Superfund Record of Decision Fletcher's Paint Works and Storage Milford NH


                                    EPA/ROD/R01-98/124
                                    1998
EPA Superfund
     Record of Decision:
     FLETCHER'S PAINT WORKS & STORAGE
     EPA ID: NHD001079649
     OU01
     MILFORD, NH
     09/30/1998

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EPA 541-R98-124

                            RECORD OF DECISION

                   US Environmental Protection Agency
                                 Region 1

                          FLETCHER'S PAINT WORKS
                                  AND
                     STORAGE FACILITY SUPERFUND SITE
                         Milford, New Hampshire

                        CERCLIS No. NHD001079649

                            September 30, 1998

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TABLE OF CONTENTS

Contents                                                                Page Number

    I.  SITE NAME, LOCATION AND DESCRIPTION	      1

   II.  SITE HISTORY & ENFORCEMENT ACTIVITIES	      6

        A. Land Use & Response History
        B. Enforcement History

  III.  COMMUNITY PARTICIPATION	      9

   IV.  SCOPE & ROLE OF OPERABLE UNIT OR RESPONSE ACTION	     10

    V.  SUMMARY OF SITE CHARACTERISTICS	     11

   VI.  SUMMARY OF SITE RISKS	     21

  VII.  DEVELOPMENT AND SCREENING OF ALTERNATIVES	     33

        A. Statutory Requirements/Response Objectives
        B. Technology and Alternative Development
           and Screening

 VIII.  DESCRIPTION OF ALTERNATIVES	     35

        A. Source Control (SC)  Alternatives Analyzed
        B. Management of Migration (MOM)
            Alternatives Analyzed

   IX.  SUMMARY OF THE COMPARATIVE ANALYSIS	     58

    X.  THE SELECTED REMEDY	     81

          A.  Interim Ground Water Cleanup Levels
          B.  Soil Cleanup Levels - Protection of Human Health
          C.  Description of Remedial Components

   XI.  STATUTORY DETERMINATIONS	    101

          A.  The Selected Remedy is Protective of Human
              Health and the Environment
          B.  The Selected Remedy Attains ARARs
          C.  The Selected Remedial Action is Cost Effective
          D.  The Selected Remedy Utilizes Permanent Solutions
              and Alternative Treatment or Resource Recovery
              Technologies to the Maximum Extent Practicable
          E.  The Selected Remedy Satisfies the Preference
              for Treatment as a Principal Element

  XII.  DOCUMENTATION OF NO SIGNIFICANT CHANGES	    Ill

 XIII.  STATE ROLE	    118


        FIGURE A - Site Location	      1

        FIGURE B - Elm Street Site	      2
        FIGURE C - Mill Street Site	      2
        FIGURE D - Mill Street Storage building	      7

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FIGURES:
     FIGURE 1 - Study Area Location Map
     FIGURE 2 - Fletcher's Paint Site,  Cross-Section Plan View
     FIGURE 3 - Elm Street Site - Cross Section A-A' ,  PCB Contamination
     FIGURE 4 - Elm Street Site - Cross Section B-B',  PCB Contamination
     FIGURE 5 - Elm Street Site - Cross Section C-C',  PCB Contamination
     FIGURE 6 - Elm Street Site - Cross Section G-G' ,  PCB Contamination
     FIGURE 7 - PCB and TCB Soil Contamination
     FIGURE 8 - Chlorinated Solvent Plume in Shallow Overburden Wells
     FIGURE 9 - Chlorinated Solvent Plume in Deep Overburden and Shallow Bedrock
     FIGURE 10 - Mill Street Site - Cross Section D-D',  PCB Contamination
     FIGURE 11 - Mill Street Site - Cross Section E-E' ,  PCB Contamination
     FIGURE 12 - Mill Street Site - Cross Section F-F',  PCB Contamination
     FIGURE 13 - Soil Volume for Soils  from 0-1 foot at  1 mg/kg PCB
     FIGURE 14 - Soil Volume for Soils  from 1-10 feet at 100 mg/kg PCB
     FIGURE 15 - Soil Volume for Soils  >10 feet at 100 mg/kg PCB
     FIGURE 16 - Location of the 100 year Floodplain

 TABLES:
     TABLE  1 - Field laboratory PCB Results - Elm Street Site
     TABLE  2 - Estimated PCB Mass by Depth and Location
     TABLE  3 - Results of PCB- Congener Analysis on Flocculent Material
     TABLE  4 - Field laboratory PCB Results - Mill Street Site
     TABLE  5 - Summary of Chemicals of Concern by Media
     TABLE 6 - TABLE 24:  Exposure parameters;  Carcinogenic and Non-carcinogenic
                         Exposure pathways for Surface and Subsurface soils
     TABLE 25 - Comparative Analysis of Source Control Alternatives
     TABLE 26 - Comparative Analysis of Management of Migration Alternatives
     TABLE 27 - Chemical  Specific ARARs for Source Control
     TABLE 28 - Location Specific ARARs for Source Control
     TABLE 29 - Action Specific ARARs for Source Control
     TABLE 30 - Chemical  Specific ARARs for Management of Migration
     TABLE 31 - Location Specific ARARs for Management of Migration
     TABLE 32 - Action Specific ARARs for Management of  Migration

     APPENDIX A - NHDES Letter of Concurrence
     APPENDIX B - Responsiveness Summary
     APPENDIX C - Administrative Record Index
     APPENDIX D - Groundwater Use and Value Determination
     APPENDIX E - Recalculation of Risks Associated with Soil Cleanup Levels
     APPENDIX F - Cost Estimate for the Selected Remedy

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                 DECLARATION FOR THE RECORD OF DECISION

        Fletcher's Paint Works and Storage Facility Superfund Site
                         Milford, New Hampshire
                        CERCLIS No. NHD001079649

STATEMENT OF PURPOSE

This decision document presents the selected remedial action for the Fletcher's Paint Works and Storage
Facility Superfund Site  (Site) located in Milford, New Hampshire, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980  (CERCLA) ,  42 USC  9601 et
seq.,  as amended, and to the extent practicable, the National Oil and Hazardous Substances Contingency
Plan (NCP),  40 CFR Part 300 et seg.,  as amended. The Director of the Office of Site Remediation and
Restoration has been delegated the authority to approve this Record Of Decision (ROD).

The State of New Hampshire has not concurred on the selected remedy as of the signing of this ROD. It is
anticipated that the State will concur shortly.

STATEMENT OF BASIS

This decision is based on the Administrative Record which has been developed in accordance with Section
113(k)  of CERCLA and which is available for public review at the Wadleigh Memorial Library in Milford,
New Hampshire and at the US EPA - Region I Office of Site Remediation and Restoration Records Center in
Boston, Massachusetts. The Administrative Record Index (Appendix C to the ROD) identifies each of the
items comprising the Administrative Record upon which the selection of the remedial action is based.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to the
public health or welfare or to the environment.

DESCRIPTION OF THE SELECTION REMEDY

This ROD sets forth the selected remedy for Operable Unit One at the Fletcher's Paint Site, which
involves the excavation and on-site treatment of principal threat wastes which consist of primarily PCB
contaminated soils, the replacement of those treated soils at the Site, and placement of a soil and
asphalt cover over the residual low level threat wastes.  The selected remedy also includes monitored
natural attenuation of the contaminated groundwater in the overburden and bedrock aguifers and
institutional controls to prevent future ingestion of contaminated groundwater, as well as restrictions
on the use and assess to the subsurface soils at the Elm Street Site. The selected remedy is a
comprehensive approach for this operable unit which addresses all current and potential future risks
caused by soil and groundwater contamination. Specifically, Operable Unit One includes the areas referred
to as the Elm Street Site, the Mill Street Site, the drainage ditch and the plume of groundwater
contamination that exists from the Mill Street Site to the Souhegan River. The remedial measures will
prevent the future leaching of PCBs from the low level residual waste, into groundwater in excess of
drinking water standards and will allow for restoration of the Site to beneficial uses.

The selected remedy includes these major components:

Soil

Phase 1 - Mill Street Site Cleanup:

To address the current and future risks associated with dermal contact or ingestion of the contaminated
surface and subsurface soils at the Mill Street Site, the activities would include:

       •      Excavation of approximately 1,500 yd 3 of surface soils (0 to 1 foot)  at  the Mill Street
              Site to a depth of 1 foot,  wherever PCB concentrations are greater than 1 mg/kg PCB.

To address the future risks associated with ingestion of contaminated groundwater at the Mill Street Site
as a result of leaching, the activities include:

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       •       Excavation of approximately 12,000  yd 3  of subsurface soils  at  the  Mill  Street  Site  (1  to 20
              feet (bedrock)  below surface),  approximately 3,000  yd 3  of which are located below the
              water table,  wherever PCB concentrations remain that exceed  1 mg/kg PCB;  or excavation  of
              soils to a PCB concentration at which leaching models and/or soil column testing show that
              infiltration through the  remaining  PCB soil concentrations will not result  in future
              groundwater concentrations in excess  of  the 0.5 ug/1 MCL groundwater concentration for  PCBs.
              The determination of a subsurface soil cleanup level other than 1 mg/kg  PCB,  will be  in the
              sole discretion of the EPA.

       •       Water collected from the  dewatering of the excavated soils and  water collected  as a result
              of lowering of the water  table to conduct the excavation,  will  be either treated on-site
              in a mobile unit and appropriately  discharged to the Souhegan River or sent off-site  to a
              treatment facility.

       •       Treatment of approximately 13,500 yd  3 of excavated soils  by ex-situ thermal desorption.
              The thermal desorption unit would be  located on the Elm  Street  property.  This property  is
              currently secured with a  fence.  Consideration may be given to the use of the former
              Fletcher's Paint Works building on  the Elm Street Site as  storage to stage  and  screen the
              contaminated soils prior  to treatment.  Liguid PCB condensate produced from  the  thermal
              desorption process will be disposed of off-site at  an appropriate facility.

       •       Demolition and disposal of the Fletcher's Elm Street,  building  prior to,  or following
              thermal  desorption activities.  The  manufacturing portion of  this building was used to
              store paint pigments and  chemicals. While these were removed in the 1993 removal action,
              gross contamination still exists in this facility and therefore some of  the debris will have
              to be disposed of at an appropriate landfill facility. Consideration may be reviewed  for use
              of these materials as fill material on the Site.  Decontamination of building material,  if
              warranted,  and off-site disposal will be conducted  in accordance with TSCA.

       •       Off-site disposal of all  soil and debris that is either  oversized or cannot be  treated
              through  the thermal desorption unit.  All contaminated soil and  debris will  be disposed  of
              in accordance with TSCA disposal regulations.

       •       Backfilling of the treated soils back onto the Mill Street Site and restoration of the
              property consistent with  the anticipated future use of the Site.  Specifically,  the
              majority of the Mill Street Site will be paved,  physically re-aligning Mill Street.   The
              pavement will reduce infiltration of  precipitation,  control  erosion and  promote drainage
              away from the residential properties.

       •       Regrading and repair of the storm drainage ditch system,  as  necessary, to promote surface
              water flow away from the  Site.  Erosion control measures  shall be incorporated into the
              final drainage system to  prevent erosion or debris  from  restricting future  storm water
              flow from the Mill Street Site or filling in of the drainage ditch.

Phase 2 - Elm Street Site Cleanup.

To address the current and future risks associated with dermal contact or  ingestion of the contaminated
surface and subsurface soils on the Elm Street Site, the activities would  include:

       •       Excavation of approximately 2,800 yd  3 of surface soils  at the  Elm  Street Site  to a depth of
              1  foot,  wherever PCB concentrations are  greater than 1 mg/kg PCB.

       •       Excavation of approximately 1,000 yd  3 of subsurface soils,  within  the utility  corridor(s),
              at the Elm Street Site at depths between 1 and 10 feet,  wherever PCB concentrations are
              greater  than 25 mg/kg PCB. Final location of the utility corridor(s)  within the Site  will be
              determined during design.

       •       Excavation of approximately 11,600  yd3 of remaining subsurface  soils,  with  the  exception of
              the "hot spot" materials  described  below,  from 1 foot to the seasonally  low water table,
              wherever PCB concentrations remain  that  exceed 100  mg/kg;  or to a PCB concentration at  which
              leaching models and/or soil column  testing show that infiltration through the remaining PCB
              soil concentrations will  not result in future groundwater  concentrations in excess of the
              0.5 ug/1 MCL groundwater  concentration for PCBs.  The determination  of a  subsurface soil
              cleanup  level other than  100 mg/kg  PCB,  will be in  the sole  discretion of the EPA.

        •     Excavation and off-site disposal in an appropriate  landfill  of  the  EB-03 "hot spot",  a
              semi-solid stain (polyamide and polyurethane)  material.  This material is not amenable to

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the thermal desorption process, as the material is comprised of polyurethane, alkyd
resins, etc., which may affect the performance of the thermal desorption unit. (The actual
volume of this material is estimated to be 1,000-2,000 yd3, and is considered part of the
subsurface excavation volume describe above.)

Removal and disposal of the 5 underground storage tanks located on the Fletcher's Elm
Street property. (This could take also place during Phase 1, if appropriate)

Treatment of the approximately 15,400 yd 3 of excavated soils by ex-situ thermal desorption.
The thermal desorption unit would be preferably located on the Fletcher's Elm Street
property. This may involve the placement of the mobile unit at one or more locations on the
property during the excavation and treatment operations. Liguid PCB condensate produced from
the thermal desorption process will be disposed of off-site at an appropriate facility.

Backfilling of the treated soils on-site.

Final grading of and placement of a 10 inch soil cover over the treated soils, or placement
of treated soils within the top foot, which can demonstrate PCB concentrations less than or
egual to 1 mg/kg PCB. Asphalt would be placed on areas designated for parking, consistent
with the final grading plans and the future anticipated use of the Site. The asphalt
covering will promote drainage and further minimize infiltration through the residual
contamination at the Site. Restoration and landscaping of the remaining areas, not covered
by asphalt. Erosion control measures will be incorporated into the final grading to prevent
erosion of the cover materials off-site and into the Souhegan River.

Institutional controls, in the form of deed restrictions would be implemented to prevent
unauthorized access into the subsurface. Deed restrictions would also have to implemented to
restrict future use of the Site, or the modification of the cover or surface drainage
structures in ways inconsistent with this remedy or the anticipated future use of the Site.
Groundwater
• Establish a Groundwater Management Zone (GMZ) under NH's Comprehensive Groundwater Policy.
The GMZ sets plume boundaries within which groundwater will be monitored over time to ensure
that the contaminant concentrations are decreasing; to ensure that the remaining
contamination has not migrated beyond the established plume boundaries or impacted the
Souhegan River, and that the remedial action cleanup is working and remaining effective over
time. Institutional controls would have to be implemented to restrict the use of the
groundwater within the GMZ, while contaminant concentrations are in excess of drinking water
standards. Further action may be necessary consistent with the NH Comprehensive groundwater
Policy.

• Interim Groundwater Cleanup Levels must be achieved within the GMZ and maintained for a
period of three consecutive years. A risk assessment will, be performed on residual
groundwater contamination to determine protectiveness of the remedy. If EPA determined the
remedy is not protective, the remedial action shall continue until protective levels are
achieved and not exceeded for three years or until the remedy is deemed protective or is
modified.

SPECIAL FINDINGS

Issuance of the ROD embodies specific determinations made by the Regional Administrator pursuant to
CERCLA. Under 121 (d)(4)(D) of CERCLA, the Regional Administrator hereby invokes the eguivalency waiver
for the New Hampshire closure reguirements (Env-Wm 708.02)

Further, an interim remedy waiver pursuant to CERCLA 121 (d)(4)(A) is being invoked for the RCRA and TSCA
storage limitations for the RI/FS generated wastes since the wastes currently stored on the Site is
interim in nature and the final remedy will comply with all ARARs for final disposition of the waste.

DECLARATION

The selected remedy is protective of human health and the environment, attains or waives Federal and
State reguirements that are applicable or relevant and appropriate for this remedial action and is
cost-effective. This remedy utilizes permanent solutions and alternative treatment (or resource recovery)
technology, to the maximum extent practicable, and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element.

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The selected remedy is a comprehensive approach for the first operable unit, which includes both source
control and management of migration components. The source control portion of the remedy includes
excavation and the on-site treatment of PCB contaminated soil by ex-situ thermal desorption.
Institutional controls will be employed to limit the surficial future uses of the Elm Street Site to
activities deemed recreational, while allowing limited access for utility maintenance within the
designated utility. Institutional Controls will be employed to limit future excavation into the
subsurface soils at the Elm and Mill Street sites, where PCB concentrations will remain which are
protective to groundwater from leaching, but which are in excess of protective human health standards.
The management of migration portion of the remedy relies on natural attenuation to restore the
contaminated groundwater to its beneficial uses. Treatment will not be utilized to restore the
contaminated groundwater because it was determined not to be warranted or cost effective considering the
conditions and type of contaminants found at the Site. Active groundwater restoration would not afford a
significant cleanup time advantage and, with institutional controls to prevent consumption of groundwater
in the interim, the selected remedy is as protective of public health as active restoration. The overall
estimated net-present worth cost of the selected remedy is $14,731,975.

