater, but could also involve soils, surface water and
sediments, subsurface gas or air.
Facility Management Planning Process
Although we are focusing on land disposal facilities as our
first priority, all TSDFs are subject to corrective action provi-
sions. Because the number of facilities requiring corrective
action could be substantial (Region I estimates 350 facilities),
the Waste Management Division developed a priority setting pro-
cess to determine in what priority facilities will be addressed.
Another purpose of the process is to make co rrective action
decisions as consistently as possible in the Region.
Chart 15 shows the priority setting process developed in the
Region in 1986. Briefly, TSDFs were identified and issued
letters requesting information (RCRA Section 3007 letters). As
facilities responded to these letters, each facility was ranked
based on program and environmental considerations. The ranking
system determines the facility’s “environmental significance.”
Figure 15
Facility Management Planning Process
Facility Action EPA Action Comments
Identify TSDFs Land disposal identified; In
process of defining other
TSDF5 for Corrective Action.
3007 Letter Send/Review 3007 Selected in groups over time
Response Letter based on previous knowledge
Initially Screen If not “environmentally significant”
a Rank Facilities then facility action postponed.
RFA must be done eventually.
Develop Multi—Year Determine RFA priorities based on
Strategies/FMP initial screen score.
Complete RFA
Release? p If no release, then the facility
has completed corrective action
obligations.
Group Meets to Informal priority scheme based on
Determine Type & environmental impact of release
Priority of Action and other management considerations.
Public 4 Issue Permit/Order
Notice _____________________
(permit Only)
Submits RFI I d Review and Approve ]
Proposal j
Implements RFI ) Oversees 23
Isubmits RFI Review & Approve
Iseport I
-------
A RCRA Facility Assessment will then be conducted at all TSDFs,
based on their priority standing, to determine if a release of con-
taminants has occurred. If no release has occurred, the facility
has completed its corrective action obligations.
If, however, a release has occurred, another priority setting
takes place based on the potential environmental impact of the
release and other management considerations. The facility is then
put in line for a corrective action permit or order and will be
addressed according to its priority standing. Region I completed
the FMP initial ranking for 137 land disposal facilities in 1986
and determined that 128 were environmentally significant.
As a result of this corrective action process, the RCRA—HSWA
program has begun to develop an approach very similar to that used
in Superfund:
RCM Activity Superfund
I RA Facility Environmental Problem Preliminary Assessment
Assessment Identification Site Identification
Corrective Action Dete inine public health Hazard Ranking System
Decision and environmental impact;
Assign priority
RCRA Facility Study the problem in-depth I iedial Investigation/
Investigation and evaluate different Feasibility Study
remedies
Remedy Selection Assure remedy is logged Record of Decision
and meets other statute
requirements
Remedy Implementation Clean up contemination Remedial Design/
Remedial Action
Enforcement in the RCRA Program
The effective implementation of RCRA’s regulatory programs
rests on compliance with the rules and regulations developed under
the Act. Facility inspections by Federal/State officials are the
primary tool to determine compliance.
EPA and the States inspect TSDFs to make sure they are com-
plying with their RCRA permits or interim status requirements.
Region I conducted 24 inspections in non—authorized States in
1986; authorized States conducted 187 inspections of facilities.
This exceeds the statutory mandate of inspecting 50% of the regu-
lated universe each year (the regulated universe in Region I is
369 TSDFs, not including land disposal).
When violations are found, EPA or the State issues a warning
letter or a compliance order, which specifies what the permit
holder must do to remedy a violation, and may also assess a fine.
24
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Region I States issued 67 Administrative Orders in 1986, and EPA
issued 8 in non—authorized States. $387,700 in fines was assessed
to non—compliers. In serious cases, a permit or interim status may
be revoked, and civil or criminal law suits may follow. Region I
filed seven civil cases on behalf of State Agencies in 1986.
In addition, Region I began the first civil cases in the
country against three facilities in Connecticut that were not
in compliance with the loss of interim status (LOIS) regulations
discussed earlier.
Significant Non—compliers
One of the highest enforcement priorities for EPA and State
enforcement action is focused on “Significant Non—compliers.”
Facilities defined as significant non—compliers in the RCRA
program are those land disposal facilities that have high priority
violations (Class I) of groundwater monitoring requirements
(Subpart F), closure and post closure requirements (Subpart G)
or financial requirements (Subpart H).
Region I had 79 RCRA facilities in significant non—compliance
at the beginning of 1986. Forty—five of these facilities (57%)
were in compliance at the end of Fiscal Year 1986. Twenty—seven
of the facilities had formal enforcement actions taken against
them and only seven facilities did not have formal enforcement
actions and remained in significant non—compliance at the end of
the year.
RCRA Special Project Grants
In addition to providing grants to States to carry out the
RCRA program, the RCRA staff in Region I also administers “one—time”
grants to States for special projects. These funds were first made
available to EPA in 1985 through a Congressional budget add—on to
support two types of activities:
1) development or implementation of hazardous waste programs
focused on innovative waste management activities such as
waste reduction, waste exchange and alternatives to land
disposal; and
2) acceleration of permit issuance to new or expanding
facilities which provide alternatives to land disposal and
thereby reduce the dependence on land disposal.
Region I decided to focus its funding efforts on assistance
and education of small quantity generators (SQGs), considering
this to be a Regional priority. Under HWSA, SQGs are now defined
as those generators who generate between 100 Kg and 1,000 Kg per
month of hazardous waste.
In 1986, funds again became available for these grants.
Region I and the New England states committed the funds to moving
forward on the work they had done previously on SQG projects.
25
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Region I issued $272,000 to States for six special projects in
1986. New England States conducted seminars, produced video—tapes
and handbooks, and published listings of local testing laboratories
or hazardous waste transporters available for small quantity genera-
tor use. The example below highlights the potential these projects
have to reach SQGs who are often not aware that the law affects
them.
The Cape Cod Planning and Econc nic Developtient Group received
funds for a project designed to be completed in two phases, begin-
ning in 1986. Phase I emphasized technical assistance to genera-
tors. Phase II will include establishment of a regional data base
on hazardous waste generators and waste streams, rk with SQGs to
achieve conpliance with disposal regulations and to reduce the volume
of waste requiring land disposal. In 1986, they began conducting
sate of the 25 one-on-one site consultations and held several of the
eight seminars with SOGs to explain State and Federal laws. Sate
of these seminars are “cluster” seminars which focus on a specific
audience such as photography labs or auto—body shops. The on—site
consultations are designed to help facility vners spot areas where
they could make changes in their processes to reduce or recycle
waste.
One of the short-term projects on Cape Cod involves develop-
ment of “milk—runs.” 1b encourage email SQGs to dispose of hazard-
ous waste properly, licensed transporters periodically pick up the
waste fran SQGs on a specific route and transport it to a licensed
I RA treatment, storage or disposal facility. With the 1987 grant
they will continue their previous rk, and will conduct a feasi-
bility study for siting a transfer station for hazardous waste.