OSWER Directive 9355.7-02 states that five-year reviews will be conducted at sites where cleanup levels
will take five or more years to achieve (policy review) or where institutional controls are necessary to
achieve protectiveness (statutory review). Since the management of migration portion of the remedy will
reguire more than five years to complete,  and groundwater and land-use restrictions are necessary, a
review will be conducted within five years after commencement of this remedial action to ensure that the
remedy continues to provide adeguate protection of human health and the environment.

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        FIiETCHER'S PAINT WORKS AND STORAGE FACILITY SUPERFUND SITE
                           ROD DECISION SUMMARY
                              September 1998

1. SITE NAME, LOCATION AND DESCRIPTION



The Fletcher's Paint Works and Storage Facility Superfund Site consists of approximately 12 acres of land
in the town of Milford, Hillsborough County, New Hampshire. The Site is divided into two operable units.
The first operable unit, which is the subject of this Record of Decision  (ROD), specifically consists of
areas referred to as the Elm Street Site, the Mill Street Site and the drainage ditch as well as the
plume of groundwater contamination that exists from the Mill Street site to the Souhegan River  (Referred
to as the "Site") .  The second operable unit consists of the Keyes Municipal Well Field and the Souhegan
River, both of which will be the subject of a future Record of Decision. A more complete description of
the Site can be found in Section 1, pages 1 through 9 of the Remedial Investigation Report.

A. General Site Description and Land Use

The Fletcher's Paint Site is located in a residential and light commercial/industrial area in Milford,
within the Souhegan River Valley, immediately west of the town center (See Figure A) . The First Operable
Unit of the Fletcher's Paint Site is comprised of three general areas:  (1) Fletcher's Paint Works,
located at 39 Elm Street, and referred to as the "Elm Street Site"; (2)  the former Fletcher's Paint
Storage Facility on the northern side of Mill Street, immediately west of the Cottage Street
intersection, referred to as the "Mill Street Site"; and (3) the drainage ditch/culvert system that flows
northward from the Mill Street Pond, along the Hampshire Paper Company property to Draper Mobil property,
where it then flows beneath Elm Street and the Elm Street site, and discharges into the Souhegan River.
All three areas of the Site are located within 700 feet of each other. See Figure 1.

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transport propane and gravel and other materials into and out of Milford. The Mill Street Pond is located
approximately 250 feet southwest of the site.

The Drainage Ditch/ Culvert System

The drainage ditch/culvert system extends from the Mill Street Pond to the Souhegan River. The flow is
carried under Mill Street from the pond, under the Draper Energy Coal Yard, along the Hampshire Paper
Company property, where it enters a culvert system behind the Mobil station. The culvert channels the
flow under Cottage Street and Elm Street, then under the Elm Street site, where it discharges to the
Souhegan River.

Keyes Field and Souhegan River

A 10 acre municipal recreation area, called Keyes Field, is located along Keyes Drive, and is the subject
of a second operable unit at the Site. Keyes Drive encompasses the western portion of the Elm Street
Site. The Keyes Field consists of tennis and basketball courts, ball fields, a playground, and a
community swimming pool. The pool and playground areas are used heavily by children of all ages. The ball
fields and tennis courts are also used by local sport leagues and high school extracurricular sports.

The Souhegan River runs adjacent to the Elm Street Site and the Keyes Field and is used for recreational
swimming and fishing.

B. Geologic Characteristics

Overburden

Overburden deposits in the study area consist primarily of glacial outwash deposits, composed of
stratified fine to coarse sand and gravel, underlain by glacial till. The stratified sands and gravels
have a minimal content of fine materials, i.e., silt and clay, and are generally noncohesive. The glacial
outwash deposits, commonly called "stratified drift," form the highest yield component of the overburden
aguifer in the site area. These deposits are consistently underlain by the upper till, characterized by a
matrix of olive gray fine sand. The upper till ranges in thickness from 0 to 35 feet and is found in most
cases to overlie a slightly more compact till. The lower till is approximately 2 to 5 feet in thickness,
and contains a higher percentage of silt and clay along with angular rock fragments.

In addition to the natural deposits identified above, surface fill is prevalent in the study area. At the
Elm Street site, various fill materials have extended the property over time, pushing back the Souhegan
River from its former position adjacent to Elm Street, to its current position several hundred yards away
from Elm Street. The parking area and a portion of the former manufacturing facility at the Elm Street
site is situated on top of an old municipal burning dump, which operated from 1927 until 1945. The dump
material typically consists of approximately 10 feet of decayed wood, brick fragments, broken glass,
oxidized metal, and slag in an ash-like matrix. Additional sand and gravel fill overlies the burning dump
materials,
A zone of boulders was identified beneath portions of the Mill Street site that may represent the
interface between backfill and native materials. This boulder zone occurred at an approximate depth of 10
feet and was not detected anywhere else in the study area.

The thickness of overburden deposits changes greatly over the study area, varying with bedrock
topography. From the Mill Street site, extending north along the eastern side of the drainage ditch,
overburden is generally 20 feet thick. Overburden thickness on the eastern side of the drainage ditch is
between 50 and 75 feet. Overburden is 60 to 70 feet thick below the Keyes Park and on the north side of
the Souhegan River.

Soil

A number of soil types characterize the ground surface within the Fletcher's Paint Site study area. The
primary soil units are excessively drained, rapidly permeable and very rapidly permeable soils with very
low available water capacity.

Bedrock

The Fletcher's Paint Site is underlain by bedrock which occurs at depths between approximately twenty and
seventy feet below ground in the study area. It is competent bedrock with little weathering, having a
thin (less than one foot) layer of weathered rock at the bedrock surface and few high-angle fractures.
The bedrock surface includes an area of high elevations in the vicinity of the Mill Street and Elm Street
sites and an area of low elevations extending to the west from the vicinity of the nursing home to Keyes
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Park. A relatively steep bedrock slope separates these two areas.

C. Hydrogeologic Characteristics

The Milford area is characterized by three unconfined aquifers which provide the majority of the area's
municipal water supply needs. These aquifers, composed primarily of stratified sand and qravel, are
qenerally oriented west to east, parallel to the Souheqan River and Great Brook.

In addition to these unconfined overburden aquifers, there are fractured bedrock aquifers. Both bedrock
wells and overburden wells provide domestic water supplies in the Milford area.

The Fletcher's Paint Site study area is situated alonq the southeastern extent of the Milford-Souheqan
Aquifer. Depth to qround water across the site varies from approximately four feet below the qround
surface near Mill Street Pond to approximately twenty feet at the Elm Street site and twelve feet at
Keyes Park. The saturated thickness also varies across the study area from approximately ten feet near
the Mill Street site to twenty feet beneath the Elm Street site and fifty-five feet beneath the Keyes
Park.

The base of the Milford-Souheqan Aquifer is locally defined by a discontinuous veneer of clayey silt with
qravel  (lower qlacial till)  that ranqes in thickness from zero to four feet. At locations where the lower
qlacial till is discontinuous, such as the eastern half of the Elm Street site and the Mill Street site,
direct hydraulic communication exists between the bedrock and overburden aquifers. Some hydraulic
communication may also exist in areas where the lower qlacial till is present.

Generally qround water flow is toward the Souheqan River and flows in a north-northwest direction from
the Mill Street site and a north-northeast direction across the Elm Street site and Keyes Park. This
lateral flow is consistent with reqional interpretations that suqqest the river is the primary qround
water discharqe point associated with this part of the Milford-Souheqan Aquifer.

Vertical flow in both the overburden and bedrock aquifers is qenerally upward in the immediate vicinity
of the Souheqan River and prevails downward in the vicinity of the Mill Street Site.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Fletcher's Paint was in operation from approximately 1948 until 1991 as a manufacturer and retail
distributor of paints and stains for mostly residential uses. The paints were primarily water-based latex
paints and orqanic-based solvent paints. The company's annual production was 25,000 to 35,000 qallons.
Followinq the closure of the Fletcher's Paint Works, a consiqnment shop has operated in the front brick
portion of the buildinq. Parkinq for this consiqnment shop is limited as a result of the 1991 fence
installation. The Mill Street site sits vacant followinq the 1993 shed demolition removal action.

Land use at the Elm Street site prior to 1949 included aqricultural farminq in the 1800's (as part of the
Crosby Farm), hide storaqe for the nearby tannery, a turn of the century blacksmith and carriaqe paintinq
business, an armory (1913 to 1926) , the town burninq dump (1929 to 1947),  and an automotive dealership
(1920 to 1949). The Mill Street site contained two sheds that were used by Fletcher Paint as warehouses
for bulk paint piqments for over twenty-five years. Previously, they had been used for qrain storaqe. One
of the buildinqs was reportedly destroyed by fire, prior to EPA's involvement at the site.

On February 1, 1983, the New Hampshire Office of Waste Manaqement (NHOWM)  conducted an inspection of the
Fletcher Paint Works.  The facility was classified as a waste qenerator and was noted to be out of
compliance with the New Hampshire Department of Public Health requlations. The facility never returned
the notification forms requested. However, no further action was taken and, upon a follow-up inspection
on July 7, 1985, NHOWM determined that the Paint Works facility was no lonqer considered a qenerator of
hazardous waste.

The 1984 detection of volatile orqanic compounds  (VOCs) in the nearby Keyes Well by the New Hampshire
Department of Environmental Services ("NHDES"), formerly known as the New Hampshire Water Supply and
Pollution Control Commission, triqqered the removal of the Keyes Well from service and prompted a series
of investiqative activities to determine the contaminant source. Durinq a Preliminary Assessment
conducted in 1985, EPA inspected the facility and found in the Fletcher's Paint Works parkinq lot
approximately fifty drums stacked on their sides several drums hiqh. On the southeastern edqe of the
parkinq lot, approximately 150 drums containinq alkyl resins were adjacent to the buildinq.  The majority
of these drums were bulqinq. rusty, and dented, and the qround beneath the drums was stained. A third
area of drum storaqe located near the southeast edqe of the buildinq contained approximately fifty drums
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of inorganic pigmenting agents used in the manufacture of paint. In addition, twenty to thirty drums were
found stacked outside the storage building on Mill Street. Most of those drums were open, empty, and
stored on their side without benefit of a liner or other containment system.

From May, 1988, to October, 1988, EPA conducted removal activities at both the Elm Street and Mill Street
locations. At Elm Street, the main activities performed by EPA were the staging, sampling, analysis and
disposal of 863 drums of hazardous substances and the covering of the contaminated soils of the parking
lot with geotextile fabric and fill. At Mill Street, EPA covered contaminated soils, inventoried bags of
pigment in the storage shed, and disposed of 12 bags of asbestos contained in the shed. The Fletcher
Paint Works and Storage Facility Superfund Site was proposed for inclusion on the National Priorities
List on June 24, 1988, and finalized on March 30, 1989. In November and December of 1991, EPA conducted a
second removal, installing a fence at the Elm Street portion of the Site and removing laboratory
containers found in the building on that portion of the Site.



A third Removal action was completed be EPA at the Mill Street and Elm Street sites during the summer of
1993. The Removal Action included characterization and disposal of wastes found in the Elm Street and
Mill Street buildings, demolition and disposal of the Mill Street building  (see Figure D), and repair of
the caps on both the Mill street and Elm Street properties.

Approximately 500 bags of dry paint pigments, 100 cardboard drums of dry resins, and numerous
various-sized containers of unknown materials were found in the Mill street building Approximately 327
drums of hazardous substances, 750 bags of paint pigments 10 bags of friable asbestos and 2,500 small
containers of miscellaneous substances were removed from the Elm Street building. A total of 512 drums
and 99 wrangler boxes were disposed of during this action. The materials were categorized into 26
different waste streams including oxidizers, peroxides, cyanides, lead, chlorinated organics, acids,
organic solids, inorganic solids and PCBs.

The Elm Street cap was repaired, and re-graded with 64 tons of crushed stone and 132 tons of 3/4 inch
washed stone. A geotextile liner was placed at the Mill Street site where the shed was formerly located,
and 3 to 6 inches of sand fill and 6 to 8 inches of topsoil were placed over the liner. The Mill Street
site was then hydro-seeded.

In April of 1996 EPA completed a Remedial Investigation/Feasibility Study (RI/FS) ,  which began in the
summer of 1990. The RI and other studies reveal that soils, sediments,  surface waters and groundwater are
contaminated with volatile and semi-volatile organic compounds, metals, PCBs, and pesticides. In
addition, the studies show that the Souhegan River has surface water and sediment contamination, as well
as potential impact to certain fish and biota within the river as a result of the contamination.

In December, 1995, EPA Region I made the decision to split the Keyes Well Field and the Souhegan River
into a second operable unit in order to conduct further investigations of the contamination at those
locations. In a future RI/FS, EPA will complete the investigations into the groundwater contamination in
the Keyes Field area and conduct a feasibility study on alternatives to address the contamination in the
River. An April 1998 Ecological Risk Assessment reported the contamination of the sediments, surface
water and biota in the river and concluded that there is a chronic health risk to the biota in the river
as a result of the contaminated sediments.  As part of Operable Unit Two, EPA will determine whether the
Keyes Field and Souhegan River reguire further remedial action.

A more detailed description of the Site history can be found in the Remedial Investigation Report in
Section 1, Table 1-1 and in pages 5 through 8.

B. Enforcement History

In 1990 the EPA referred a complaint to the Department of Justice seeking recovery of costs incurred in
the 1988 and 1991 removals from three potentially responsible parties  (PRPs). Settlement of the complaint
has been reached.

In the summer of 1995, General Electric (GE) , a potentially responsible party at the Site, conducted a
fourth removal. Pursuant to a Unilateral Administrative Order issued on July 13, 1995, under Section 106
of CERCLA, GE removed PCB contaminated soil from surface soil, under lawns,  and on the dirt driveways of
three residential properties across from the Mill Street site to protect residents from the risks of
direct exposure to PCBs. Many of the residents chose to be included in a voluntary relocation program
during this action. A 10 foot wide paved apron was added to the Mill Street site at the end of the action
to prevent further degradation and wear of the edge of the cap and Mill Street itself was re-paved to
direct surface water runoff toward the Fletcher Paint property and away from the residences.
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In August of 1996, GE performed a voluntary soil cleanup of the small piece of land east of, and adjacent
to the Fletcher Paint building. This small piece of land was found to have low levels of PCB
contamination. General Electric voluntarily removed the contaminated soils as well as additional soil to
enable a Korean War Memorial to be built on that location.

On October 11, 1996, EPA issued General Notice to four remaining PRPs, which include the Town of Milford.

On July 10, 1998 a proposed Consent Decree in United States v. The Town of Milford. No. 98-430-B (D.N.H.)
was lodged with the United Stated District Court for the District of New Hampshire. Subseguently a notice
was published in the Federal Register  (Vol 63 No. 142)  on Friday July 24, 1998, opening the Proposed
Consent Decree for comment for thirty  (30) days from publication. In this action, the United States
sought, pursuant to Section 107 (a) of CERCLA, 42 U.S.C. 9607  (a), recovery of costs concerning the First
Operable Unit of the Fletcher's Paint Site, and the subject of this Record of Decision. The Town of
Milford currently owns a portion the site  (the Keyes Drive), and previously has operated a burning dump
on another portion of the site. In the Proposed Consent Decree, the Town of Milford, New Hampshire,
agrees to pay the United States, $62,139.00, for past and future response costs incurred for the First
Operable Unit at the Site; to provide various in-kind services, including replacement piping material,
which is valued at $ 16,675.00, and perform future routine maintenance on the Site; to provide access to
portions of the Site owned or controlled by the Town of Milford; and to covenant not to sue the United
States. This settlement does not address any potential liability for the Second Operable Unit at the
Site.

III. COMMUNITY PARTICIPATION

Throughout the Site's history, community interest and involvement has been high. EPA has kept the
community and other interested parties appraised of the Site activities through six informational public
meetings, numerous personal contacts, nine fact sheets, and press releases.

During February, 1993, EPA released a community relations plan which outlined a program to address
community concerns and keep citizens informed and involved in activities during remedial activities. On
September 25, 1991, EPA held an informational meeting at the Hampshire Hill Sports & Fitness Club to
describe the plans for the Remedial Investigation and Feasibility Study. On August 17, 1994 EPA held an
informational meeting at the Hampshire Hill Sports & Fitness Club to discuss the results of the Remedial
Investigation.

In the fall of 1995 EPA held an informational public meeting at the Town Hall to discuss potential
community related impacts from the various cleanup alternatives that were under review as part of the
Feasibility Study  ("FS"). As a result of this meeting,  which was well attended, EPA met with specific
public and business representatives to further discuss and resolve some of the potential community
impacts.

In April of 1996 EPA released the Feasibility Study report. In June 10 1996 EPA held a public
informational meeting to reiterate the results of the Remedial Investigation and present the various
cleanup alternatives for the site. At the request of the Milford Selectmen, EPA specifically did not
release the Proposed Plan concurrently with the FS, to allow the Town to review and comment on the
potential alternatives prior to EPA finalizing the Proposed Plan.

In December, 1996, EPA made the Administrative Record available for public review at EPA's offices in
Boston and at the Wadleigh Public Library in Milford, New Hampshire. EPA published a notice and brief
analysis of the Proposed Plan in the Milford Cabinet on January 8, 1997, and made the Proposed Plan
available to the public at the Wadleigh Public Library.

On January 14, 1997, EPA held an informational meeting to discuss the results of the Remedial
Investigation and the cleanup alternatives presented in the Feasibility Study and to present the Agency's
Proposed Plan. From January 14 through April 21, 1997,  the Agency held a ninety day public comment period
(an extension of sixty days was granted in addition to the initial thirty-day comment period) to accept
public comment on the alternatives presented in the FS and the Proposed Plan and on any other documents
previously released to the public. On January 29, 1997, the Agency held a public hearing to discuss the
Proposed Plan and to accept any oral comments. A transcript of this meeting and a summary of all comments
and the Agency's response to comments are included in the Responsiveness Summary in Appendix B..

IV. SCOPE AND ROIiE OF OPERABLE UNIT ONE RESPONSE ACTION

As discussed in Section II above,  several removal actions have been performed at the Site to protect
human health and the environment,  to remove hazardous substances and to stabilize the contaminated soils.
The remedial action authorized by this ROD addresses the remaining contaminated soil and groundwater for
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Operable Unit One. The selected remedy was developed by combining components of different source control
and management of migration alternatives to obtain a comprehensive approach for remediation. In summary,
the remedy provides for source control through soil excavation with on-site treatment using an ex-situ
thermal desorption technology, replacement of the treated soils, and installation of a soil cover over
the Elm Street Site as well as an asphalt over portions of the both Elm Street and Mill Street sites.
Management of migration will be achieved through monitored natural attenuation and the use of
institutional controls. The implementation of the remedy for Operable Unit 1 can occur independently of
future investigations and remedial actions relating to Operable Unit 2, the Keyes Well Field and the
Souhegan River.

This remedial action will address the following principal threats to human health and the environment
posed by the Site: current and future human exposure to contaminated surface soils through dermal contact
and incidental ingestion, future human exposure to contaminated subsurface soils through dermal contact
and incidental ingestion, as well as the future ingestion of contaminated ground water; and prevents the
leaching of and continued migration of contaminants through the soils into the groundwater at levels that
would exceed drinking water standards.

V. SUMMARY OF SITE CHARACTERISTICS

Significant soil, surface water, sediment and groundwater contamination is present at the Fletcher's
Paint Site. Major sources of the soil and groundwater contamination were eliminated when drums were
removed during the EPA's 1988 Removal Action. Temporary caps were also placed at the Mill Street and Elm
Street sites during this time period since high levels of residual contamination remained in the soil as
a result of the historical surface spills and improper handling and storage of drums on the properties.

Groundwater contamination is present at both the Elm Street and Mill Street Sites. Groundwater at the
Mill Street Site exhibits the highest levels of groundwater contamination found at the Site and is the
source area for a large plume of groundwater contamination which extends from Mill Street to the Souhegan
River.

At the Elm Street Site, a significant area of groundwater contamination exists as a result of leaching
from a hot spot of polyurethane resins within the subsurface. Groundwater flow is generally toward the
Souhegan River and flows in a north-northwest direction from the Mill Street Site and a north-northeast
direction across the Elm Street Site and Keyes Field. The lateral flow is consistent with regional
interpretations that suggest that the river is the primary groundwater discharge point associated with
the Milford-Souhegan Aguifer. A small portion of the groundwater flow at the Mill Street Site was
observed to flow Southwest, toward the Mill Street Pond. Vertical gradients are generally downward in the
area of the Mill Street site and invert to an upward direction as the Souhegan River is approached.

Chapter 2 of the Feasibility Study contains an overview of the Remedial Investigation. The Remedial
Investigation was carried out in two phases, the first phase (Phase 1A) was conducted between October
1991 and February 1992; and the second phase (Phase IB) were conducted between October 1993 and January
1994. The significant findings of the Remedial Investigation are summarized below.

A. Fletcher's Paint Elm Street Site

Soil

The Elm Street portion of the Fletcher's Paint Works was the location for the manufacturing and operation
of the paint business, including the storage of the materials in drums, as well as the retail outlet. The
Elm Street site is also the location of the former town burning dump. PCBs. while not extensively used in
the paint operations, were identified as the primary contaminant at the Site. The Paint Works used and
resold some of the "scrap pyranol" (which contained various mixtures of PCBs, trichlorobenzene and
trichloroethylene) for other non-paint related purposes such as a dust suppressant, heating oil and as a
compound for the roofing cement industry. The Fletcher's Paint Works also used the scrap pyranol to
suppress the dust at the Elm Street facility.

The RI investigations revealed that in addition to overall surficial PCB contamination in the soils as a
result of the dust suppression, temporary drum storage and related activities at the Site, the highest
and deepest concentrations of PCB contamination directly correspond to former drum storage areas of the
site. To a lesser extent, other hazardous materials found at the site during the RI included volatile
organic compounds (VOCs) such as xylenes, ethylbenzenes and toluene, metals such as lead, chromium,
antimony and barium, and semivolatile organic compounds (SVOCs) such as phthalates and polycyclic
aromatic hydrocarbons  (PAHs), all relating most likely to the paint operations. In the deeper materials
and debris, that comprised of the former burning dump, metals and PAHs (formed as a result of incomplete
combustion) were found.  (See Figures 2 through 6).
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The most prevalent hazardous substance found at the site was PCBs.  Four different PCB Arochlors were
detected in the Contract Lab Program  ("CLP") analysis of soil and groundwater samples collected from the
Elm Street site: Arochlors 1242, 1248, 1254 and 1260. The most freguently identified mixture at the Elm
street site were the Arochlors 1242 and 1248 in the Phase 1A investigation and 1248 and 1254 in the Phase
IB investigation; Arochlor 1260 was only identified once. Arochlors are industrial mixtures of specific
PCB congeners. Arochlor compounds are thermally and chemically stable compounds with excellent dielectric
properties. They have been used in nominally closed systems such as heat transfer liquids, hydraulic
fluids, lubricants and in open ended systems such as surface coatings, inks, adhesives, pesticides,
extenders and for micro encapsulation of dyes of carbonless paper (Merck & Co., 1989).  Trichloroethylene
(TCE) and 1,2,4-Trichlorobenzene (TCB) are compounds typically used with the PCB industrial Arochlor
mixtures, as a cleaning solvent and carrier fluid. In general, where high levels of PCBs are found at the
site, TCE and TCB are also found.  (See Figure 7).

In general three major areas of contamination were identified on the Elm Street property: 1) the EB-15
area, which is just west of the warehouse portion of the Paint Works, and behind the older brick portion
2) EB-03 area, adjacent to the river bank, and 3)  the EB-02 /EB-17 area west and north of the Fletcher's
Paint building.

The area in the vicinity of location EB-15, (See Figure 6), just west of the Elm Street building, and
centrally located on the Elm Street Site, represents the major area of surface contamination at the Elm
Street site. This is one area that was used to store drums during the years of paint operations. The
near-surface sample  (one to two and one-half feet)from this location exhibited the highest concentrations
of TCE (50 ug/kg) , 1.2,4-TCB (8,800 ug/kg), 4-nitrophenol  (860 ug/kg), and percent level PCBs (14,000
mg/kg -total PCBs by field data and 5,000 mg/kg 1248 PCB by CLP). PCB concentrations at this location
generally decreased with depth, however PCBs were found at depth, with field data indicating 940 mg/kg
PCBs detected in the soils from 9 to 11 feet below the surface and 640 mg/kg PCBs detected in the soils
19 to 20.5 feet below grade, and essentially at the water table. Just below the water table, the field
data indicated that the PCB concentrations dropped to 11 mg/kg at 24 feet below grade.

Subsurface soil sampling at location EB-20A, located under the Fletcher's Paint warehouse addition,
indicated that concentrations of PCBs (13mg/kg PCB 1248) were detected from 26 to 30 feet below grade. At
12 to 14 feet, 2.6 mg/kg PCB 1248 was detected. The near surface sample, 0 to 4 feet, at EB-20A contained
6.2 mg/kg PCBs 1248 and 1254. Soil samples were obtained at EB-20A by drilling through the concrete floor
of the warehouse portion of the paint facility. The area that currently houses the warehouse portion of
the paint facility (and has since it was built in the mid 1970's) was formerly the area of the driveway
and drum storage location. Also detected at EB-20A was TCE at 46 ug/kg from 12 to 14 feet and 3 ug/kg at
26 to 30 feet. This location is also close to the location of the culvert system located at similar
depths within the Elm Street site,  and beneath the former Fletcher's Paint Works building.

At EB-03, the subsurface soil sample collected at eleven to thirteen feet and in close proximity to a
resin-like material,  exhibited concentrations of volatile aromatics of 1.9 mg/kg toluene, 21 mg/kg
ethylbenzene, and 20 mg/kg xylenes. PCB concentrations at this location were 6,700 mg/kg and 7,900 mg/kg
(dup) 1242 from 9 to 10.5 feet. PCBs at a concentration of 1,900 mg/kg were detected from 11 to 13 feet.
The vertical extent of the measured PCB contamination in this area reaches a maximum depth of 46.5 feet,
with the highest concentrations found in the top 15 feet. All concentrations below 25 feet were below 1
mg/kg PCB. At the EB-04 location, northwest of EB-03, lower levels of PCBs were found at depths
correlating to the contamination found at depth at EB-03.

A yellowish crystalline material and a brownish, viscous, resin-like substance were encountered during
the Phase 1A drilling at both the EB-03 A and EB-03B locations.  These materials extend from a depth of
approximately 5 feet to 11 feet below the surface. These materials were analyzed using Fourier Transform
Infrared Spectoscopy (FTIR) to determine the overall chemical composition of the materials. The FTIR
spectrum of the yellowish crystalline material was identified as a urethane or polyurethane; the spectrum
for the brownish, viscous material was identified as a polyamide resin.

Also at the EB-03 location, Aroclor 1248 and the higher molecular weight PAHs were detected in the soil
sample collected at seven to nine feet,  in materials determined to be consistent with the burning dump
debris. The materials that were used to define the extent of the burning dump included ash, burnt wood,
broken glass, metal fragments and ceramic fragments. The thickness of the former burning dump materials
varies, ranging from 2 feet at EB-22 to 8 feet at EB-17.

PAH contamination found at the Site indicated that two different types of PAH contamination were
observed, contamination due to combustion by-products and contamination due to petroleum products and/or
paint related manufacturing chemicals. The majority of the PAH contamination found at the site were the
high molecular weight,  three and four ring PAHs and are associated with incomplete Combustion products.
The PAH contamination relating to paint operations were found in near surface samples and included the
two ring PAHs such as naphthalene,  phenols and alkyl-substituted phenols, and phthalates.
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              The subsurface soils from EB-17,  located behind the Elm Street building and,  to a lesser
              extent,  soils from EB-02A,  showed elevated concentrations of volatile aromatics,  PAHs,
              phthalates,  pesticides,  and PCBs.  The contamination at this location was observed in the
              deeper soils (twenty-seven to twenty-nine feet),  which corresponds with possible burning
              dump debris, however,  additional  sources for this contamination include debris within the
              overlying fill surficial releases of contamination and migration from off-site sources
              through the  drainage ditch/culvert system into surrounding site soils.

              Inorganics were observed in soils from EB-18B (seventeen to eighteen and one-half feet);
              Barium,  chromium,  lead,  and zinc,  as well as several other inorganic elements, were observed
              at elevated  (above background)  concentrations in this sample. The locations and depths  of
              the elevated concentrations were  found in an area consistent with the mapped location of the
              former burning dump. However, these metals,  as well as many others,  are extensively used in
              paint formulations.  Lower concentrations of the inorganics mentioned above were observed in
              surface and  near-surface soils in the vicinity of EB-02A and EB-15,  and in deep soils from
              EB-02A and B and nearby EB-17.  This area of contamination is not well defined and could be
              associated with the numerous former storage areas at the site.
Groundwater
       •      At the Elm Street site,  ground water appears to be most contaminated in the area of the
              Site along the river,  at monitoring well ("MW')  03B,  which is screened from eleven to
              twenty-one feet.  Data from this well indicate extremely elevated concentrations of
              volatile aromatic compounds (55,000 ug/1 xylenes,  4,100 ug/1 toluene and 8,400 ug/1
              ethylbenzene).

              Also at MW-03B,  total phenols at 2,927 ug/1 and 5,987 ug/1 were found during Phase IB.
              The high phenols  in the  groundwater is believed to be associated with the paint-related
              polyurethane and  polyamide paint resins that were found at depth at EB-03.

              PCBs were found in the groundwater at MW-04C, MW-02B and MW-20A during Phase IB at
              concentrations of 0.78 ug/1,  0.74 ug/1, and 1.7 ug/1, respectively.

       •      Low levels of TCE contamination (5-84ug/l)  were found in the groundwater monitoring well at
              the Elm Street Site.  The location and depths of the TCE contamination indicate that the
              contamination is  not likely from surficial  releases,  but rather from the TCE contamination
              at the Mill Street Site, which has migrated into the Elm Street Site.

       •      Hydraulically upgradient,  and immediately South of the Elm Street site,  VOC and PAH
              contamination was detected in the groundwater monitoring wells at both the Mobil and Gulf
              Service station.  These gasoline stations have had prior releases, which have impacted their
              properties.

Figures 2 through 6, and Figures 8 and 9, show the PCB contamination at the Fletcher's Elm Street
property, the geology of the site with depth and the extent of TCE groundwater contamination found during
the RI. Table 1 shows the field data collected and analyzed for PCBs for the Elm Street soil borings.

B. Fletcher's Paint Mill Street Site

Soil

At the Mill Street site, contamination was detected  in surface soils, subsurface soils, and groundwater.
The major contaminants include chlorinated VOCs  (primarily TCE), volatile aromatic hydrocarbons
(primarily xylenes), PAHs, PCBs, TCB and metals  (primarily lead).  Surface soil and near surface soil
contamination consists primarily of PCBs and to a lesser extent TCB, PAHs and metals. The area just east
of the former storage shed, where the highest concentrations of contaminants, and especially PCBs, were
found, is known to have been a former drum storage and staging area, as well as an area where contents of
drums were transferred from one drum to another. PCB contamination was also observed in building surface
samples collected from the east wall of the wooden storage shed, immediately adjacent to the known drum
storage area.
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              The area in the vicinity of EB-21C,  EB-12 and EB-07A,  located on the western portion of the
              Mill Street Site,  represents the major area of near surface contamination at the Mill Street
              site.  The vast majority of the PCBs  found at the Mill  Street Site are situated within the
              top four feet. While PCB concentrations decrease rapidly with depth across the site,  PCBs
              were found at depths to the water and below during the field studies. Data from EB-12 and
              EB-21C indicate that PCBs have migrated through the unsaturated zone into the saturated
              zone,  though PCB concentrations found continue to decrease with depth.  Table 2 shows the
              estimated mass of PCBs at Site. PCBs are considered a  dense non-agueous phase liguid
              (DNAPL),  characterized as highly viscous liguids,  compared to other, less viscous DNAPL
              chemicals such as the chlorinated solvents TCE and PCE,  The primary reason believed for the
              infiltration of the PCBs at the Mill Street Site,  was  the initial surficial release of PCBs,
              most likely combined with other compounds, as a liguid material.  This material,  being dense,
              but highly viscous, spread laterally and vertically through the unsaturated the saturated
              zones  leaving residual contamination. The PCBs would have continued to penetrate in this
              fashion until the volume and mass of the material was  no longer sufficient to overcome the
              gradient reguired for further,  deeper penetration into the subsurface.  While the high
              concentrations of PCBs found in the  hallow surface soils are indicative of residual DNAPL,
              free phase DNAPL was never identified in any soil sampling or exploratory boring event
              during the RI.