Underground Storage Tank Program
In addition to the Waste Management Division’s efforts to con-
trol today’s hazardous wastes through RCRA, and clean up yesterday’s
improper waste disposal through CERCLA, we are beginning to require
proper management of underground storage tanks containing petroleum
products and chemical substances used as raw materials.
Recent estimates show there are approximately 150,000 under-
ground storage tanks at 50,000 sites in New England. To understand
the regulatory problem this number presents, consider that there
are approximately 5,000 handlers of hazardous waste regulated under
RCRA in Region I and 58 sites on the Superfund National Priorities
List in Region I. The number of underground tanks falling under
EPA or state regulations is 30 times higher than the number of RCRA
facilities we are presently addressing. This means that EPA and
the States cannot handle underground storage tanks in the classic
way of doing business. We will have to rely heavily on outreach
efforts and voluntary compliance.
As with many of the environmental statutes, Congress intended
that States conduct the Underground Storage Tank COST) proqram.
Region I States were regulating Underground Storage Tanks before
Congress mandated the development of Federal regulations and thus
have a jump on the problem. Five of the New England States now
have effective regulations in place for most tanks, and Vermont’s
26
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program will be in place in January, 1987. The Federal regulations
addressing leak detection and leak prevention for underground
storage tanks are being developed in EPA Headquarters and should
be in place in 1988.
Not if i cation
The first task mandated by law was called notification:
owners of currently used tanks and tanks taken out of operation
within the past ten years notified the designated State agency
that they owned a tank or tanks. This notification procedure is
complete in Region I and gives us an idea of the size of the
problem.
Grants
One of the primary responsibilities of the Regional program
is to provide grant monies to States for addressing the UST
problem. In 1986, EPA issued $120,000 in grant funds per State
and laid the groundwork for new State grants for 1987. Grants in
1986 focused on managing the notification requirement, including
printing and distribution of forms and educating tank owners
about this effort, and continuation of State regulatory program
development.
Special UST Projects
State grant projects in the UST program for 1987 will continue
to focus on notification and program development. In addition,
the Region will fund several special projects, including:
o in Maine, a grant to assist in documenting experiences of a
“first in the country” tank installation certification board
(focusing on one of the two largest reasons for tank failure);
o in Vermont, to study the need for, and possibly site on
State—owned land, a landfill for contaminated soil from
leaking tank site clean ups; and
o also in Connecticut, a study to help determine if EPA needs
to regulate certain exempt tanks (small motor fuel tanks at
farms and residences), supporting an upcoming EPA report to
Congress.
The New England Interstate Water Pollution Control Commission
(NEIWPCC) was one of the first multi—state coordinating committees
to focus on the problem of leaking underground tanks. NEIWPCC
was later selected by EPA Headquarters as the national coordinating
group. They publish a quarterly bulletin called LUSTLINE and work
on national outreach and education of tank owners.
In Region I, EPA has also focused on compliance with new
regulations. In 1986, we started three enforcement cases, presently
under investigation, against tank owners who did not comply with
the Federal interim prohibitions reqarding new tank installation.
27
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HAZARDOUS
WASTE
MANAGEMENT
IN
NEW
ENGLAND
STATES
ALL DATA ON HAZARDOUS WASTE
GENERATED IN 1985 IS
PRELIMINARY DATA FROM THE 1985
STATE BIENNIAL REPORTS.
-------
Progress at Superfund Sites in Maine
Site
Previous Accanplishments
1986 Acccxiplishments
F. O’Connor
Removal of tanks, drums and
their contents. Fence
irstalled around site.
R iova1 unilateral order
valued at $10,000.
Remaining tanks
removed • Enforcement
order for private
party RI/FS signed.
First round of field
sampling cat plete.
McKin Co.
Alternative drinking water
supplied by town. Liquid
wastes removed. Surface
tanks and drums and their
contents ware removed. Site
fenced. RI/FS canplete.
1 )D signed.
Pilot study of soil
aeration successfully
canpieted. Lagoon
closed and filled.
Buildings decontaminated
and removed • Full
soil aeration begun
with about 6000 cubic
yards treated.
Pinettes
Salvage Yard
Saco Fannery
Waste Pits
Union chemical
Ccinpany, Inc.
Contaminated soil removed.
Wastes ware neutralized,
capped and a fence installed.
RI/FS begun in 1985.
Drums removed. Site was proposed
on NPL Update and is riot yet
on final NPL.
Remedial Investigation
ongoing. Three rounds
of field sampling
and surveying canpleted.
State conducting ongoing
RI/FS funded by EPA
through cooperative
agreement.
State investigations and
raa)val act ions underway.
EPA enforcement actions
planned.
U.S. Navy NAS
(Brunswick Naval
Air)
Initial asses isrits identified 10
areas with possible contamination.
Ground water, surface water and
soil samples have been taken for
study.
Scoping of RI/FS and
RA Corrective Action
underway with Navy.
Winthrop 1’bwn
Landfill
Waterline installed under consent
order with PRPs. RI/FS caupleted.
Remedial actions will include
capping, alternate water supply,
and pumping and treating of
groundwater if necessary.
Remedial design begun
by PRPs under joint
enforcement consent
decree by Maine and
EPA. Several designs
reviewed and sane are
being revised. Surface
debris r ioved.
31
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The 1 RA Program
RCRA
Tons of Hazardous Tons Tons Number of State/Country That Program
Waste Generated Treated Disposed Regulated Receives Majority Authorization
in 1985 in State in State Generators of Waste Decision
9,136 1,053 0 348 Canada Expected
May 1987
The amount of waste reported generated in Maine has decreased since the
1983 r ort on hazardous waste genera on (1983—10,211 tons). Almost 12% of
the waste generated in the State is treated in Maine.
Maine has not been authorized to conduct the RCRA program but Region I
staff in the Waste Management Division rely on the state to conduct the
day—to-day business of the program, including inspections and enforcement
cases, under grant agreements.
LCP Corrective Action Order
Region I’ S first Section 3008(h) Corrective Action Order was issued to
LCP chamicals, Inc., a TSD facility located in Orrington, Maine. LCP will be
conducting a RCRP Facility Investigation to tharacterize contamination enanating
fran land disposal and solid waste management units on—site. In the past,
LCP and former owners used landfills for disposal of solvents and mercury
bearing sludges. Concurrent with the Corrective Action Order, LCP was issued
a 3008(a) order for violations of subpart F graindwater monitoring requir nents,
and assessed $23,125 in penalties.
rtamouth Navy Shipyard HSWA Permit
Region I is drafting a H A permit for the rt uth Navy Shipyard. To
ensure public participation, an expanded canmunity relations program has been
developed. EPA has held two public workshops (August and October 1986) in
Kittery, Maine to solicit public irput and educate the public concerning
HSWA. The topics of discussion included a detailed explanation of the H A
permitting process, and an overview of the environmental investigations -
the facility may have to undertake.-
As a result of these workshops, there has been heightened public interest
in the HS & permitting process, and the public is better informed of how the
process works. Also as a result of our expanded efforts, the Maine Waste
Regulation Section was recently invited to speak at the Ikrtsmouth League of
Wanen Voters general membership meeting on the draft permit.