The near-surface sample  (one to three feet) from the EB-12 location exhibited very high levels of PCBs,
found at 26,700 mg/kg  (CLP) and 110,000 mg/kg  (field data). Arochlors 1242 and 1248 were the primary
arochlors found at this location. Other samples of contaminated soil, taken from near surface soils from
this general location for various treatability studies, indicated PCB concentrations of approximately
88,000 mg/kg  (GE treatability study - Maxymillion Technologies - ex-situ thermal desorption), 35,5000
mg/kg (EPA treatability study, IT technologies, ex-situ thermal desorption) and 60,000 mg/kg  (EPA
treatability study - CF Systems, solvent extraction). TCE, xylenes and trichlorobenzene were also found
at high levels in the near surface sods at this location, 1,2,4-TCB detected in EB-21C at 64 and 69 mg/kg
(dup) from 0 to 4 feet, was the highest observed during this investigation at the Fletcher's Paint Site.
The concentrations generally appeared to decrease with depth. Elevated PCB concentrations in this area,
9,400 mg/kg and 9,600 mg/kg  (dup) Arochlor 1248 from 0 to 4 feet, 780 mg/kg from 8 to 10 feet and 190
mg/kg from 12 to 14 feet, also suggests that the majority of the PCB contamination exists in the upper
soils with a trend toward decreasing lateral and vertical concentrations.

              PAHs were detected in the near-surface samples,  SS-01,  SS-02, SS-03, SS-12,  and S-09.  At
              SS-01,  SS-02,  and SS-03,  PAH contamination generally decreased with depth.  The higher
              molecular weight PAH contamination appears to be from  nearby asphalt surfaces.

       •      While  most of the observed concentrations of inorganics,  in soil samples collected during
              the Mill Street investigation were consistent with background levels, elevated levels of
              lead and barium were found in soil samples from underneath the former storage shed at the
              NEU Street site during the 1993 removal action,  and subseguently were removed. Paint pigment
              removed from the storage shed during the 1993 removal  action were found to contain high
              levels of lead,  chromium,  antimony,  and iron oxides.

Groundwater

A major source of groundwater contamination is prevalent at the Mill Street site. Groundwater
contamination at the Mill Street site includes TCE, TCB, PCBs and a flocculent material, all of which
were all identified at extremely high concentrations.

       •      There  are 4 overburden monitoring wells associated with the Mill Street site,  of which one,
              MW-07A is the only well located on the Fletcher's property itself One shallow bedrock
              monitoring well,  MW-21C,  is also located within the suspected source area of the Mill Street
              site.  The highest concentration detected at the Mill Street site were in monitoring well,
              MW-21C,  a shallow bedrock well, where 5,700 ug/1 TCE,  270 ug/1 PCB and 140 ug/1 TCB were
              detected.

              GE's consultant,  ESE,  conducted additional sampling in 1995 of both MW-21C and MW-07A using
              an even lower flow volume per minute than was used in  the RI, Phase IB investigations,  to
              determine the nature of the contaminant in the mobile  phase.  Laboratory analysis was
              performed on raw water samples collected from each location,  as well as on aliguots of each
              sample that were filtered or centrifuged prior to analysis. While not consistent with the
              EPA protocol for low flow sampling and analysis,  the rationale behind the sampling and
              analysis was that for PCBs,  centrifugation and filtration would be expected to remove
              colloids and particles too large to  migrate while at the same time provide representative
              samples which would obtain mobile PCBs (those dissolved in the water as well as those sorbed
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              to mobile colloidal particles).

The results of the 1995, GE sampling round for MW-07A include: 77.8 ug/1 PCB  (raw water), 58.9 ug/1 PCB
(centrifuged water), and 35.0 ug/1 PCB  (filtered water). The results for MW21C include: 229 ug/1 PCB  (raw
water) ,  182 ug/1 PCB (centrifuged water) and 131 ug/1 PCB  (filtered water) .

As stated in ESE's June 1995 Focused Feasibility report prepared on behalf of GE, "The results of the
analysis of samples collected at the site [both Elm and Mill Street],  with the exception of MW07,
concentrations of PCBs in groundwater have decreased from previous sampling results." "Further reductions
in concentrations are evident in centrifuges and filtered samples. Based on these results, it is apparent
that removal of particulate matter from samples, via centrifuging or filtering, results in a reduction of
the concentrations of PCBs, indicating that a portion of the PCBs in the samples may be attributed to
PCBs adsorbed onto particulate matter or the filter. A portion of these particles are immobile, and the
true dissolved-phase concentration of PCBs is in the range indicated by results for the centrifuged and
filtered samples. Concentrations at Mill Street are indicative of site conditions that are different than
Elm Street."

A flocculent-type (precipitate)  material was observed in groundwater from MW-07A and MW-21C during the RI
investigations. An FTIR analysis of the material from MW-07A indicated the presence of polydimethyl
siloxanes, polyvinyl stearate, acrylic and hydrocarbons. These materials are used in paint formulations.
The presence of this flocculent material was not observed in either well MW07A or MW21C during the GE/ESE
1995 sampling event. In November of 1997, GE conducted a sampling and analysis of the flocculent
material, and reported the findings to the EPA on May 25, 1998.  (See Table 3). The collected was divided
into a top yellow-tan colored sample and a bottom flocculent sample, since ten minutes after sampling,
the flocculent material settled to the bottom of the bailer. The GE report states that "the water was
removed from the bottom of the well using a Waterra TM pump and was visually checked for the presence of
DNAPL that may have not been picked up by the bailer. There was no evidence of DNAPL in the groundwater.
Following purging, the groundwater did not contain suspended material nor was there visual evidence of
DNAPL." GE's reported the findings of the analysis as follows:

Top sample(yellow-tan groundwater): The top sample contained TCE at 72 ug/1, and 46 ug/1 PCBs. The report
notes that this concentration of PCBs may not be representative of the concentrations of PCBs in the
groundwater in the formation, as it may be influences by fine particulate material in the bailer sample
which may not have settled out completely.

Bottom sample  (flocculent material ): The bottom sample contained 77 ug/1 TCE, and 1,780 ug/1 PCB. GE
reported that the PCBs present on the flocculent material and in the groundwater are Arochlor 1242 and
are only slightly altered from the initial chemical composition.

The suspended material in the bottom sample was consistent with the materials found by the EPA during the
RI.  The data from this materials  (from both GE and EPA's analyses)indicate that the flocculent materials
formed as a result of reduced (soluble) iron in the groundwater, in combination with the dense paint
related compounds, entered the well and became oxidized by atmospheric oxygen that can diffuse and enter
the standing water in the well.  Following removal of the flocculent material by purging, no suspended
material was observed,  demonstrating that if the flocculent material is present in the groundwater around
the well, it is not mobile within the formation. The mobility of the flocculent materials within the well
screen is limited as a result of low interstitial groundwater velocity relative to the settling velocity
of the particles. However, the mobility of these same chemical compounds in the groundwater around the
well, which have not yet oxidized to form a precipitated flocculent is not known.

The flocculent materials contained extremely high PCB concentrations (1,780 ug/1) when compared to the
solubility limit for Arochlor 1242 (100 ug/1 [Montgomery and Welkom, 1990]) . Because of the limited
extent of PCB found in the soils at MW07A, where the majority of the contamination is in the top 4 feet,
and concentrations fall below 1 mg/kg at the water table, the extremely high PCB concentration in the
flocculent material is likely due to the absorption of the PCBs at the surface into the other, paint
related materials, which were also likely released as liguids onto the soil surface, and the ultimate
migration of those compounds through the subsurface.

Figures 10, 11 and 12 show the PCB contamination at the Fletcher's Mill Street Site, the geology of the
site with depth. Figures 8 and 9 show the extent of the TCE contamination in the groundwater for the
shallow overburden and shallow bedrock wells. Table 4 shows the field data collected and analyzed for
PCBs at the Mill Street soil borings.
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C. Drainage Ditch/Culvert System

Surface water and sediment related to the Mill Street Pond and drainage ditch/culvert system were
collected and analyzed to determine the role this system had in surface transport mechanisms. This system
connects the Mill Street Pond to the Souhegan River.

       •      PCBs were detected in the sediments from the pond,  drainage ditch,  and culvert system at
              concentrations  ranging from 240 mg/kg to 3.7 mg/kg.  Lead and chromium were found in the
              drainage ditch  system,  in the area identified as a  residential  garden.  Low levels of PCBs
              and pesticides  were also found within the garden area.  The residents using the garden were
              given the sampling results and future protocols on  the  proper washing and handling of the
              vegetables grown in the soils were discussed.  The garden,  at this  time,  is no longer used  by
              the residence.

       •      PAHs were found in the sediments of the Mill Street pond (SED-13)  and in the surface soils
              adjacent to the American Legion parking lot. The concentrations of PAHs decreased
              significantly with distance from surrounding asphalt surfaces.

       •      Phenol,  and 4-methylphenol were detected in the Mill street Pond sediments and surface
              waters as well  as in the drainage ditch sediment locations.  Pentachlorophenol was detected
              in the Mill Street Pond and also during the groundwater monitoring in well locations,
              MW08A(lug/l),MW08B(2ug/l)  and Res-01 (5ug/l).

       •      The presence of high levels of VOCs in the catch basins within  the storm drainage culvert
              system,  with no apparent upgradient detections,  indicates  that  a localized petroleum
              release under investigation by the NHDES was entering the  culvert  system and discharging
              downgradient of the system in the Souhegan river. Sampling of the  outfall from the culvert
              system (OF-5) into the river also indicated the presence of VOCs,  but at a four fold
              reduction in concentration.  The outfall to the River currently  is  being monitoring and an
              absorbent boom  is maintained at the outfall to catch any further petroleum release.

D. Souhegan River

The RI included investigations into the nature and extent of contamination of the Souhegan River. Future
remedial actions, if any, for the Souhegan River would be included as part of Operable Unit Two, and is
not included in this ROD. The surface water and sediment data has been included in this ROD to give a
better understanding of the chemical contamination at the Site, its surroundings, and the potential fate
and transport of the chemicals found on the properties described as part of this ROD.
Sediments
              Moderately high levels of PCBs (49 mg/kg)  were present in the Souhegan River sediments
              adjacent to the Elm Street site,  and concentrations appear to decrease with distance
              downstream of the site.  Sediment  samples downstream at the dam were not collected.
              Deposition from a former Fletcher employees indicates that drums  containing PCBs  may have
              fallen into the river,  when drums were stored along the banks in  the vicinity of  EB-03.  In
              addition,  a fairly steep slope extends from the Fletcher's property into the river  allowing
              PCB contaminated soils to erode into the river,  as is evident by  the detection of PCB
              contamination all along the bank  and immediately adjacent sediments.

              Lead and chromium were also found in samples of Souhegan River sediments adjacent to the Elm
              Street site,  with concentrations  also decreasing with distance downstream of the  site.

              Elevated total xylenes concentrations (11 and 14 mg/kg)  were detected in the Souhegan
              River sediment location SED-11,  adjacent to the Elm Street site and the location  of the
              EB03 boring,  where the paint related resins and high VOCs were found in both the  sods and
              groundwater.

              The highest concentrations of phenolic compounds (phenol and pentachlorophenol) were
              detected at SED-09 adjacent to the Elm Street Culvert discharge point.  The concentrations at
              the river location are likely the result of contaminants migrating from the Elm Street  site
              as well as from the Mill Street Pond and drainage ditch.

              Elevated PAH concentrations were  detected in river sediments adjacent to the Elm  Street
              site at SED-11 and SED-09. PAH concentrations decrease steadily downstream with distance
              from the Elm Street site.  However,  levels of PAHs immediately upgradient of SED-11  (e.g.,
-------
              SED-01)  were comparable to the levels adjacent to the Elm Street site.  Therefore,  the Elm
              Street site does not appear to be impacting PAH concentrations in the Souhegan River
              upgradient of the Elm Street Culvert discharge point near SED-09.

Surface Water

       •      The only surface water sampling location with reported PCB concentrations was SW-03 (0.41
              Ig/L).  This sample was unfiltered and was collected approximately 300 feet downstream of the
              Elm Street site.

       •      The only surface water sampling locations with reported lead concentrations were SW-11 and
              SW-09.  The origin of these detected concentrations is likely from the Elm Street site and
              the Elm Street Culvert.

A complete discussion of site characteristics can be found in the Remedial Investigation Report in
Section 4 at pages 1 through  69 and in Section 5 at pages 1 through 57.

VI. SUMMARY OF SITE RISKS

A Final Baseline Human Health Risk Assessment  (BHRA),  reported in section 6 of the RI  (July, 1994), an
amended BHRA, reported in Appendix A of the FS  (April, 1996) , as well as a Preliminary Ecological
Assessment (July, 1994) were performed to estimate the probability and magnitude of potential adverse
human health and environmental effects from exposure to contaminants associated with the Site.

The public health risk assessment followed a four step process: 1) contaminant identification to identify
those hazardous substances which, given the specifics of the site were of significant concern; 2)
exposure assessment to identify actual or potential exposure pathways, characterized the potentially
exposed populations, and determined the extent of possible exposure; 3) toxicity assessment to consider
the types and magnitude of adverse health effects associated with exposure to hazardous substances, and
4) risk characterization to integrate the three earlier steps to summarize the potential and actual risks
posed by hazardous substances at the site, including carcinogenic and non-carcinogenic risks. The results
of the public health risk assessment for the Site are discussed below followed by the conclusions of the
environmental risk assessment.

Thirty-five contaminants of concern, found in Table 5, were selected for evaluation in the risk
assessment (1994 BHRA). These contaminants constitute a representative subset of the more than sixty
contaminants identified at the Site during the Remedial Investigation. The thirty-five contaminants of
concern were selected to represent potential site related hazards based on toxicity, concentration,
freguency of detection, mobility and persistence in the environment. A summary of the health effects of
each of the contaminants of concern can be found in Appendix A, Toxicity Profiles, of the 1994 BHRA.

Potential human health effects associated with exposure to the contaminants of concern were estimated
guantitatively or gualitatively through the development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to hazardous substances based on the
present uses, potential future uses, and location of the Site. Future land use for the Elm Street Site is
expected to be recreational, with a designated utility worker area, and future land use at the NO Street
Site is expected to commercial. The following is a brief summary of the exposure pathways evaluated. A
more thorough description can be found in the BHRA and in the amended BHRA, Appendix A of the FS.

Surface Soils

There are 3 locations at the Site were potential exposures to surface soils could occur: 1) surface soil
at the Mill Street Site, 2) surface soil at the Elm Street Site and 3) surface soil along the drainage
ditch. Exposure to surface soils in all areas could occur under the current commercial land use, when
adults and children trespass and come in direct contact with contaminants in the surface soils through
incidental ingestion, direct contact , or the inhalation of particulates. Surface soil is considered to
be from the surface to 1 foot in depth.

In the future, the Town of Milford has indicated that it expects the Elm Street Site to become a part of
the Keyes Field Recreation Area, with the primary purpose of this area being additional parking to the 10
acre recreation field. The Elm Street site would also potentially house a concession stand and restroom
facility and provide additional access for the children to reach the main playing areas. Residential
properties are located approximately 20 feet from the Mill Street Site and abut the Elm Street Site on
the western side of the Keyes Drive. Children routinely cut across the Elm Street Site on their way to
the nearby elementary schools, and to access the Keyes Field or access the Souhegan River. Potentially
exposed populations for the future use include adults and children who visit the property for
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recreational purposes. The exposure pathways would be the same as was used for the current use scenario.
This future recreational use designation for the Elm Street Site would not limit the Town to the above
stated purposed, but would however, limit the Town to the future use of the property in ways consistent
with recreational activities.

The current and future use of the Mill Street Site is as a commercial area. The Mill Street Site is
located extremely close to residential properties. Current and future use exposed populations include
adults and children who visit the property for recreational activities. The exposure pathways include
direct contact and incidental ingestion of the contaminated soils and inhalation of particulates.  The
samp exposure pathways were evaluated for the drainage ditch.

For all scenarios, dermal contact and incidental ingestion of soils were evaluated for adults and
children ages one to six years. The EPA recommended values for incidental sod ingestion of 100 mg/day for
adults and 200 mg/day for children, and values of exposed skin surface area of 5,800 cm2 for adults and
2,000 cm2 for children were used to determine the risks associated with surface soil exposure. The
exposure frequency was assumed to be 140 days per year over a 30 year residency (six and twenty-four
years, respectively for adults and children). Refer to Table 6 for specific exposure parameters.