32
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McKin Site Case History
The McKin site is one example of
the results possible in cleaning
up a Superfund site once studies
have been canpieted and a decision
about tie remedy has been made.
The description below highlights
previous efforts at the site and
progress made in 1986.
The seven—acre McKin site, located
approximately 15 miles north of
Ikrtland, Maine, is an abandoned
waste collection, transfer and
disposal facility which operated
between 1965 and 1978. When organic
chemical contamination was detected
in nearby residential wells in 1979,
an alternate water supply was built
by the Ibwn of Gray with a matching
grant fran the federal Department
of Housing and Urban Development.
Between 1979 and 1983, EPA removed
all surface drums and tanks fran
the site, thus controlling any
immediate public health hazards.
In 1985, the remedial investigation
and feasibility study (RI/FS) were
canple ted. The RI/FS determined
tie nature and extent of contamina-
tion remaining at the site and
evaluated potential technologies to
reduce any environmental or public
health hazards. The studies identi-
fied volatile organic chemicals in
the soil in specific areas on the
site and contamination of tie nearby
aquifer.
In July, 1985, EPA announced its
decision to attack both problems.
r tie onsite soil contamination,
EPA chose to aerate the affected
soils under controlled conditions.
Fbr off site groundwater contamina-
tion, EPA decided to pump contam-
inated qroundwater and treat it in
a new treatment plant to be built at
the site.
Shortly after EPA made its
cleanup decision, two canpanies
previously identified by EPA as
potentially responsible parties
(PRPs) offered to carry out the
approved remedy. In August,
1985, EPA formally ordered these
canpanies, Fairchild Camera and
Instrument ODrp. and Sanders
Pssoc., to begin cleanup activi-
ties including a pilot study for
soil aeration.
The purpose of the pilot study,
canpleted in 1986, was to inves-
tigate the effectiveness of one
or more methods of aerating soil
to allow volatile contaminants
to evaporate.
This system, the first of its kind
at a Superfund site, was designed
to treat soil in an enclosed area
while controlling the levels of air
air pollutants in the air around
the site. Tb ensure air emissions
were controlled, an elaborate air
monitoring system was designed for
the site and nearby residential
areas.
Data fran five air monitoring sta-
tions around the site are continu-
ously fed to a canputer in a
trailer at the site. Visual and
audible signals will be produced
if activities need to be modified
to produce air contaminants. This
continuous ccviputerized monitoring
network is the most canprehensive
to have been used this way in
New England.
In July, 1986 an Administrative
Order was issued to the PRPs which
canpelled them to aerate solvent
contaminated soils and prepare an
excavation plan that would delin-
eate the actual area of excavation
33
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and level of contamination to be
aerated. A total of 8500 cubic
yards will ultimately be aerated
with 3500 cubic yards left to can-
plete. Druns filled with oily
sludges and other wastes fran
earlier resoval actions are being
shipped to an EPA approved hazardous
waste facility and will be off—site
by November 1986.
lb keep residents informed of
activities at the site, EPA
established a telephone hot—line.
The hot—line gives periodically updated
recorded messages regarding the site
status and air quality nonitoring, and
records the caller’s questions. In
addition, throughout the decision process,
the EPA project manager met with local
officials and the public to share
information and answer questions
about activities and the cleanup at
the site.
34
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Progress at Superfund Sites in Vermont
Site Previous Accanplishments 1986 Accanplishments
Old Alternate waterline installed — Waste seeps fenced and posted.
Springfield paid for by PRPs. RI/FS begun Waste delineation investigation
Landfill in 1984. and feasibility study ongoing.
Pine Street Surf icial coal tar wastes were Develcpirkj RI/FS workplan.
Canal solidified and removed. PRP search ongoing.
The I RA Program
Tons of Hazardous Tons Thns Number of State that RCRA
Waste Generated Treated Disposed Regulated Receives Majority Program
in 1985 in State in State Generators of Waste Authorized
11,580 0 0 351 New York Jan. 1985
Vermont reported an increase of 56% in the amount of hazardous waste
generated in the State since the 1983 hazardous waste report (1983 — 7,425
tons). All of Vermont’s hazardous waste is stored in the state and then
shipped to other States for treatment and disposal.
Vermont has eight facilities which will receive 1 RA permits as either
storage facilities or closures in 1987. Approximately 60% of all regulated
generators in the State are inspected on an annual basis. State requirements
are more extensive than Federal requirenents under RCR and include many
standards that are required for storage facilities. These efforts focus on
reducing the potential for environmental releases at facilities not regu—
lated for storage, treatment or disposal.
Underground Storage Tanks
Vermont held public information meetings in every county in the State
explaining the notification rules addressing underground storage tanks.
Subsequently, the State has received and processed notifications fran more
than 2800 locations in the State and estimates there are 7000 underground
storage tanks. After 18 months in development, the Waste Management Division
in the State has also su}:niitted proposed final regulations to the Legislative
Cannittee on Administrative 1 jles. The rules call for secondary containment
as the general rule for all new tank installations, and should be adcpted by
January, 1987.
Waste—end Tax
Vermont also developed and implemented a Waste End tax in 1985, based on
the volune and destination of hazardous waste. Waste which is destined to be
reclaimed, recycled or recovered for beneficial purposes is taxed at the
lowest rate (.9 cents per pound of solid); waste destined for treatment is
taxed the next highest; and hazardous waste destined for land disposal is
taxed the highest (28 cents per gallon). This tax may provide the incentive
to move State industries toward the RCRA goal of waste minimization, reuse or
recycling of hazardous waste.
35
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Progress at Superfund Sites in Connecticut
State provides bottled water
to 2 homes with contaminated
wells. RI/FS and )D cctTlplete.
Remedial action will include
cap, extension of water supply
and groundwater monitoring system.
1986 Accomplishments
Negotiations with ccmunittee
representing most of 77 PRPs.
Unilateral order issued to
31 PRP5 to design and con-
struct waterline extension.
Kellogg-
1 ering
Well Field
Laurel Park,
Inc.
Remedial Investigation begun.
RI/FS and 1 )D ccz pleted.
Water treatment and
distribution system will be
done first. Letters
notifying PRP5 of actions issued.
F nce installaticn completed.
Negotiations ongoing with PRPs
for design and construction
of waterline for 54 homes.
Old
Southington
Landfill
Revere
Textile
Prints Corp.
Drume and contaminated soil
were removed, by the PRP.
Reviewed technical proposal
for State Order issued to the
town of Southington. ‘The
Order is not yet being enforced.
Solvents
Recovery
Services
of NE
Ya rski
Waste Lagoon
22 PRPs identified.
On-site groundwater recovery
system constructed and
began operation. Operation
of off—site groundwater
intercept system awaits State
issuance of NPDES permit.
Remedial Investigation
completed. Project funding
constraints forced temporary
slowdown. Feasibility Study
began under new contract to EPA.
Site Previous Accomplishments
Beacon
Heights
Landfill
Initial studies of site predated
formal RI/FS and W)D documents.
36
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The 1 RA Program
Tons of Hazardous Tons Tons Number of States/Country RCRt
Waste Generated Treated Disposed Regulated Receiving Majority Program
in 1985 in State in State Generators of Waste Authorized
176,100 47,106 16,284 701 Canada Potentially
Pennsylvania 1987
New Jersey
Connecticut industries are among the largest generators of hazardous
waste in New England. However, the waste is generated by a small number of
regulated ccinpanies. The amount of waste generated by Connecticut industries
decreased by 9% since the 1983 hazardous waste report (1983 — 193,725 tons).
Connecticut is the only state in New England reporting that any significant
amount of waste was reclaimed, recycled, or reused in 1985 (34,887 tons).
The state of Connecticut is also singled out among New England states by
the large number (over 100) of land disposal facilities, primarily containing
sludges fran the treatment of metal finishing wastes. These “regulated
units” under I RA resulted fran an early aggressive program by Connecticut to
require treatment of these wastes prior to discharge. intil the November
8, 1985 deadline, these facilities routinely were allowed to place the wet
sludges in unlined lagoons. The econanic and regulatory requirements to file
for and obtain permits to upgrade these disposal methods caused most facilities
to stop operating their lagoons by the deadline and begin dewatering and
shipping sludges out of state. The formerly regulated units are now being
“closed” as required by ! RA (waste is being excavated and trucked off—site
or the units are closing with waste in place).
I)iring 1986, EPA also actively reviewed Connecticut’s application for
authorization to man e the RCRA program. Connecticut lost it’s interim
authorization to manage the RCRA program which reverted to EPA in 1986. With
the loss of Connecticut’s interim authorization, the large number of land
disposal facilities, and even larger universe of major facilities entering
the corrective action process, the Connecticut Section has becane the largest
in Region I’ S WRA program.
Several major issues were identified by EPA when the program reverted,
including standards for “closure” of the land disposal facilities and require-
ments for timely and apprcpriate enforcement policy development. EPA outlined
these deficiencies and entered into a letter of intent with the Connecticut
Department of Enviranental Protection (DEP) in April 1986 to bring the State
program into conformance with the Federal regulations. EPA and DEP staffs
have worked throughout the year to develop joint and similar procedures for
reviewing technical closure plans and conducting enforcement actions with the
goal of authorization early in 1987.
In 1986, Region I staff conducted many RCPA activities in Connecticut.
Over 2300 letters were sent to Connecticut 1 RA facilities to advise them of
procedures under program reversion. The operating status and canpliance with
groundwater and financial requirements of all land disposal facilities in
Connecticut were verified, resulting in the first three Loss of Interim
Status (LOIS) enforcement cases in the country. Three permits were issued
containing corrective action facility investigation requirements, among
the first permits of this type in the U.S.
37
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The Connecticut Section also ccxnpleted Facility Managenent Plans for all
lard disposal facilities as the first step in the corrective action process.
Information was received frau facilities on old non—regulated units in response
to RCM Section 3007 information request letters sent to each facility. Due
to staff constraints, similar letters were not sent to another 130 storage
and treatnent facilities, many of which have significant past disposal problems.
The first gr ip of these requests are being sent in December. We will screen
the entire universe of storage, treatnent, and disposal facilites in Connecticut
to determine priorities for corrective action at facilities of greatest risk
to human health and the environnent.
38
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Solvents Recovery Services of New England
The Solvents Recovery site shows the clean-
up of environmental contamination possible
after extensive studies are ccmpleted to
determine the source and extent of contain—
ination. The site is a good example of the
EPA’S efforts to ensure other environmental
media are not affected in removing contam-
inants frcEn a Superfund site. Solvents
Recovery is also unique in that it predated
the formal remedial investigation/feasi-
bility study now under Superfund.
Solvents Recovery Services of New England
(SRS) is a three—acre site located in
Southington, Connecticut, approximately
500 feet west of the Quinnipiac River.
Primary activities at the facility included
the recovery of industrial solvents by
distillation and the manufacture of a
waste fuel blend for use in the cement
industry. The facility operated fran
1955 to the present.
In addition to being listed as a Superfund
site, SRS has applied for a RCRA permit
and currently has interim status. Since
the mid—70’s, the facility has operated as
a solvent storage and treatment facility.
Currently, no disposal of hazardous waste
takes place at the facility.
Southington municipal water supply wells
number 4 and 6 are located approximately
1350 and 1900 feet north of the site, res-
pectively. Both of these wells were found
to be contaminated with volatile organic
canpounds in September, 1976. Studies by
EPA determined that groundwater contamina-
tion in well 4 and in other off—site areas
was due to contamination by SRS.
A Consent Decree was signed in 1983 requir-
ing remediation of groundwater contamina-
tion. The onsite groundwater recovery sys-
tem began operating in 1986. The purpose
of the system is to prevent off—site migra-
tion of contaminated groundwater and con-
sists of a series of interconnected ground-
water recovery wells on the downgradient
edge of the SRS site. Extracted ground-
water f ran the system is treated to remove
volatile organics in an on—site air strip-
ping tower. The treated water is then
discharged to the Quinnipiac River.
With the on—site groundwater treatment
system operational, the facility had to
canply with other environmental statutes.
Under the Clean Water Act, SRS was re-
quired to obtain a National Pollutant
Discharge and Elimination System (NPDES)
Permit in order to discharge the treated
groundwater to the river. The permit
requires SRS to sutinit monitoring results
to the State and EPA bi—weekly. The
monitoring results show the reduction in
groundwater contaminants obtained through
the system and the cleanup of environ-
mental contamination.
NP1 S monitoring reports suttnitted by the
SRS show the decrease in contamination of
the extracted groundwater by providing
analytical results of samples taken prior
to and after treatment in the air stripping
towsr.
The October report reflecting samples
collected by the facility in July and
August of 1986 indicates that 96.3% of
total olatile organics were removed
fran the extracted groundwater before it
was discharged to the river. SRS is also
required to analyze for a limited number
of individual volatile organic contami-
nants. For example, the monitoring report
indicated that 100% of the benzene was
removed f ran the water, and 95.7% of the
toluene was removed.
The off—site recovery system consists of
several wells connected to a cannon collec-
tion pipe. It has been constructed but
cannot begin operating until a NP1 S per-
mit is issued also allowing this sytem to
discharge treated water to the Quinnipiac
River.
The two groundwater recovery systems do
not represent the final action in environ-
mental cleanup at the SRS site. Residual
soil contamination not addressed by a
Superfund action at the site will be covered
by a RCRA HSWA permit. In addition, EPA
is undertaking an evaluation of the perfor-
mance of the groundwater recovery systems
to determine if they are achieving the
groundwater cleanup performance standards
laid out in the Consent Decree.
39
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Progress at Superfund Sites in Massachusetts
Site
Previous Accanplishments
1986 Accanplishments
Baird &
McGuire, Inc.