The potential surface soil exposure route of garden crop ingestion was considered only for the drainage
ditch surface soils for adults, because gardening (at the time the risk assessment was conducted)  was
taking place along the ditch at one residential location. For this exposure pathway, uptake of
contaminants into garden crops was modeled. The potential exposure pathways quantified, included
ingestion of above-ground crops such as tomatoes and lettuce and root vegetables such as carrots.  Refer
to Table 6 for the specific exposure parameters.

Although some site areas are adequately covered by grasses and other vegetation which limit particulate
emissions, other areas are not vegetated. Because no inhalation toxicity value existed for airborne PCBs,
potential exposures via inhalation of particulates emitted from surface soils were qualitatively
evaluated.

Subsurface Soils

The amended BHRA, 1996, evaluated exposures in the Elm Street Site and at the Draper Energy
Property(which is part of the Mill Street Site), to subsurface soils which could be displaced to the
surface during excavations related to utility work,  recreational building or amenities, or commercial
related excavation work(Draper Energy). No current exposures to subsurface soils on the Elm Street Site
and on the Draper Energy Coal Yard are occurring, and thus these exposures were not evaluated. The change
in future land use at the Elm Street Site and on the Draper Energy Coal Yard from future residential
(assumed in the 1994 BHRA),  to future recreational (assumed in the amended HBRA, 1996) was due to a
reassessment of the land use by the Town of Milford,  NH  (Lee Mayhew, Town Administrator, May 1, 1995).
The results of the 1996 BHRA are presented in this ROD. At the Elm Street Site and the Draper Energy Coal
Yard, it was assumed that a young child or adult could be exposed to subsurface soils that were brought
to the surface during excavation. Exposure routes included incidental ingestion and dermal contact with
contaminated soils. The exposure parameters used, were identical to those used for contact with the
surface soils.

No current exposures to subsurface soils in the Mill Street Site are occurring. The Town of Milford
reassessed the use of the Mill Street Site and concluded that it would be used as a right of-way to
expand Mill Street, giving a greater buffer between the residents along Mill Street and the road itself
(Lee Mayhew, town Administrator, may 1, 1995). Thus future exposures to subsurface soils at the Mill
Street Site changed from residential exposures assumed in the 1994 BHRA, to no exposure assumed in the
1996 BHRA. Therefore, exposures to subsurface sods were not assessed.

Groundwater

Although groundwater from beneath the site is not currently in use, residential wells could be dug in
this area, or a municipal supply well could be reinstated in the future. Potential exposure pathways for
future residential exposure to contaminants in groundwater include ingestion, dermal contact and
inhalation. Only the risks for groundwater ingestion by adults were quantified, using an ingestion rate
of 2 liters per day for a 30 year residency period.  Dermal exposure and inhalation to groundwater were
not quantitatively evaluated because of the uncertainties associated with quantifying these exposure
routes. The inhalation exposure was qualitatively evaluated by assuming that the exposure dose from
inhalation while showering was equal in magnitude to that received from ingesting 2 liters of
groundwater.
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Drainage Ditch - Sediments and Surface Water

Adults and children ages 1 to 6 could wade in the drainage ditch because of its close proximity to
residences, although there are usually low levels of water within the drainage ditch most of the year.
These individuals could contact surface water and sediments. The potential exposure pathways include
incidental ingestion of sediments and dermal contact with surface water and sediments. Incidental soil
ingestion rates were 100 mg/day for adults and 200 mg/day for children ages 1 to 6, modified by a term
"fraction ingested from source" of 10 percent. An exposed body surface area of 2,000 cm 2 was applied for
children and 5800 cm 2 was applied for adults. Incidental ingestion and dermal contact with sediments
were evaluated for a child (one to six years old) and for an adult who may be exposed 100 days per year
for six and twenty-four years, respectively.

Risk Estimates

For each pathway evaluated, an average and a reasonable maximum exposure estimate was generated
corresponding to exposure to the average and the maximum concentration detected in that particular
medium. The table following this discussion summarizes the risks at the Site, for each exposure pathway.
Risks associated with inhalation of various contaminants were evaluated gualitatively. Excess lifetime
cancer risks were determined for each exposure pathway by multiplying the exposure level with the
chemical specific cancer factor, Cancer potency factors have been developed by EPA from epidemiological
or animal studies to reflect a conservative "upper bound" of the risk posed by potentially carcinogenic
compounds. That is, the true risk is unlikely to be greater than the risk predicted. The resulting risk
estimates are expressed in scientific notation as a probability (e.g. 1 x 10 -6 for 1/1,000,000) and
indicate, using this example, that an average individual is not likely to have greater that a one in a
million chance of developing cancer over 30 years as a result of site-related exposure as defined to the
compound at the stated concentration. Current EPA practice considers carcinogenic risks to be additive
when assessing exposure to a mixture of hazardous substances.

The hazard index was also calculated for each pathway as EPA's measure of the potential for
non-carcinogenic health effects. A hazard guotient is calculated by dividing the exposure level by the
reference dose (RfD))  or other suitable benchmark for non-carcinogenic health effects for an individual
compound. Reference doses have been developed by EPA to protect sensitive individuals over the course of
a lifetime and they reflect a daily exposure level that is likely to be without an appreciable risk of an
adverse health effect. RfDs are derived from epidemiological or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will not occur. The hazard guotient is
often expressed as a single value (e.g. 0.3) indicating the ratio of the stated exposure as defined to
the reference dose value (in this example, the exposure as characterized is approximately one third of an
acceptable exposure level for the given compound). The hazard guotient is only considered additive for
compounds that have the same or similar toxic endpoint and the sum is referred to as the hazard index
(HI).  (For example: the hazard guotient for a compound known to produce liver damage should not be added
to a second whose toxic endpoint is, kidney damage).

Risk summaries for the contaminants of concern in each medium were evaluated to reflect present and
potential future exposures corresponding to the average and the RME scenarios. Risk summaries for the
contaminants of concern, which included: the ingestion of and dermal contact with surface soil at the
Site; the ingestion and dermal contact with the subsurface soils at the Elm Street Site and the Draper
Energy portion of the Mill Street Site; the ingestion of and dermal contact with surface soil and
sediment and surface water in the drainage ditch; the ingestion of garden vegetables grown near the
drainage ditch, and the ingestion of groundwater, are found in Tables 6 through 24.
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FLETCHER'S PAINT SITE  SUMMARY  OF  RISKS
Surface Soil  (Mill Street  and  Elm Street)

                 Incidental  Ingestion -Adults

       Incidental Ingestion  -  Children 1 to 6

                   Total Soil  Ingestion Risks

                       Dermal Contact  - Adults
TOTAL SURFACE SOIL RISKS
(MILL/ELM STREETS)
1.1

11.3
         12.4
11.9

112.5

124

132 .5
                                                                                           COCs with
                                                                                              HI>1               Average
                                                                                           (max cone)  Average     Totals
7E-05

2E-04

2E-04

7E-04


3E-04

          1E-03

          1E-03
                                                                                        Maximum
                                                                                         Totals
                                                                                                                                           1E-02

                                                                                                                                           1E-02
Subsurface Soil  (l-10ft)(ELM STREET)- Future

                 Incidental  Ingestion - Adults    21.8

       Incidental Ingestion - Children 1 to 6    75.4

        Total Subsurface  Soil Ingestion Risks

                       Dermal Contact - Adults     95
TOTAL FUTURE SUBSURFACE  SOIL
RISKS
                                                       4E-04

                                                       1E-03
                                                                 1E-03
                                                                                                                    7E-03

                                                                                                                    8E-03
                                                                                                                               3E-02

                                                                                                                               1E-02
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Risk Summary

Exposure pathways described previously for the site, and the resulting incremental risk estimates are
calculated separately for adults and children ages 1 to 6, and then are summed for total lifetime risks.
Below is a breakdown of the risk estimates for the Fletcher's Paint Site.

Surface Soils: Risks to surface soils are presented in Tables 7-9 of the ROD. Exposure pathways for
surface soil include incidental ingestion and dermal contact. Cancer risks for adults and children
exposed to surface soils at the Elm Street Site,  Mill Street Site, and the Draper Energy property
exceeded 1 x 10 -6 in all cases. The total lifetime incremental cancer risk for the average case scenario
for incidental ingestion of soils f6r children and adults combined is 2 x 10 -4 while for maximum
concentrations, the total lifetime cancer risk is 2 x 10 -3  . For potential dermal contact of soils for
both children and adults combined, the estimated total lifetime incremental cancer risks are 1 x 10 -3
for the average scenario and 1 x 10 -2 for the reasonable maximum exposure (RME)  scenario, The highest
individual estimated cancer risks are for Aroclor 1248 and for Aroclor 1254.  Although risks are not
calculated for inhalation of particulates, risks associated with inhalation maybe similar to those
associated with soil ingestion. The total surface soil incremental cancer risk for the incidental
ingestion and dermal contact with surface soils is 1 x 10 -3for the average scenario and 1 x 10 -2 for
the maximum scenario. Both the average and maximum incremental cancer risk estimates exceed EPA's
acceptable risk range of 10 -6 to 10 -4.

Hazard guotients were not derived for PCBs in the 1994 BHRA because a reference dose ("RfD") for Arochlor
1254 did not exist at the time. Hazard guotients were mistakenly omitted from the 1996 amended BHRA and
have been added into the risk tables in this ROD. These additional HQs further support previous risk
management conclusions based on the 1994 and 1996 BHRA as to which media pose potential risks to human
health. The noncancer hazard indices for incidental ingestion is 12.4 for average concentrations and 124
for the RME scenario for children and adults combined. PCBs are the major contributor to these hazard
indices. For dermal contact, the hazard index is 21.8 for the average and 223 for the RME scenario. The
major contributor to the hazard indices are PCBs. The total HI including dermal contact and ingestion
pathways, is 47.8 for the average case and 479 for the RME scenario. These values greatly exceed EPA's
acceptable noncancer risk range of a total hazard index of 1 to 10.

The results of the Lead Uptake Model for children ages 0 to 6 were evaluated. Predicted blood lead levels
for this age group do not exceed a level of concern, defined as greater than 5 percent of the population
exceeding a lOug/dL increase in blood lead as a result of site exposures.

Subsurface Soils  (Elm Street and Draper Energy):  Risks to subsurface soils are presented in Tables 11 -
13 in the ROD. Exposures pathways to subsurface soils in the Elm Street Site and evaluated in the 1996
amended BHRA include incidental ingestion and dermal contact with soil. Cancer risks for adults and
children exposed to subsurface soils at the Elm Street Site exceeded 1 x 10 -6 in all cases. The total
lifetime incremental cancer risk for the average case scenario for the incidental ingestion by children
and adults combined is 1 x 10 -3 while for maximum concentrations, the total lifetime cancer risk is 7 x
10 -3. For potential dermal contact of soils for both children and adults combined, the estimated total
lifetime incremental cancer risks are 7 x 10 -3 for the average scenario and 4 x 10 -2 for the RME
scenario. The highest individual estimated cancer risks are for Aroclor 1242, Aroclor 1248 and for
Aroclor 1254. Although risks are not calculated for inhalation of particulates, risks associated with
inhalation may be similar to  those associated with soil ingestion. The total subsurface soil incremental
cancer risk for all pathways and at receptors is 8 x 10 -3 for the average scenario and 5 x 10 -2 for the
maximum scenario. Both the average and maximum incremental cancer risk estimates exceed EPA's acceptable
risk range of 10 -6 to 10 -4.

Hazard guotients were not derived for PCBs in the 1994 BHRA because a reference dose ("RfD") for Arochlor
1254 did not exist at the time. Hazard guotients were mistakenly omitted from the 1996 amended BHRA and
have been added into the risk tables in this ROD. These additional HQs further support previous risk
management conclusions based on the 1994 and 1996 BHRA as to which media pose potential risks to human
health. The noncancer hazard indices for incidental ingestion for adults and children combined is 97.2
for the average scenario and 427 for the RME scenario. PCBs are responsible for the majority of the HQ
For dermal contact, the hazard index for adults and children combined is 250 for the average and 1225 for
the RME scenario. The total HI for subsurface soils for all receptors combined and for a pathways is 347
for the average case and 1652 for the RME scenario. These His greatly exceed EPA's acceptable noncancer
risk range of a total hazard index of 1 to 10.

Groundwater: Risks to groundwater are presented in Table 24 in the ROD. In the future,  residential wells
could be installed at the Fletcher's Paint Site,  therefore future risks associated with ingestion of
groundwater were calculated.
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The estimated total incremental cancer risks are 1 x 10 -3 for the average scenario and 3 x 10 -2 for the
RME scenario. The highest individual estimated cancer risks are for benzene,  and PCBs. The contribution
of the inhalation pathway from groundwater to the total risk was gualitatively evaluated in the risk
assessment by assuming the exposure from inhalation was approximately eguivalent to the exposure risk
from the ingestion of 2 liters per day of groundwater. Thus the total risk from groundwater is about
double the risk from ingestion. This approach was adopted by EPA Region 1 due to the uncertainty in
inhalation models at the time. Both the average and maximum incremental cancer risk estimates exceed
EPA's acceptable risk range of 10 -6 to 10 -4.

Hazard guotients were not derived for PCBs in the 1994 BHRA because a reference dose  ("RfM")  for Arochlor
1254 did not exist at the time. Hazard guotients were mistakenly omitted from the 1996 amended BHRA and
have been added into the risk tables in this ROD. These additional HQs further support previous risk
management conclusions based on the 1994 and 1996 BHRA as to which media pose potential risks to human
health. Noncancer hazard indices for adult residents are 18 for the average case scenario and 381 for the
RME scenario. PCBs are the only contributor to the HI for the average case. For the RME scenario, the
individual hazard guotients for ethylbenzene, toluene, manganese and PCBs exceed 1, with PCBs being the
major contributor to the risk, for the RME scenario. These His greatly exceed EPA's acceptable noncancer
risk range of a total hazard index of 1 to 10.

Drainage Ditch: Risks for exposure to surface water and sediment in the drainage ditch for adults and
children combined, are presented in Tables 15 through 23 in this ROD. Exposures to contaminants in
surface soil, sediments and surface water in the area of the drainage ditch could occur via incidental
ingestion and dermal contact for adults and children ages 1 to 6. Ingestion of garden vegetables could
also contribute to exposures for individuals gardening near the ditch.

Estimated lifetime cancer risks associated with ingestion of surface soils in the drainage ditch for
adults and children combined are 3 x 10 -5 for the average case scenario and 1 x 10 -4 for the RME
scenario. The contaminants of concern with individual cancers risks of greater than 1 x 10 -6 are PAHS,
PCBs and arsenic. The compounds contributing the majority of the potential cancer risk in drainage ditch
surface soils are carcinogenic PAHs. Dermal contact with the drainage ditch surface soils for adults and
children combined, results in a lifetime cancer risk of 5 x 10 -6 for the average case scenario and 2 x
10 -3 for the RME scenario. Dermal risks were only calculated for Aroclors 1248 and 1254. Although risks
are not calculated for inhalation of particulates, risks associated with inhalation may be similar to
those associated with sod ingestion.

Ingestion of garden vegetables grown in drainage ditch soils results in cancer risks of 3 x 10 -5 for the
average case and 1 x 10 -4 for the RME scenario for adults.

The total incremental cancer risks through all exposure routes and across all receptors to the surface
soils in the drainage ditch are 7 x 10 -5 for the average scenario and 2 x 10 -4 for the maximum
scenario.

Incidental ingestion of drainage ditch soils for adults and children combined, results in a hazard index
of 1.1 for the average scenario and 4.4 for the RME scenario. Although no individual chemical hazard
guotient exceeds 1, both antimony and chromium (for children) have a calculated hazard guotient of 1.
Dermal contact to surface soils for both adults and children combined results in a hazard index of 0.16
for the average case and 0.82 for the RME scenario. The total hazard index for exposure to surface soils
in all pathways for all receptors combined is 1.7 for the average case and 6.9 for the RME scenario.

Estimated lifetime cancer risks associated with ingestion of sediments in the drainage ditch for children
and adults combined, are 2 x 10 -6 for the average case scenario and 1 x 10 -5 for the RME scenario.
Dermal contact with the drainage ditch surface soils for both adults and children combined, result in a
lifetime cancer risk of 4 x 10 -6 for the average case scenario and 1 x 10 -5 for the RME scenario.
Dermal risks were only calculated for Aroclors 1249 and 1254. The total HI for the drainage ditch
sediments for all pathways is 6 x 10 -6 for the average case and 2 x 10 -5 for the RME scenario. The
total hazard index for ingestion and dermal contact with drainage ditch sediments for all receptors
combined is 0.2 for the average case and 0.6 for the RME scenario.

The estimated lifetime cancer risks associated with dermal contact of the surface waters in the drainage
ditch are 9 x 10 -9 for the average case scenario and 2 x 10 -8 for the RME scenario.