Contaminated soil was capped.
Site is cmpletely fenced.
Initial remedial actions include
demolition of two buildings,
relocation of watermain and
temporary capping of contamin-
ated soil. Four PRPs identified.
RI/FS and W)D caBpleted.
Construction of waterline
underway
Cannon
Engineering
corp.-
Bridgewater
600 drums and hazardous waste
renoved • Part of Cannofl’ s
enforcement case.
RI/FS ongoing.
Negotiations ongoing with
PRPs.
Charles
George Land
Reclamation
Landfill
Fence installation, cover and
regrading of exposed refuse,
and water supply. 376 PRPs
identified. I )ES for on—site
work and waterline ccntpleted.
Wetlands assesement received
and approved. Caupleted
first information meeting
with PRPs. PRP search ongoing.
Waterline under constructidn.
Cover design alnost canplete .
Off—site RI/PS underway.
Groveland
Wells 1 & 2
P1/PS ccinpleted. Supplemental
source contamination invest iga—
tioris ongoing.
Welihead treatment system
under construction. Should be
ccinplete in Spring, 1987.
Haverhill
Municipal
Landfill
PRP search in progress.
Hocanonco
Pond
RI/FS and 1 )D canpieted.
7 PRPs identified.
Consent Decree for design,
construct ion and maintenance
referred to Dept. of Justice.
Revisions needed to canply
with 1986 Superfund amendments.
Irilustri—
Plex 128
Fence installed around
site. RI/FS caupleted.
20 PRPs iaentified.
1 D canpleted.
Iron Horse
Park
Cover over asbestos piles.
Five PRPs identified.
RI/FS ongoing. Initial
removal of PCBs frcm 6
catch—basins. Renoval of
clean steel and cement
underground tanks.
New Bedford
Harbor
Signs posted and playground•
has been fenced.
RI/FS ongoing. Dredging
feasibility study also being
conducted • Trial began for
liability/damages to
natural resources.
Nor ood PCBs
518 tons of PCB contaminated
soil renoved. Liner over PCB
soil contamination while sam-
pling is ccinpleted. Nine PRPs
identified.
Negotiations underway with
PRPs for RI/FS.
40
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Massachusetts
Site
Previous AccQnplishments
1986 Accanplishments
Plyniuth Harbor!
Cannon
Engineering
Tanks were drained and are
currently clean. RI/FS and
)D ccxnpleted. Part of
Cannon’s enforcement case.
Remedial Design for sludges
underway. I )D provides for
groundwater and surface
water diversion, consolidation
and capping.
Remedial design underway and
remedial action to start in
Spring of 1987. Negotiations
ongoing with PRPs.
PSC Resources
Tanks were drained of over
one million gallons and are
currently clean.
State and EPA agreement being
finalized for State lead
RI/FS.
Resolve, Inc.
RI/FS and I )D were ccmpleted.
Remedial action renoving
lagoon contents and contain—
mated soils (16,000 cubic
yards) have been canpieted.
245 PRPs identified.
Supplemental Remedial Invest-
igation being conducted to
determine extent of soil
con€aminat ion on—site and
to address groundwater and
wetlands contamination.
Rose Disposal
Pit
Alternate waterline and fence
have been installed. Soil
contaminated with PCBs has
been covered.
Feasibility study ongoing.
Salem Acres
Fence has been installed.
Negotiations underway with
PRP5 for them to conduct
RI/FS.
Shpack aunp
iarterly monitoring of
residential wells by State.
Silresim
Chemical Co.
All chemical wastes located
in above-ground storage
containers were removed by
1981. Site is fenced and
RI/FS ongoing conducted by
Silresim Trust, formed by
185 PRPs.
has a temporary clay cap.
Sullivan’s
Ledge
Site has been fenced.
Remedial
ongoing.
began.
investigation is
Enforcement work
W.R. Grace & Co.
Large tanks were dismantled
and removed. Aquifer
restoration program underway.
Landfill, other waste sites,
and lagoon closure RIs
ccaiplete. Negotiations
ongoing for final closure
options.
Wells G & H
Wells were shut down due to
contamination of drinking
water. Drums have ixien
removed and site fenced.
RI/FS ongoing.
Nyanza
Fence installed.
RI/FS and
Chemical
ROD ccmpleted
sludges.
to
address
41
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The Program
Tons of Hazardous Tons Tons Number of State That RCRA
Waste Generated Treated Disposed 1 gu1ated I ceives Majority Program
in 1985 in State in State Generators of Waste Authorized
209,543 154,530 158 4,894 New York Feb. 1985
The amount of waste generated in Massachusetts in 1985 is almost double
what was reported in 1983 (111,017 tons). At this time, it is difficult to
determine where the increase lies, but an EPA study underway should determine
if changes in reporting are responsible’ for the increase.
Aln st 74% of the hazardous waste generated in the State is treated
within the State, with .07% disposed of in the State. Massachusetts did not
report that any waste generated in the State was reused, reclaimed or recycled.
An initiative of the Massachusetts E partment of Environmental Quality
Encjineering (DEQE) in 1986 was the passage of penalty regulations and imple—
mentat ion of a penalty policy. This is a major step toward developing a
“timely and appropriate” enforcement program and should result in a higher
degree of ccmipliance in the State.
DEQE continues its progressive education and outreach programe for the
public and regulated ccrimunity. A iall quantity generator (SOG) caTunittee
has been formed to review Federal and State requirements and make reccutunen—
dations for requlatory revisions and ways to increase SQG canpllance.
42
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Baird & Mccuire Superfund Site
CERCIA mardates that the public be
involved in decisions about Superfurid
sites. The Baird & McQjire site is an
excellent example of the cpportunities
an EPA site maneger has in the community
relations aspects of the job.
The Baird & McGuire site, 20—acres in
size, is located south of Boston in
Holbrook, Massachusetts. The chemical
mixing company located at the site was a
formulator and batcher of soaps, disin—
fectants, floor waxes and pesticides/
herbicides fran 1912 to 1983. Approx-
imately 100,000 gallons of hazardous
materials were stored in various tanks at
the site. Of the 129 Superfund priority
pollutants, 102 have been found at the
site. The town’s welifield has been
contaminated by pesticides arid volatile
organic canpounds. As a result, three
water supply wells have been closed.
Surface water is threatened, and dioxin
has been found in wetlands at the site.
EPA conducted several renoval actions
to control inminent threats to public
health. The first removal action was
in 1984 where a breadi in a creosote
lagoon in heavy rains created an oil
slick on the Codiato River. EPA
renoved 1000 cubic yards (50 truckloads)
of contaminated soil, installed a ground-
water recirculation system to prevent
the contaminated groundwater plume fran
discharging into the river, temporarily
capped and fenced part of the site, and
closed sluice gates on Richardi Reservoir
to prevent Cochato River water from enter-
ing the drinking water supply. A 5700
foot fence (over a mile of fencing) was
also installed in late 1985 after dioxin
was discovered at the site.
After stabilizing imminent threats at the
site, EPA began a series of studies into
the problems at the site to propose a
remedy. The canrnunity became very involved
in this process, beginning in June, 1985.
Active arid interested citizen’s groups
encouraged the EPA site manager to go
well beyond the general Superfund community
relations plan, to educate and work with
the community on site decisions. The
press served to keep the community up—to—
date on progress at the site.
The cannunity subnitted a list of
seven requests to EPA at a meeting
when the results of initial studies
were discussed. The requests included:
fence the entire site arid post signs
warning of hazards/ ranove the buildings
on the site prci iptly and install a
fire alarm in the interim; divert the
water main around the site; conduct a
comprehensive testing program of the
sediments in the Cochato River and
all drinking water sources; and
recognize residents of the caiununity as
official participants in the remedial
process.
EPA responded to residents’ requests
and started Initial Remedial Measures
(IRM) to meet these requests. Under
the IRM, denolition of two buildings
and the chemical storage tanks will be
done. Relocation of the 12” water main
began in July 1986, arid highly contam-
inated soils will be capped.
A Citizen’s Advisory Catimittee was formed,
consisting of local members of the Boards
of Selectmen and Boards of Health, the
Fire Chief, environmental interest groups
and local residents. The chairman of the
canrnittee is a State Representative arid
the co—chairman is a chemistry professor.
EPA’s site man er
weekly meetings to
about the site arid
meetings were open
television.
Essentially, the site manager educated the
citizens as to how decisions at the site
are made. Speakers not involved in the
project often made presentations at the
meetings on subjects such as risk assess-
ment arid innovative technologies. When
EPA released a report, the citizens knew
what to expect. Citizens were informed of
timelines and design plans; any decision
EPA made, they i’nfluenced.
The final Record of Decision (ROD) was
signed in September 1986, and requires a
$44.4 million “permanent” remedy. The
remedy calls for incineration of con-
taminated soils, groundwater treatment
and wetland restoration. This is the
largest sum to be spent in the Region
to date to clean up a site.
attended bi—weekly or
present information
answer questions. The
and covered by cable
43
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Monsanto Canpany Facility
In 1986, EPA focused on the integration of the
RA and CEI LA programs to use the statute
best suited to address a particular site or
facility. The Monsanto Ccinpany facility in
Springfield, Massachusetts is an outstanding
example of breaking new ground through the use
of 1 RA at a facility that first was addressed
under CERCLA. The facility is being addressed
under RCRA for two reasons: 1) The Monsanto
Cctnpany will be conducting the studies and
cleanup of hazardous waste with EPA oversight
— under Superfund this would be a “potentially
responsible party” (PRP) lead site; and 2) The
facility is seeking a Part B RCRA permit to
allow stor e of hazardous waste at the
facility.
Corrective action under RCRA can be incor-
porated as a condition of the RCRA permit.
Contaminated soils arid groundwater will be
cleaned up without using Federal Superfund
dollars in the process, arid conducting a
lengthy enforcement case afterwards.
brk at the facility also exemplified cocp—
eration between EPA and the State to address
active hazardous waste facilities. The efforts
of Massachusetts’ Department of Envirorinental
iality Engineering and EPA led to r ore pro-
gress than had each organization addressed the
facility separately.
The Monsanto facility, 400—acres, is the larg-
est chemical manufacturing facility in New
England, and one of the oldest in the area
(operating for over 80 years). Fiberloid
operated the facility beginning in 1904,
manufacturing products such as brushes and
piano keys fran one of the earliest developed
plastics. Monsanto bought the property in
1938. The site has various landfills with
manufacturing buildings constructed on one
of them, liquid disposal pits where benzene,
toluene arid of fproduct have been dumped,
leach fields where solvents have been dis-
posed, four burning pits and cages, and
several areas where manufacturing accidents
have occurred (25,000 gallons of formaldehyde)
were spilled at one location).
The facility was originally addressed in 1982
arid 1983 under CE1 1A and a pre—ranedial inves-
tigation was conducted. EPA and the State then
issued a joint order in 1983 to require a reme-
dial investigation and feasibility study
(RI/FS).
Field work began on a three—phase reme-
dial investigation in 1984. Phase I
emphasized collection of information
about prior history of the site and
seismic work. Phase II of the investi-
gation began in late 1984 and included
geophysical work and ground penetrating
radar to determine if there were buried
drums on site. Monitoring wells were
installed and sampling of groundwater
also took place.
In 1986, Phase III of the study began.
Sampling of groundwater, soils, sedi-
ments and surface water was conducted.
Also, test pitting (digging into the
ground with a large backhoe) to confirm
the presence of buried drums arid contents
in the drums took place late in 1986.
We are currently awaiting the Phase III
report which will include choices for
reinediation. At this writing, Monsanto
had spent $1.5 million to study the rate
arid extent of contamination.
The corrective action provisions in the
1984 amendments to ICRA provide EPA with
a strong tool to examine a facility tool
to examine a facility through an inte-
grated approach. We can now lock at
past and present waste practices and
examine the manufacturing process when
issuing a permit.
As a condition of the RCRA permit,
Monsanto will be required to clean up
past releases of hazardous waste. The
permit to store waste on—site can then
be revoked if Monsanto does not cauply
with any aspects of the permit, includ-
ing the corrective action provisions.
The permit application fran Monsanto is
three volumes, in binders each about three
inches in thickness. This permit appli-
cation will have to be reviewed by EPA
and the State as part of the permitting
process • The Monsanto case emphasizes:
1) the importance of State involvement;
2) the importance of consistency across
Regions in dealing with non—local caupan—
ies; arid 3) the similarities between the
I R and CERCLA programs • EPA’s Headquar-
ters offices have also recognized this
case as exemplary in corrective action
arid will use the work at the facility in
the 1 RA Facility Investigation Guidance
I ,cument.
44
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Progress at Superfund Sites in New Hampshire
Site
Previous Accxinplishments
1986 Accxi plishments
Auburn Road
Landfill
1 mporary relocation of
residents.
Removal of drums began. Focused
feasibility study cc*npleted for
alternate water supply. 1 )D can—
pleted. PR? negotiations ongoing.
Coak].ey
Landfill
Dover Municipal
Landfill
Public water supply extended
to several hanes with contam-
inated wells. 6 PRPs identified.
R [ /FS initiated.
RI/FS ongoing.
Kearsarge
Metallurgical
Drums removed fran site.
Remedial investigation by
PR? is ongoing.
Keefe
Environmental
Services
Lagoon cicEe to o rerflcMing
and was drawn down 4 times to
prevent overf low. Lagoon now
closed. Drums have been removed.
Remedial investigation canplete.
Draft feasibility study
under review.
Mottolo Pig
Fanu
Drums have been removed.
Three PRPs identified.
Site is not final on NPL.
Ottati & Goss/
Great Lakes
Container Corp.
9000 tons of PCB contaminated
soil and 3000 empty drums
were removed. In court under
Section 106/107 of CEI LA,
with several PRPS.