The total incremental cancer risks for exposure to the surface water, sediment and soils in the drainage
ditch are 7 x 10 -5 for the average scenario and 2 x 10 -4 for the maximum scenario. After consideration
and review of the conservative nature of the assumptions used in calculating the risk estimates, these
cancer risk estimates are determined to be acceptable and reasonably within the bounds of the EPA's
acceptable risk range of 10 -6 to 10 -4.
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The total hazard index for exposure to all medium in the drainage ditch is 1.9 for the average case and
7.5 for the RME, After review of the conservative nature of the assumptions used in estimating these
risks, these Hi's are considered to be within EPA Region 1 acceptable risk range.

Summary:

There are uncertainties and limitations associated with the BHRA including, data collection, exposure
assessment, toxicity assessment and risk characterization, the details of which are described in Section
2.6.4 of the FS. These uncertainties resulted in the selection of conservative exposure parameters and
model inputs which resulted in conservative estimates of potential site related risks. Because of the
uncertainties, the Fletcher's Paint site Baseline risk Assessment is not an absolute estimate of risks to
human health resulting from exposure at the Fletcher's Paint Site. Rather, it is a conservative analysis
that is a rough measure of the potential for adverse health effects to occur, based on the postulated
exposures scenarios.

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment. Exposure to the following media was determined to exceed EPA's
cancer risk range of concern: surface soils at the Elm Street and

Mill Street locations, subsurface soil at Elm Street Site and the Draper Energy Portion of the Mill
Street Site, and groundwater. The compounds contributing to the majority of the potential cancer risk in
Elm Street and Mill Street soils are PCBs. The compounds contributing to the majority of the potential
cancer risk in ground water are benzene, 1,2-dichloroethane, trichloroethene, and PCBs.

As can be seen in the Risk Summary Table, which follows this discussion, hazard indices exceed 1 for
surface soils at the Elm Street and Mill Street Sites, subsurface soils at the Elm Street Site, for total
exposures to surface soil near the drainage ditch (RME case scenario) and for ground water ingestion in
the future. The contaminants contributing to the majority of the potential noncarcinogenic effects in
ground water are ethylbenzene, manganese and PCBs.

ECOLOGICAL RISK ASSESSMENT

A Preliminary Ecological Risk Assessment was conducted as part of the Phase 1A RI to assess the potential
site contamination risks to the dominant biota and major ecosystems found in the vicinity of the Site.
The primary objectives of the preliminary ecological risk assessment were to document the baseline
ecological conditions at the Site and in the surrounding local study area, and evaluate the need for
supplemental field studies to fully characterize the biological communities of the study area that may
have been or could have been affected by site-derived contamination. The findings of this study were
reported as part of the Phase 1A RI, in the March 15, 1994 Final Report for the Preliminary Ecological
Risk Assessment at the Fletcher's Paint Site.

From a toxicity and bioaccumulation perspective, the contaminants and four exposure zones of greatest
potential ecological concern, and warrant further ecological consideration are:

              •       On-site  surface soils  -  inorganics,  PCBs  and pesticides
                     Mill  Street  Pond -  inorganics,  PCBs,  Pesticides  and PAHS
                     Drainage Ditch  - Inorganics,  PCBs,  Pesticides,  PAHS
              •       Souhegan River  - Inorganics,  PCBs Pesticides and PAHS

As a result of the Preliminary Ecological Risk Assessment Evaluation, the Souhegan River Study area was
separated from the OU1 study area, and will be further investigated as part of OU2 activities. The
conclusion from the Preliminary Ecological Risk Assessment was that there were areas of the site which
held potential for ecological impacts as a result of site-related contamination, and that the potential
risks should be guantified by computing analyte-specific hazard guotients  (HQs) and aggregate hazard
indices (Ms) for each pairing of ecological receptors and exposure zones. As part of the future risk
assessment for the benthic community of the river, a guantitative benthic invertebrate survey was
recommended, together with a characterization of benthic substrate features and sediment contamination,
in order to supplement guantitative risk estimates risk estimates to be developed for the benthic
community, by using NOAA sediment guidelines to calculate inferential risk guotients. Food chain exposure
models were recommended to calculate HQs and His for a selection of aguatic,  wetland, and/or terrestrial
faunal indicator species.  As part of OU2, field studies were completed in 1995 and a Final Ecological
Risk Assessment Report for the Souhegan River was completed in April of 1998.
-------
VII.   DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Response Objectives

Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with all federal and more stringent state environmental
standards, requirements, criteria or limitations unless a waiver is invoked; a requirement that EPA
select a remedial action that is cost-effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies in which treatment which permanently and significantly reduces the volume,
toxicity or mobility pf the hazardous substances is a principal element over remedies not involving such
treatment. Response alternatives were developed to be consistent with these Congressional mandates.

Based on preliminary information relating to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial action objectives were developed to aid in the development and
screening of alternatives. These remedial action objectives were developed to mitigate existing and
future potential threats to public health and the environment. These response objectives were:

       1.   Prevent the ingestion of groundwater contaminated in excess of drinking water standards
            (MCLs/MCLGs) or, in their absence, which produces an incremental cancer risk greater than
            10-6, for each carcinogenic compound. Also prevent ingestion of contaminated groundwater
            which produces an incremental cancer risk level greater than 10 -4 to 10 -6 for all
            carcinogenic compounds together.

       2.   Prevent ingestion of groundwater contaminated in excess of drinking water standards for each
            non-carcinogenic compound which produces a hazard quotient greater than 1 and a total hazard
            index of 1 to 10.

       3.   Restore the groundwater to drinking water standards or, in their absence, the more stringent
            of an incremental cancer risk of greater than 10 -6, for each carcinogenic compound, or a
            hazard quotient of 1 for each non-carcinogenic compound. Also restore the aquifer to the more
            stringent of  (1) a total incremental cancer risk level of 10 -4 to 10 -6 for all carcinogenic
            compounds; or (2) a hazard index of 1 to 10.

       4.   Prevent contact with soil contamination through ingestion or dermal contact which produces an
            incremental cancer risk of greater than 10 -6 for each carcinogenic compound. Also prevent
            dermal contact with and ingestion of contaminated soil which produces a total incremental
            cancer risk level of 10 -4 to 10 -6 for all carcinogenic compounds.

       5.   Prevent contact with soil contamination which, through ingestion or dermal contact, produces
            a hazard quotient greater than 1 for each non-carcinogenic compound and a total hazard index
            of 1 to 10.

       6.   Prevent the leaching of contaminants from the soil to the groundwater that would result in
            groundwater contamination in excess of drinking water standards.

       7.   Prevent or mitigate the release of contaminants to the Souhegan River in excess of surface
            water standards.

B. Technology and Alternative Development and Screening

CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives was developed for the site. With respect to
source control, the RI/FS developed a range of alternatives in which treatment that reduces the toxicity,
mobility, or volume of the hazardous substances is a principal element. This range included an
alternative that removes or destroys hazardous substances to the maximum extent feasible, eliminating or
minimizing to the degree possible the need for long term management, This range also included
alternatives that treat the principal threats posed by the Site but vary in the degree of treatment
employed and the quantities and characteristics of the treatment residuals and untreated waste that must
be managed; alternative(s) that involve little or no treatment but provide protection through engineering
or institutional controls; and a no action alternative.

With respect to groundwater response action, the FS developed a limited number of remedial alternatives
that attain site specific remediation levels within different time frames using different technologies;
-------
and a no action alternative.

As discussed in Chapter 3.4 of the FS, soil and groundwater treatment technologies were identified,
assessed and screened on implementability, effectiveness, and cost. These technologies were combined into
source control  (SC) and management of migration (MOM) alternatives. Chapter 3.4 of the Feasibility Study
presented the remedial alternatives developed by combining the technologies identified in the previous
screening process in the categories identified in Section 300.430(e)  (3) of the National Contingency Plan
("NCP").  The purpose of the initial screening was to narrow the number of potential remedial actions for
further detailed analysis while preserving a range of options. Each alternative was then evaluated in
detail in Chapters 4.2 and 4.3 of the FS.

In summary, of the 30 source control and 39 management of migration remedial alternatives screened in
Chapters 3.4, 35 were retained as possible options for the cleanup of the Site. From this screening,
remedial options were combined, and eight  (8) source control and six  (6) management of migration
alternatives were selected for detailed analysis.

VIII. DESCRIPTION OF ALTERNATIVES

A. Source Control  (SC) Alternatives Analyzed

The source control alternatives analyzed for the Site include:

       SC Alternative 1: No action
       SC Alternative 2: Limited action/Institutional controls
       SC Alternative 3: Containment
       SC Alternative 4: Off -site disposal of soils at a chemical waste landfill
       SC Alternative 5: Off- site incineration
       SC Alternative 6: Thermal desorption
       SC Alternative 7: Stabilization/Solidification
       SC Alternative 8: Solvent Extraction

Each of the eight source control alternatives are summarized below. A more complete, detailed
presentation of each alternative, along with comparison to the nine NCP criteria, are found in Section
4.2 of the FS.

Source Control 1: No-Action

Under this alternative, no actions would be taken to address the threat to public health and the
environment from soil contamination found at the Site. The no action alternative would not result in the
attainment of the interim cleanup levels for soils or groundwater in the near future. The contaminated
soils would remain a threat to human health through dermal contact and ingestion for a very long time,
greater than 100 years, and until natural processes reduce the concentrations of the contaminants in the
soil. Contaminants would continue to migrate to surface waters, ground water and sediments, and exposures
could take place as the temporary cover at Elm Street erodes without continued maintenance.

The only costs associated with this alternative would be for mandated reviews every five years, to
determine if the alternative remains protective to human health; this alternative would not provide
protection for human health or the environment. EPA must include a no action alternative to serve as a
baseline against which to compare the other alternatives.

Estimated time for design and construction:       None

Estimated time for operation:                     Indefinitely, however monitoring costs are
                                                  estimated over 30 years
Estimated capital cost (1996 dollars):            $ 0

Estimated O&m (present worth):                    $ 4,000 per year for 30 years

Estimated total cost sc-1  (present worth for 30   $ 51,000
years at 7% interest):

Source Control 2: Limited Action/Institutional Controls

The implementation of the Limited Action/Institutional Controls alternative would involve taking legal
and physical measures to restrict access to and the use of the Fletcher's Paint Site, repairing and
maintaining the existing temporary caps, as necessary, and conducting long-term monitoring of the soils,
-------
sediments, surface waters and groundwater. Physical measures would include building a fence around both
the Elm Street and Mill Street Sites and utilizing the current fencing as much as possible. Land use
restrictions would have two purposes:

       •       Restricting access to the Fletcher's Paint site in order to prevent direct human exposure
              through dermal contact or ingestion to contaminants in the soil,  and

       •       Restricting future land use at the Fletcher's Paint site to prevent,  or limit,
              residential,  recreational and industrial development and prohibiting excavation,
              drilling,  or otherwise intrusive activities at the Site.

The contaminated soils would remain a threat to human health through dermal contact and ingestion for a
very long time, greater than 100 years, and until natural processes reduce the concentrations of the
contaminants in the soil. Contaminants would continue to migrate to surface waters, ground water and
sediments, and exposures could take place as the temporary cover at Elm Street erodes without continued
maintenance. If imposed, deed restrictions would be retained at the Fletcher's Paint site until future
reviews indicated that the Site no longer posed a human health threat.

Repair and maintenance of the existing caps would also occur under this alternative. The caps, installed
and repaired during several of the previous removal actions at the Site, consist of a permeable liner,
soil, stone dust, and gravel.

Estimated time for design and construction:      1-3 months

Estimated time for operation and                 30 years of long-term monitoring and cap maintenance
maintenance:

Estimated capital cost  (1996 dollars):           $ 96,000

Estimated 0 & m. (present worth):                $ 42,000 per year for 30 years

Estimated total cost sc-2  (present worth for     $ 600,000
30 years at 7% interest):

Source Control-3: Containment

This alternative includes the removal of the top three feet of soil from both the Elm Street and Mill
Street Sites in order to install a cap that would protect human health and the environment by eliminating
exposure to the contaminated soils, promoting drainage, and minimizing infiltration; and which would be
complimentary of the existing natural grade. The actions that would be reguired under this alternative
include:

       •       Removal of the top three feet of contaminated soils for off-site disposal or treatment.

       •       Covering of the remaining highly contaminated soils with a protective,  impermeable cap to
              prevent direct contact with the contaminated soils and to prevent infiltration and the
              leaching of contaminants from the soils into the groundwater in excess of the interim
              cleanup levels.

       •       Installation of a vertical underground barrier,  called a slurry wall,  at the Mill Street
              area  to keep contaminants from migrating away from the Site,  and to reduce the amount of
              groundwater extracted from the Mill Street property and reguiring treatment at the surface.

       •       Installation of an extraction well at the Mill Street Site,  within the slurry wall area,  to
              prevent groundwater from migrating out of the contained area.  Operation of a groundwater
              treatment system to treat the extracted groundwater.  (Costs for this treatment would be
              considered with the groundwater "MOM" alternatives).

       •       Disposal of the excavated soils off-site to either an approved hazardous waste landfill or
              an approved hazardous waste incinerator.

       •       The re-routing of the Town's storm water drainage system around the capped areas of the
              Elm Street Site.

       •       Use of institutional controls such as deed restrictions to restrict the use of the Site,  to
              prevent activities that could damage the integrity of the cap and allow direct contact with
              the soil contamination under the cap.
-------
The cap required, a Resource Conservation and Recovery Act ("RCRA") Subtitle C Cap. would consist of
several layers of natural (sand, gravel, clay) and man-made materials (synthetic liners) to form an
impermeable barrier over the contamination to prevent infiltration. A slurry wall would be installed
around the Mill Street Site to keep groundwater from mounding and carrying contamination away from the
Site: While not required, the slurry wall would be cost-effective at limiting the amount of groundwater
removed from the area over time, which would then require treatment at the surface. The excavated soil
would be transported by rail car either to an approved hazardous waste landfill or approved hazardous
waste incinerator, Future Site access and use would be restricted to prevent damage to the cap that could
release contamination or allow direct contact with the contamination.

  Estimated time for design and         13 months
  construction:

  Estimated time for operation:         30 years

  Estimated capital cost (1996$):       $ 6.7 million for off-site disposal and $13.1 million
                                        for off-site incineration of the excavated soils

  Estimated 0 & m (Present Worth):      $ 42,000 per year for 30 years

  ESTIMATED TOTAL COST SC-3             $ 7.2 million, - with off-site landfilling of excavated
 (Present worth for 30 years at 7%      soils; and
 interest):                             $ 13.6 million with off-site incineration of the
                                        excavated soils.

SC Alternative 4: Off-Site Disposal of Soils at a Chemical Waste Landfill

Under this alternative, soils would be excavated which exceed soil cleanup levels for risk-based
protection at both Elm and Mill Street sites. The excavated soils would be disposed of at a Toxic
Substances Control Act (TSCA) approved landfill and/or a RCRA Subtitle D landfill  (depending upon PCB
concentration). Containment of the remaining contaminated soils at the Site would be consistent with one
of three options detailed for the long-term protection of groundwater. The existing storm sewer at the
Elm Street Site would be replaced and/or re-routed and clean soils would be used to backfill the Site
prior to surface restoration consistent with the expected future uses of the Sites, Specifically, the
activities included under this alternative include:

       •      Removal  of  the surface soils at both Elm and Mill Street Sites  in the top foot (0-1 foot)
              wherever PCB  concentrations are greater than 1  mg/kg.

       •      At the Elm Street Site,  removal of the subsurface soils to a depth of 10 feet (1  to 10  feet)
              wherever PCB  concentrations are greater than 1  mg/kg.

       •      For all  soils  deeper than one foot at the Mill  Street Site,  and deeper that 10 feet at  the
              Elm Street  Site,  three long-term management options were developed for the long-term
              protection  of  the groundwater:

Option 1, Containment and Capping - Concentrations remaining in the soils would be greater than 500 mg/kg
PCB.

Elm Street - Leave the remaining contaminated soils in place; backfill to a depth that would allow
construction of an impermeable RCRA composite cap; construct an RCRA, Subtitle C composite cap to
minimize infiltration of precipitation through the contamination and into the groundwater; and, implement
institutional controls as necessary to allow for future limited access to the site.

Mill Street - Leave the remaining contaminated soils in place; backfill to a depth that would allow
construction of an impermeable RCRA composite cap; construct a RCRA Subtitle C composite cap to minimize
infiltration of precipitation through the contamination and into the ground water; construct a hydraulic
containment system consisting of a ground water extraction well and a slurry wall; and, implement
institutional controls as necessary to allow for future limited access to the site. Groundwater
extraction from within the slurry wall system would be considered part of the management of migration
alternative selected to complement the source control action.