RI/FS canpie ted.
Savage Municipal
Water Supply
Bottled water was supplied to
residents. Met with PRPs and
town of Milford to review
draft workplan.
Cctnpleted workplan. PR?
negotiations underway. Title
search on properties underway.
Sanersworth
Sanitary Landfill
RI/FS ongoing.
South Municipal
Water Supply
RI/FS ongoing by PR?.
Sylvester’s
Drums r ved. An emergency
action intercepting and recir-
culating groundwater was in-
stalled to delay migration of
contamination.
Groundwater treatment
facility was started; has
been in 24—hour operation
since April, 1986. Part
of Cannon’s Enforanent case.
Tibbetts Road
Drums have been removed.
Contaminated soils have been
excavated. Waterline is being
designed for adjacent residences.
Negotiations with PRPs
ongoing for Rh/FS.
Tinkham Garage
Pei:manent waterline
installed.
RI/FS and ROD ccznpleted. PR?
negotiations ongoing RD/RA.
Part of Cannon’s Enforcement
case.
45
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The CRA Program
Tons of Hazardous ns Itns Number of States That RA
Waste Generated Treated Disposed Regulated Receive Majority Program
in 1985 in State in State Generators of Waste Authorized
19,791 0 88 440 Ohio Dec. 1984
New York
The amount of hazardous waste generated in New Hampshire in 1985 was 59%
higher than the amount of waste generated in 1983 (12,410 tons). Industries
in the State dispose of 45% of the hazardous waste generated in the State.
In the fall of 1986, New Hampshire conducted six free public education
seminars for hazardous waste generators across the state. Over 500 people
attended the program which addressed the latest laws and regulations.
Household Hazardous Waste
In 1986, New Hampshire launched an active household hazardous waste
collection program by authorizing the use of the New Hampshire Hazardous
Waste Clear ip Fund for this purpose. Twenty—two collections were held last
year, serving 648,373 individuals or almost 2/3 of the State. Each partici—
pating municipality raises matching fund monies for the project and conducts
a public education campaign on the dangers and proper disposal methods for
household hazardous wastes.
RCR Enforcement Actions
New Hampshire fined two canpanies for RCRA violations including improper
disposal on hazardous waste, and transporting without a permit and manifest.
RA Cleanups
Closure of a lagoon ccinmenced November 18, 1985 at W.W. Cross, Jaffrey.
In May, over 4,000 tons of sludge arid 5,000 gallons of liquid were shipped to
an Ohio landfill. Backfill arid cover of the lagoon was cciupleted August 8,
1986. The ccinpany submitted a closure certificate on September 22, 1986.
The Division and ccnpany are currently developing a post closure plan for
on—going monitoring at the site.
46
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Sylvester Superfund Site
The Sylvester site in Nashua is an excel-
lent example of the Federal/State/Local
partnership that often develcps during
the process of addressing a Superfund
site. EPA and the State entered into
the first cooperative agreement funded
under CEICIA to address the Sylvester
site. The site also exemplifies the
environmental results possible once a
site has been fully studied and a remedy
implemented.
Sylester’s Diinp site is a 7—acre sand and
gravel operation. The owner ran an ille-
gal waste disposal operation, accepting
household refuse, denolition materials,
chemical sludges, and hazardous liquid
materials. Thirteen—hundred 55-gallon
drums were disposed of at the site, ard
records also show that over 900,000 gal-
lons of hazardous wastes were discharged
into a leach field, subsequently seeping
into soils and contaminating over 100
million gallons of groundwater.
Several emergency actions were taken at
the site. A security fence was installed
by the City of Nashua around the drum
storage area, and hazardous waste in
approximately 1,314 drums was analyzed
and shipped to an approved hazardous
waste treatment facility for treatment
and disposal. A groundwater interception
and recirculation system was installed
to temporarily contain the most heavily
contaminated groundwater and prevent
contamination fran going into a nearby
brook and river. This system effectively
delayed migration of the contaminants
until further action could be taken.
The final remedial actions at the site
called for isolation, interception and
treatment of contaminated groundwater.
In 1982, a slurry wall surrounding the
20—acre site was constructed to reduce
migration of contaminated groundwater.
A synthetic membrane cap was also placed
over the site to prevent rain water and
snow melt fran infiltrating the soils and
canbining with contaminated groundwater.
The slurry wall and cap were constructed
at a cost of $2.4 million (90% paid by
EPA, 10% paid by New Hampshire). A
municipal water line has also been ex-
tended to potentially affected local
residents at a cost of $140,000 shared
by EPA, the State and the City of Nashua.
In April 1986, the treatment facility
for contaminated groundwater became
operational. Approximately 430,000
gallons per day of groundwater will be
treated each day. As contaminated water
is pumped f ran the ground, lime is added
to raise the pH of the groundwater to
remove heavy metals such as iron and
manganese. The groundwater is further
processed through a high temperature
“air stripper” which separates the vola-
tile organic canpounds fran the ground-
water. These volatile organic canpourtds
are then incinerated.
The flow is then split, with approxi-
mately 360,000 gallons per day being
returned to the groundwater contained by
the slurry wall and eventually treated
again. The remaining 70,000 gallons per
day receives further biological treat-
ment, similar to treatment at a conven-
tional secondary wastewater treatment
facility, prior to discharge to a re-
charge trench outside of the slurry wall
containment area. This sidestreain is
intended to induce groundwater flow into
the slurry wall containment area, through
the fractured bedrock below the site,
thus preventing leakage out of the con-
tainment area.
EPA estimates that approximately 300
million gallons will have to be treated
in this manner before contaminants in
the groundwater are reduced to an accept—
table level. I estimate the facility
will need to operate for approximately
two years (costing approximately $1.5
million per year, 10% of which is paid by
the State). After two years of opera-
tion, the treatment system will be eval-
uated to determine whether the treatment
plant should be shut down.
The State conducts quarterly groundwater
monitoring inside and outside the con—
tairinent area to monitor the effect ive—
ness of the slurry wall and the containment
system. EPA is also actively involved in
identifying the PRPs and recovering costs
for the work at the site.
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Progress at Superfund Sites in Rhode Island
Site Previous Accanplithiients 1986 Aocanplishments
Central Landfill PRPs installed nknitoring Negotiations ongoing with
(Johnston Site) network in response to PRP5 to conduct RI/FS.
State order.
Davis GSR Final listing on NPL.
Landfill PRP search began.
Davis Liquid 255 drums were renoved. RI ccinpleted; action meno
Waste 17 PRPs identified. for waterline drafted.
Landfill & Site stopped accepting waste RI started.
Resource Recovery in 1985. Most portions of the
landfill have been capped.
Peterson! PRP independently installed W3rkplan ccii pleted for fUnd
Puritan, Inc. interceptor well to control lead RI/FS. EPA will review
migration of contaminated work aireedy done at site
groundwater. during RI/FS.
Picillo Farm All barrels have been Negotiations ongoing
excavated and renoved. with State before iniple—
RI/FS and 1 )D canpieted. menting remedy. Need
20 PRPs identified. reauthorization funds
before proceeding.
Stamina Mills Waterline installation RI/FS ongoing.
oatplete. 3 PRPs identified.
Western Sand & Renoval of liquids. Design underway for a water
Gravel RI/FS and 2 I )De ccmpleted. supply system. Consent
150 PRPs identified. Decree to collect past costs,
cap the site and study
groundwater contamination
filed.
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The W RA Program
Tons of Hazardous Tons Tons Number of State That 1 RA
Waste Generated Treated Disposed Regulated Receives Majority Program
in 1985 in State in State Generators of Waste Authorized
14,974 4465 0 1476 New York Jan. 1986
Rhode Island facilities treat alncst 30% of their hazardous waste in the
state. The State continues to regulate all hazardous waste generators regard-
less of the anount of hazardous waste generated. The Rhode Island Department
of Envirorinental Management also conducted several successful “Household
Toxic Waste Clean—up” days during 1986.
Rhode Island has increased its use of administrative and criminal penalties
as enforcement tools. The State is also beginning to ccmputerize its manifest
system which should prove to be a valuable aid during enforcement actions.
A great deal of effort was spent to authorize Rhoc e Island’s 1 RA program.
Inorder to acocm plish this task, Region I and Headquarters’ staff had to
evaluate various aspects of the State’s program. This evaluation focused on
ccinp) .iance and enforcement, permitting, regulations, grant caimiitments,
management, and reporting requirements. Upon ccn pletion of the evaluation,
EPA determined that the State is running a capable program and therefore
deserves final authorization. Rhode Island received Final Authorization to
run the RA program in January 1986.
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Derecktor criminal Case
In late 1986 the largest environmental
crimes penalty ever imposed in New England
was levied against Robert E. Derecktor
and his firm, Robert E. Derecktor of
Rhode Island, Inc. The case is also a
successful example of Federal/State coop-
erat ion in enforcement of environmental
laws.
Robert E. Derecktor of Rhode Island,
Inc. is a Rhode Island corporation doing
business at a facility on Ccddington
Cove, Middletown, Rhode Island. Robert
Derecktor is a shareholder, corporate
director and president of the Rhode Island,
Inc. and operated an industrial facility
operation for ship repair and construction.
The Rhode Island Department of Envirormental
Management (DE7I) investigated the case along
with EPA. The canpany was charged with dis-
charging abrasive blastiflg debris and other
poflutants into Narragansett Bay, in viola-
tion of the Clean Water Act. The canpany
pled guilty to 24 discharge violations.
violations.
The canpany also admitted it failed to notify
EPA when removing asbestos, a violation of the
Clean Air Act, and failed to notify EPA of a
release of asbestos during ship repair opera-
tions, a violation of CE L (or Superfund).
Derecktor pled guilty to four
violations of the 1 xic Substances
Control Act, including failure to
mark transformers containing PCB8,
inprcper storage and dispásal of
P03s, and failure to maintain storage
and disposal records • Derecktor’ s
guilty plea related to the re oval of
three PCB-contaminated transfo ,iers
fran a drydock at the Rhode Island
shipyard and burying them at his
residence in Middletown, Rhode Island.
Derecktor could have received up, to
five years in prison and fines totaling
$725,000, and the shipyard could have
received $635,000 in fines. The penal-
ties assessed in Decanber, 1986 totaled
$675,000, with $75,000 of that levied
against Derecktor himself. The court
suspended $200,000 of the’ fine provided
the oanpariy pay $200,000 as restitution
to the Rhode Island Environmental Response
Fund. -
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FUTURE
CHALLENGES
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Future Challenges
The goal of the reorganization, and a major theme we will
be addressing in the coming year, is program integration. These
words will encompass much of the work we do in 1987. we are
focusing not only on the integration of the Superfund and RCRA
programs, but on the integration of all the environmental programs
of EPA. This presents several challenges for us in the coming years.
One challenge is to address environmental problems while
ensuring the goals of the all the environmental acts will be met..
We now assess the impact of Superfund sites on wetlands, groundwater,
and surface water, in addition to soils. In our cleanup remedies,
we make sure that the contaminants we are removing from groundwater
do not end up in the air. This is a challenge, to ensure that we
are not transferring the contaminants at a Superfund site from
one environmental medium to another. In the RCRA corrective
action program, we will look at five media which may be affected
by releases from manufacting firms, and we will work to attain
the cleanest possible environment in all media.
A challenge in implementing the corrective action provisions
under RCRA will be to decide how much to rely on Superfund’s
experience. In many ways the staff in the Superfund program have.
addressed barriers the corrective action program may encounter.
We are currently encouraging staff to move between the two programs,
and share their experiences. We hope this will alleviate any
problems similar to Superfund’s first few years. -
One technical challenge we face relates to our ability to
detect contaminants in different media. This ability far
surpasses our ability to understand what those numbers mean in -.
terms of human health and damage to the environment. This in turn
relates directly to our risk management and risk communication
challenges. How can we communicate the risk to the public and help
them understand what the numbers mean?
Another technical challenge will be to understand the risks
we are facing. We need better ways to work with risk and risk—
based decision making. We need to convey to the public that we
don’t live in a risk—free society and that we won’t be able to
give them zero—risk environment. This is the challenge: to
convey to the public what we are doing and how long it takes.
This is a difficult problem and this report is but one attempt
to communicate how our programs work and what we have been
accomplishing.
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A new challenge is presented by the 1986 amendments to Superfund.
Congress mandated a higher level of public participation, and we must
maintain program continuity while factoring in the new amendments.
We will have to review work under progress to ensure it meets the
requirements of the new statute. In the amendments, Congress also
mandated that sites be cleaned up permanently. This will mean that
we need to develop new technologies.
Another challenge in the Superfund program will be to carry out
remedies. In 1986, many things were put on hold because of the lack
of reauthorization of Superfund and the unreliability of the funding
situation. Now with the new amendments and 8.5 billion dollars, we
will be able to focus on starting remedial actions where remedial
decisions have already been made.
Specifically in the RCRA program, the challenge will be to do
three things and do them all well: 1) overview existing State pro-
grams and help unauthorized States through the authorization process;
2) implement the corrective action program and see that work begins at
priority facilities; and 3) maintain an enforcement presence. Our.
enforcement programs are the leverage we have to ensure that facili-
ties which fall under the purview of the law, follow the regulations.
Another challenge for years to come will be to focus on the
goals of the Resource Conservation and Recovery Act. We must begin
to encourage waste minimization or recycling and reuse. If our
programs are working, the cost of disposing of the waste will
become higher, so that it will become economical for industry to
reuse or not generate the waste initially.
In the Underground Storage Tank ,program our goal is to work
closely with the New England States to build programs which will
be implemented at the state level. By promoting leak prevention,
encouraging leak detection and using the new Trust Fund resources
wisely to clean up leaking underground storage tanks, we will
continue our efforts to alleviate this major cause of groundwater
contamination.
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