Option 2, Partial Removal and Capping - Concentrations remaining in the soils would be less than 500
mg/kg PCB.

Elm Street - Excavate all PCB-contaminated soils with concentrations greater than 500 mg/kg PCBs and
dispose of them in an off-site TSCA-approved chemical landfill. Over the remaining soils, backfill to a
-------
depth which would allow construction of an impermeable single-barrier cap; and, construct a
single-barrier cap (RCRA Subtitle D) to minimize infiltration of precipitation through the contamination
and into the ground water.

Mill Street - Excavate all PCB-contaminated soils with concentrations greater than 500 mg/kg and dispose
of in an off-site TSCA-approved chemical landfill. Over the remaining soils, backfill to a depth which
would allow construction of an impermeable single-barrier cap; construct a single-barrier cap (RCRA
Subtitle D) to minimize infiltration of precipitation through the contamination and into the groundwater;
construct a hydraulic containment system consisting of a groundwater extraction well and a slurry wall;
and, implement institutional controls as necessary to allow for future limited access to the site.
Groundwater extraction from within the slurry wall system would be considered part of the management of
migration alternative selected to complement the source control action.

Option 3, Additional Excavation and Soil Cover - Concentrations remaining in the soils would be less than
those capable of leaching into the ground water and causing future contamination in excess of the PCB
ground water standard.

Elm Street - Excavate all soils to a concentration at which leaching models and/or column testing show
that infiltration through the remaining PCB soil concentrations will not result in future ground water
concentrations in excess of the 0.5 Ig/1 Maximum Contaminant Level (MCL) groundwater concentration for
PCBs.  For the Elm Street Site, 100 mg/kg PCB is used as the value representing the PCB concentration
which can remain in the subsurface and not impact the groundwater in the future above drinking water
standards. Backfill the excavation with clean fill.

Mill Street - Excavate all soils to a concentration of 1 mg/kg PCB, or to a concentration at which
leaching models and/or column testing show that infiltration through the remaining PCB soil
concentrations will not result in future ground water concentrations in excess of the 0.5 Ig/1 MCL ground
water concentration for PCBs. Backfill the excavation with clean fill.
              Disposal of excavated soils off-site by rail car to a TSCA-approved landfill (for soils with
              PCB concentrations greater than 50 mg/kg)  and/or a RCRA Subtitle D landfill (for soils  with
              PCB concentrations less than 50 mg/kg),  depending upon PCB concentration.

              Backfill of the excavated areas with clean fill and containment of both Elm Street and
              Mill Street,  consistent with one of the three options described above.

              Restoration of the surface of the Sites,  consistent with the expected future uses.

              Placement of restrictions on the future use of the Site,  to prevent damage to cover
              materials;  and implementation of long-term monitoring consistent with the  institutional
              controls and long-term monitoring described in detail in SC-2.
Estimated time for design and construction:
Estimated time for operation:
Option
Capital Cost
 (1996$)
  O&M

 Annual
 Cost
24 to 29 months,  depending on the
containment option selected

30 years (long-term monitoring).

Cost         (1996$)        SC-4 Total
                        Net Present
Years of     O&M Net    Value*
Operation    Present    (1996$)
             Value
Base Case

Option 1
  Elm Street
  Elm Street

Option 2
  Elm Street
  Elm Street
$11,122,700
$510,600
$375,200
$1,248,000
$2,021,900
$36,830
$5,200
$5,200
$5,200
$5,200
                                                30
30
30
30
30
             $472,897   $11,595,597
$66,768
$66,768
$66,768
$66,768
$577,368
$441,968
$1,314,768
$2,088,699
Option 3
  Elm Street
  Elm Street
$2,786,600
$4,487,900
                                      $2,786,600
                                      $4,487,900
-------
NOTE: * - The Base Case Costs and the costs for one of the "Containment Options" for both Elm Street and
Mill Street are added to determine the Total Present Value of the Alternative for the selected criteria.
The containment option selected for Elm Street and Mill street do not have to be the same. Dewatering
costs ($500,000) would also need to be added if groundwater treatment is not selected as part of the
management of migration portion of the remedy.

SC Alternative 5:  Off- Site Incineration

This alternative involves the same activities and long-term management options as described in
alternative 4 above, except that the excavated materials would be sent to an off-site hazardous materials
incinerator instead of an off-site chemical waste landfill.
Soils that exceed soil cleanup levels for risked-based protection to a depth of one foot at the Mill
Street Site and down to 10 feet at the Elm Street Site would be excavated and sent to a TSCA-approved
incinerator for treatment and disposal. The existing Elm Street storm sewer would be re-routed and/or
replaced; and, the Site would be backfilled with clean fill. The three long-term management options
presented in Alternative 4 would be the same, with the exception that any excavated soils would be sent
to an incinerator rather than disposed of at a landfill.

Institutional controls restricting the future uses of the Site to prevent damage to the containment
materials would be implemented consistent with those previously described in Alternative SC-2.
Estimated time for design and construction:
Estimated time for operation:
Option
Capital Cost
(1996$)
 O&M

 Annual
 Cost
22 to 27 months,  depending on the
containment option selected

30 years (long-term monitoring)

Cost            (1996$)
                                                Years of
                                                Operation
                                                O&M Net
                                                Present
                                                Value
SC-5 Total
Net Present
   Value
(1996$)
Base Case
$23,834,100
$36,830
                                                 30
                $472,897
 $24,306,997
Option 1
  Elm Street    $506,000
  Mill Street   $375,100
                   $5,200
                   $5,200
              30
              30
                $66,768
                $66,768
   $572,768
  $441,!
Option 2
  Elm Street    $2,606,500
  Mill Street   $4,877,400
Option 3
  Elm Street
  Mill Street
$7,477,100
$8,974,300
                   $5,200
                   $5,200
              30
              30
                $66,768
                $66,768
  $2,673,268
  $4,944,168
                                                 $7,477,100
                                                 $8,974,300
NOTE:* - The Base Case Costs and the costs for one of the "Containment, Options" for both Elm Street and
Mill Street are added to determine the Total Present Value of the Alternative for the selected criteria.
The containment option selected for Elm Street and Mill street do not have to be the same. Dewatering
costs  ($500,000) would also need to be added if groundwater treatment is not selected as part of the
management of migration portion of the remedy.

SC Alternative 6: Thermal Desorption
The use of Thermal Desorption to reach cleanup levels in the Site soils is currently EPA's preferred
alternative. The discussion of the preferred alternative includes details which differ slightly from the
SC-6- thermal desorption alternative detailed in the FS and in the Proposed Plan. The FS alternative for
SC-6 Thermal Desorption included the same activities and long-term management options as described in
alternative SC-4 above, except that the excavated soils would be treated on-site by ex-situ(above ground)
thermal desorption instead of being sent off site to a landfill  (SC-4)  or incinerator (SC-5).

Under the SC-6 alternative, soils that exceed soil cleanup levels for risked-based protection to a depth
of one foot at the Mill Street Site and down to 10 feet at the Elm Street Site would be excavated and
treated by on-Site, ex-situ thermal desorption to remove PCB contamination. The treated soils would be
returned to the Site. The PCB concentrate would be incinerated off-site at a TSCA-approved incinerator.
Any soils that cannot be treated by thermal desorption would be disposed of off-site in a TSCA-approved
-------
chemical waste landfill or a RCRA-approved Subtitle D landfill (depending upon PCB concentration).  The
existing Elm Street storm sewer system would be re-routed and/or replaced. The three long-term management
options presented in Alternative SC-4 would be the same,  with the exception that any excavated soils
would be treated by the on-Site thermal desorber rather than disposed of at a landfill or incinerator

Institutional Controls restricting the future uses of the Site to prevent damage to the containment
materials would be implemented consistent with those previously described in Alternative SC-2.
Estimated time for design and construction:


Estimated time for operation:


Option
Capital Cost
(1996$)
O&M
                                     Annual
                                     Cost
26 to 31 months,  depending on the
containment option selected

30 years (long-term monitoring)

Cost           (1996$)         SC-6 Total
                              Net Present
Years of        O&M Net       Value
Operation       Present       (1996$)
                Value
Base Case
$10,920,700
Option 1
  Elm Street   $506,000
  Mill Street  $375,100
Option 2
  Elm Street   $1,099,700
  Mill Street  $1,680,600
Option 3
  Elm Street
  Mill Street
$2,193,200
$4,957,600
$36,830
                       $5,200
                       $5,200
                       $5,200
                       $5,200
                                                     30
                30
                30
                30
                30
                $472,897
                $66,768
                $66,768
                $66,768
                $66,768
$11,393,597
$572,768
$441,868
$1,166,468
$1,747,368
                                             $2,193,200
                                             $4,957,600
NOTE: * - The Base Case Costs and the costs for one of the "Containment Options" for both Elm Street and
Mill Street are added to determine the Total Present Value of the Alternative for the selected criteria.
The containment option selected for Elm Street and Mill street do not have to be the same. Dewatering
costs would also need to be added if groundwater treatment is not selected as part of the management of
migration portion of the remedy.

SC Alternative 7: Stabilization/Solidification

This alternative would involve the same steps and long-term management options as alternative SC-4 except
that excavated soil would be treated through stabilization/solidification technologies prior to placement
back into the Site.
Under this alternative, the soils that exceed soil cleanup levels for risked-based protection to a depth
of one foot at the Mill Street Site and down to 10 feet at the Elm Street Site would be excavated and
treated by on-Site solidification/ stabilization to contain the PCB contamination. Solidification/
Stabilization would occur when a binding agent, such as Portland cement,  asphalt,  or fly ash, is added to
the contaminated soil to encase the contaminants,  forming a solid material.   The solidified soils would
be returned to the Site and an engineered,  impermeable cap would be constructed over the solidified soils
to limit access to the soils and prevent infiltration of precipitation.  Any soils  that could not be
treated by solidification/ stabilization would be disposed of off-site in a TSCA-approved chemical waste
landfill or a RCRA-approved Subtitle D landfill (depending upon PCB concentration).  The existing Elm
Street storm sewer would be re-routed and/or replaced. The three long-term management options presented
in Alternative SC-4 would remain the same,  with the exception that any excavated soils would be treated
by the on Site solidification/stabilization unit rather than disposed of at a landfill.

Institutional controls restricting the future uses of the Site to prevent damage to the cap materials
would be implemented consistent with those previously described in Alternative SC-2.
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Estimated time for design and construction:
Estimated time for operation:
Option
     Capital Cost
     (1996$)
   O&M

   Annual
   Cost
24 to 29 months,  depending on the
containment option selected

30 years (long-term monitoring)

                (1996$)
Cost

Years of
Operation
                                                                       O&M Net
                                                                       Present
                                                                       Value
Total Net
Present
Value
(1996$)
Base Case

Option 1
  Elm Street
  Mill Street

Option 2
  Elm Street
  Mill Street

Option 3
  Elm Street
  Mill Street
    $7,283,100
    $510,600
    $376,100
    $860,800
    $1,191,200
    $1,581,600
    $3,122,300
   $36,830
   $5,200
   $5,200
   $5,200
   $5,200
                                                       30
 30
 30
 30
 30
                 $472,897
                 $66,768
                 $66,768
                 $66,768
                 $66,768
                                  $7,755,997
 $577,368
 $442,868
 $927,568
 $1,2457,968
                                                  $1,581,600
                                                  $3,122,300
NOTE: * - The Base Case Costs and the costs for one of the "Containment Options" for both Elm Street and
Mill Street are added to determine the Total Present Value of the Alternative for the selected criteria.
The containment option selected for Elm Street and Mill street do not have to be the same. Dewatering
costs would also need to be added if groundwater treatment is not selected as part of the management of
migration portion of the remedy.
SC Alternative
  Solvent Extraction
This alternative would involve the same activities and long-term management options as described in
alternative SC-4 above, except that the excavated materials would be treated on-site by solvent
extraction, instead of being transported to an off-site chemical waste landfill.

Soils that exceed soil cleanup levels for risked-based protection to a depth of 1 foot at the Mill Street
Site and down to 10 feet at the Elm Street Site would be excavated and treated on-site using solvent
extraction. Solvent extraction of the contaminated soils involves adding a liguid solvent to wash PCBs
from the excavated soil. The washing process separates contaminates into treated solids,  water and the
solvent containing the contamination. The treated soils would be placed back into the Site.  The
concentrated contaminants would be sent off-site to an approved hazardous waste incinerator. Any soils
that cannot be treated by solvent extraction would be disposed of off-site in a TSCA-approved chemical
waste landfill or a RCRA-approved Subtitle D landfill  (depending upon PCB concentration).  The existing
Elm Street storm sewer would be re-routed and/or replaced. The three long-term management options
presented in Alternative 4, would be the same,  with the exception that any excavated soils would be
treated using solvent extraction rather than disposed of at a landfill.

Institutional controls restricting the future uses of the Site to prevent damage to the containment
materials would be implemented consistent with those previously described in Alternative SC-2.
Estimated time for design and construction:
Estimated time for operation:


Option
                                        29 to 35 months,  depending on the
                                        containment option selected

                                        30 years (long-term monitoring)
 Capital Cost
 (1996$)
O&M

Annual
Cost
Cost

Years of
Operation

(1996$)

O&M Net
Present
Value
SC-8 Total
Net Present
Value
(1996$)

Base Case
$10,386,500
$36,830
                                                          30
                 $472,897
                               $10,859,397
-------
Option 1
  Elm Street    $510,600              $5,200              30           $66,769       $577,269
  Mill Street   $375,100              $5,200              30           $66,768       $441,:
Option 2
  Elm Street    $1,064,900            $5,200              30           $66,768       $1,131,669
  Mill Street   $1,611,000            $5,200              30           $66,768       $1,677,768

Option 3
  Elm Street    $2,077,900             -                                -            $2,077,900
  Mill Street   $4,696,500             -                                -            $4,696,500

* - The Base Case Costs and the costs for one of the "Containment Options" for both Elm Street and Mill
Street are added to determine the Total Present Value of the Alternative for the selected criteria. The
containment option selected for Elm Street and Mill street do not have to be the same.  Dewatering costs
would also need to be added if groundwater treatment is not selected as part of the management of
migration portion of the remedy.

B.     Management of Migration  (MOM)  Alternatives Analyzed

Management of Migration alternatives address contaminants that have migrated into and with the
groundwater from the original source of contamination.  At the Site, contaminants have migrated from the
Mill Street and Elm Street properties into the groundwater and to the Souhegan River. The Management of
Migration alternatives evaluated for the Site include:

     MOM Alternative 1: No action
     MOM Alternative 2: Limited action
     MOM Alternative 3: Air Stripping
     MOM Alternative 4: Granular Activated Carbon
     MOM Alternative 5: U/V Oxidation
     MOM Alternative 6: Treat at Milford Wastewater Treatment Facility

Each of the six management of migration alternatives are summarized below. A more complete, detailed
presentation of each alternative, along with comparison to the nine NCP criteria, are found in Section
4.3 of the FS.

MOM-1: No-Action

No activity would occur under this alternative. Contaminants would remain in the groundwater and slowly
move through groundwater and discharge into the Souhegan River. If soils are addressed under one of the
source control alternatives described previously (except no action and limited action) ,  thereby
eliminating or controlling the source of the groundwater contamination, then the VOC contamination in the
overburden groundwater would persist for 20 to 25 years, while the PCB contamination in the overburden
groundwater would persist for more than 100 years.  Groundwater restoration time frames are expected to
take even longer within the bedrock,  and are dependent on the full extent of the contamination within the
bedrock. If soils are not addressed,  thereby leaving the source of the groundwater contamination in
place, the time frame for groundwater restoration to drinking water standards would be much longer. EPA
must include a no action alternative to serve as a baseline against which to compare the other
alternatives.

Estimated time for design and construction:         No Construction Activity

Estimated time for operation:                           30+ years
                                                    (5 year reviews)

Estimated capital cost (1996 dollars):               $0

Estimated 0 & m (present worth):                    $4,000 per year

Estimated total cost mom-1 (present worth over 30   $51,000
years at 7% interest):

MOM-2: Limited Action/ Institutional Controls

This alternative involves the use of monitored natural attenuation and institutional controls to reach
cleanup levels in the groundwater at the Site. This is EPA's preferred alternative. Under this
-------
alternative, restrictions would be imposed on the use of the groundwater as a drinking water supply for
as long as drinking water standards are exceeded. No treatment would occur under this alternative.
Contaminants would remain in the groundwater, slowly moving through groundwater to either be reduced to
cleanup levels through natural processes or discharged into the Souhegan River. If soils are addressed
under one of the source control alternatives described previously (except no action and limited action),
thereby eliminating or controlling the source of the groundwater contamination, then the VOC
contamination in the overburden groundwater would persist for 20 to 25 years, while the PCB contamination
in the overburden groundwater would persist for more than 100 years. Groundwater restoration time frames
are expected to take even longer within the bedrock, and are dependent on the full extent of the
contamination within the bedrock. If soils are not addressed, thereby leaving the source of the
groundwater contamination in place, the time frame for groundwater restoration to drinking water
standards would be much longer.

Institutional controls would be implemented in the form of restrictions imposed on the use of the
groundwater as a drinking water supply as long as concentrations in the groundwater remain above drinking
water standards. Long-term monitoring of the groundwater would be conducted to determine if contaminant
concentrations are declining, and to ensure that the contamination is not migrating away from the Site
area or impacting the Souhegan River. Monitoring would continue for as long as the contamination levels
exceeded the Interim Cleanup Levels. Five (5) year reviews would be conducted to ensure that the
restrictions imposed on the use of the groundwater were effective in controlling the human health risk
posed by ingestion of the contaminated groundwater.

Estimated time for design and construction:               No Construction Activity

Estimated time for operation and maintenance:            30+ years
                                                         (5 year reviews)

Estimated capital cost (1996 dollars):                    $0

Estimated 0 & m (present worth):                          $200,000 per year

Estimated total cost mom-2  (present worth over 30        $2,55 million
years at 7% interest):

MOM-3: Groundwater Treatment using Air Stripping

Under this alternative, groundwater would be pumped from several site locations to a central treatment
unit. The contaminated groundwater would be treated with an on-site air-stripping tower. Air stripping
occurs when air is forced through contaminated waters, and the contamination moves from the water into
the air. The captured air emissions are then sent through a filter system (granular activated carbon)
that collects the volatile organic chemicals. The spent filter would be sent off-site for recycling or
disposal. The treated water would be discharged to the Souhegan River.

Institutional controls would be implemented in the form of restrictions imposed on the use of the
groundwater as a drinking water supply as long as concentrations in the groundwater remain above drinking
water standards. Long-term monitoring of the groundwater would be conducted to determine if the
contamination levels are decreasing, are migrating away from the site area or impacting the Souhegan
River. Monitoring would continue for as long as the contamination levels exceeded the interim cleanup
levels. Five (5) year reviews would be conducted to ensure that the restrictions imposed on the use of
the groundwater were effective in controlling the human health risk posed by ingestion of the
contaminated groundwater.

The time frame for the groundwater to reach the cleanup levels is dependent on the source control action
selected and implemented. The time to reach groundwater cleanup levels using a groundwater extraction
system was estimated using a MODFLOW-based model utilizing groundwater concentrations and the desired
cleanup levels. Various pumping rates were also analyzed. If the contaminated soils are addressed under
one of the source control alternatives described previously  (except no action and limited action),
thereby eliminating or controlling the source of the groundwater contamination, then, the VOCs in the
groundwater in the overburden, may reach cleanup levels in 5 to 10 years. While the time frame cannot be
estimated for TCB and PCBs using this model, they are expected to take many more years to reach their
groundwater cleanup levels, and could take up to 100 years depending on the ability of these contaminants
to move through the aguifer and be captured by the treatment system. Since PCBs and to a lesser extent
TCB are more resistant to the flow of groundwater, the pump and treat alternative has a much lower impact
in the removal of those types of contaminants than for the more readily removed contaminants at the Site
(VOCs). PCBs, while not typically mobile in groundwater, may move with the particulate materials also
found in the groundwater at the Mill Street Site. Any mobile PCB material would be removed readily with
the VOCs during the pump and treat operation.
-------
If the contaminated soils are not addressed, thereby leaving the source of the groundwater contamination
in place, the time frame for groundwater restoration to drinking water standards would be greater than
100 years,

Future studies will be undertaken during design, to further investigate the groundwater contamination in
the bedrock and the impacts of the contamination on the ability of and the estimated time frame of the
groundwater within the bedrock to reach drinking water standards in the future. Regardless, groundwater
contamination in the bedrock would be expected to take significantly longer to reach cleanup levels, as
compared to the overburden.

Estimated time for design and construction:       No Construction Activity

Estimated time for operation and maintenance:     10 years (operation of the pump and
                                                  treat system in the overburden)

Estimated capital cost  (1996 dollars):            $490,000 per year

Estimated 0 & m (present worth):                   $450,000 per year

Estimated total cost mom-3  (present worth over 30 $3.77 million
years at 7% interest):

MOM-4: Groundwater Treatment using Granular Activated Carbon

Under this alternative, groundwater would be pumped from several site locations to a central treatment
unit. The contaminated groundwater would be treated by filtering the groundwater through granular
activated carbon.  Chemicals cling to the surface of the carbon material, thereby removing contaminants
from the water. The spent carbon can then be sent off-site for recycling or disposal. The treated water
would be discharged to the Souhegan River.

Institutional controls would be implemented in the form of restrictions imposed on the use of the
groundwater as a drinking water supply as long as concentrations in the groundwater remain above drinking
water standards. Long-term monitoring of the groundwater would be conducted to determine if the
contamination levels are decreasing, are migrating away from the site area or impacting the Souhegan
River. Monitoring would continue for as long as the contamination levels exceeded the interim cleanup
levels. Five  (5) year reviews would be conducted to ensure that the restrictions imposed on the use of
the groundwater were effective in controlling the human health risk posed by ingestion of the
contaminated groundwater.

The time frame for the groundwater to reach the cleanup levels is dependent on the source, control action
selected and implemented. The time to reach groundwater cleanup levels using a groundwater extraction
system was estimated using a MODFLOW-based model utilizing groundwater concentrations and the desired
cleanup levels. Various pumping rates were also analyzed. If the contaminated soils are addressed under
one of the source control alternatives described previously (except no action and limited action),
thereby eliminating or controlling the source of the groundwater contamination, then, the VOCs in the
groundwater in the overburden may reach cleanup levels in 5 to 10 years. While the time frame cannot be
estimated for TCB and PCBs using this model, they are expected to take many more years to reach their
groundwater cleanup levels, and could take up to 100 years depending on the ability of these contaminants
to move through the aguifer and be captured by the treatment system. Since PCBs and to a lesser extent
TCB are more resistant to the flow of groundwater, the pump and treat alternative has a much lower impact
in the removal of those types of contaminants than for the more readily removed contaminants at the Site
(VOCs). PCBs, while not typically mobile in groundwater, may move with the particulate materials also
found in the groundwater at the Mill Street Site. Any mobile PCB material would be removed readily with
the VOCs during the pump and treat operation.

If the contaminated soils are not addressed, thereby leaving the source of the groundwater contamination
in place, the time frame for groundwater restoration to drinking water standards would be greater than
100 years.

Future studies will be undertaken, to further investigate the contamination in the bedrock and the
impacts of the contamination on the ability of and the estimated time frame of the groundwater within the
bedrock to reach drinking water standards in the future. Regardless, groundwater contamination in the
bedrock would be expected to take significantly longer to reach cleanup levels, as compared to the
overburden.
-------
                                                           No Construction Activity

                                                           10 years (operation of the pump and
                                                           treat system in the overburden)

                                                           $370,000 per year

                                                           $480,000 per year

                                                           $3.84 million
Estimated time for design and construction:

Estimated time for operation and maintenance:


Estimated capital cost (1996 dollars):

Estimated 0 & m  (present worth):

Estimated total cost mom-4  (present worth over 30
years at 7% interest):

MOM-5: Groundwater Treatment using U/V Oxidation

Under this alternative, groundwater would be pumped from several site locations to a central treatment
unit. The contaminants in the groundwater would then be destroyed by exposing the contaminated
groundwater to ultraviolet light and chemicals such as ozone and peroxide. The treated water would be
discharged to the Souhegan River.

Institutional controls would be implemented in the form of restrictions imposed on the use of the
groundwater as a drinking water supply as 16ng as concentrations in the groundwater remain above drinking
water standards. Long-term monitoring of the groundwater would be conducted to determine if the
contamination levels are decreasing, are migrating away from the site area or impacting the Souhegan
River. Monitoring would continue for as long as the contamination levels exceeded the interim cleanup
levels. Five  (5) year reviews would be conducted to ensure that the restrictions imposed on the use of
the groundwater were effective in controlling the human health risk posed by ingestion of the
contaminated groundwater.

The time frame for the groundwater to reach the cleanup levels is dependent on the source control action
selected and implemented. The time to reach groundwater cleanup levels using a groundwater extraction
system was estimated using a MODFLOW-based model utilizing groundwater concentrations, and the desired
cleanup levels. Various pumping rates were also analyzed. If the contaminated soils are addressed under
one of the source control alternatives described previously (except no action and limited action),
thereby eliminating or controlling the source of the groundwater contamination, then the VOCs in the
groundwater in the overburden may reach cleanup levels in 5 to 10 years. While the time frame cannot be
estimated for TCB and PCBs using this model, they are expected to take many more years to reach their
groundwater cleanup levels, and could take up to 100 years depending on the ability of these contaminants
to move through the aguifer and be captured by the treatment system. Since PCBs and to a lesser extent
TCB are more resistant to the flow of groundwater, the pump and treat alternative has a much lower impact
in the removal of those types of contaminants than for the more readily removed contaminants at the Site
(VOCs). PCBs, while not typically mobile in groundwater, may move with the particulate materials also
found in the groundwater at the Mill Street Site. Any mobile PCB material would be removed readily with
the VOCs during the pump and treat operation.

If the contaminated soils are not addressed, thereby leaving the source of the groundwater contamination
in place, the time frame for groundwater restoration to drinking water standards would be greater than
100 years.

Future studies will be undertaken, to further investigate the contamination in the bedrock and the
impacts of the contamination on the ability of and the estimated time frame of the groundwater within the
bedrock to reach drinking water standards in the future. Groundwater contamination in the bedrock would,
however, be expected to take significantly longer to reach cleanup levels, as compared to the overburden.
Estimated time for design and construction:

Estimated time for operation and maintenance:


Estimated capital cost (1996 dollars):

Estimated 0 & m  (present worth):

Estimated total cost mom-5 (present worth over 30
years at 7% interest):
                                                         No Construction Activity

                                                         10 years (operation of the pump and
                                                         treat system in the overburden)

                                                         $620,000 per year

                                                         $440,000 per year

                                                         $3.82 million
-------
MOM-6: Groundwater Treatment at the Milford Water Treatment Facility

Under this alternative, groundwater would be pumped from several site locations to the Milford Publicly
Owned Treatment Works  (POTW) for treatment. The treated water would be discharged to the Souhegan River.
At this time, it is understood that the Milford POTW may not be able to accept the contaminated
groundwater from the Site due to the chlorine-containing compounds. However, this alternative was
developed and included for review should the future conditions change and discharge from the Site to the
POTW be allowed.

Institutional controls would be implemented in the form of restrictions imposed on the use of the
groundwater as a drinking water supply as long as concentrations in the groundwater remain above drinking
water standards. Long-term monitoring of the groundwater would be conducted to determine if the
contamination levels are decreasing, are migrating away from the site area or impacting the Souhegan
River. Monitoring would continue for as long as the contamination levels exceeded the interim cleanup
levels. Five  (5) year reviews would be conducted to ensure that the restrictions imposed on the use of
the groundwater were effective in controlling the human health risk posed by ingestion of the
contaminated groundwater.

The time frame for the groundwater to reach the cleanup levels is dependent on the source control action
selected and implemented, The time to reach groundwater cleanup levels using a groundwater extraction
system was estimated using a MODFLOW-based model utilizing groundwater concentrations and the desired
cleanup levels. Various pumping rates were also analyzed. If the contaminated soils are addressed under
one of the source control alternatives described previously (except no action and limited action),
thereby eliminating or controlling the source of the groundwater contamination, then, the VOCs in the
groundwater in the overburden may reach cleanup levels in 5 to 10 years. While the time frame cannot be
estimated for TCB and PCBs using this model, they are expected to take many more years to reach their
groundwater cleanup levels and could take up to 100 years depending on the ability of these contaminants
to move through the aguifer and be captured by the treatment system. Since PCBs and to a lesser extent
TCB are more resistant to the flow of groundwater, the pump and treat alternative has a much lower impact
in the removal of those types of contaminants than for the more readily removed contaminants at the Site
(VOCs). PCBs, while not typically mobile in groundwater, may move with the particulate materials also
found in the groundwater at the Mill Street Site. Any mobile PCB material would be removed readily with
the VOCs during the pump and treat operation.

If the contaminated soils are not addressed, thereby leaving the source of the groundwater contamination
in place, the time frame for groundwater restoration to drinking water standards would be greater than
100 years.

Future studies will be undertaken, to further investigate the contamination in the bedrock and the
impacts of the contamination on the ability of and the estimated time frame of the groundwater within the
bedrock to reach drinking water standards in the future. Regardless, groundwater contamination in the
bedrock would be expected to take significantly longer to reach cleanup levels, as compared to the
overburden.

Estimated time for design and construction:              No Construction Activity

Estimated time for operation and maintenance:            10 years  (operation of the pump and
                                                         treat system in the overburden)

Estimated capital cost (1996 dollars):                   $620,000 per year

Estimated 0 & M (present worth):                         $310,000 per year

Estimated total cost MOM-6  (present worth over 30        $2.85 million
years at 7% interest):

IX.       SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1)  of CERCLA presents several factors that at a minimum EPA is reguired to consider in its
assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates nine
evaluation criteria to be used in assessing the individual remedial alternatives.

A detailed analysis was performed on the alternatives using the nine evaluation criteria in order to
select a Site remedy, The following is a summary of the comparison of each alternative's strength and
weakness with respect the nine evaluation criteria. These criteria are summarized as follows:
-------
Threshold Criteria

The two threshold criteria described below must be met in order for the alternatives to be eligible for
selection in accordance with the NCP.

1.   Overall protection of human health and the environment addresses whether or not a remedy provides
     adequate protection and describes how risks posed through each pathway are eliminated, reduced or
     controlled through treatment, engineering controls,  or institutional controls.

2.   Compliance with applicable or relevant and appropriate requirements (ARARs) addresses whether or not
     a remedy will meet all of the ARARs or other Federal and State environmental laws and/or provide
     grounds for invoking a waiver.

Primary Balancing Criteria

The following five criteria are utilized to compare and evaluate the elements of one alternative to
another that meet the threshold criteria.

3.   Long-term effectiveness and permanence addresses the criteria that are utilized to assess
     alternatives for the long-term effectiveness and permanence they afford, along with the degree of
     certainty that they will prove successful.

4.   Reduction of toxicity, mobility, or volume through treatment addresses the degree to which
     alternatives employ recycling or treatment that reduces toxicity, mobility, or volume, including how
     treatment is used to address the principal threats posed by the Site.

5.   Short term effectiveness addresses the period of time needed to achieve protection and any adverse
     impacts on human health and the environment that may be posed during the construction and
     implementation period, until cleanup goals are achieved.

6.   Implementability addresses the technical and administrative feasibility of a remedy, including the
     availability of materials and services needed to implement a particular option.

7.   Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as present-worth
     costs.

Modifying Criteria

The modifying criteria are used as the final evaluation of remedial alternatives after EPA has received
public comment on the RI/FS and Proposed Plan.

8.   State acceptance addresses the State's position and key concerns related to the preferred
     alternative and other alternatives, and the State's comments on ARARs or the proposed use of
     waivers.

9.   Community acceptance addresses the public's general response to the alternatives described in the
     Proposed Plan and RI/FS report.

Following the detailed analysis of each individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the nine criteria, was conducted. This comparative
analysis can be found in Tables 4.4.1-1 and 4.4.2.-1 of the Feasibility Study, and attached to the ROD as
Tables 25 and 26.

The section below presents the nine criteria and a brief narrative summary of the alternatives and the
strengths and weaknesses according to the detailed and comparative analysis. Only those alternatives
which satisfied the first two threshold criteria were balanced and modified using the remaining seven
criteria.

Comparative Analysis of Source Control Alternatives

The comparative analysis of the eight source control alternatives is presented below for each of the NCP
evaluation criteria, except State and community acceptance.

Protection of Human Health and the Environment Alternatives SC-4, Off-site Disposal, and SC-5, Off-site
Incineration,  would provide the greatest protection of both current and future human health and the
environment by requiring the excavation of all soils to a depth of 1 foot at Mill Street and down to 10
feet at Elm Street with contaminant concentrations greater than the soil cleanup levels for risk-based
-------
protection. Removal of the contaminated soils to these depths would reduce risks associated with exposure
to contaminants from direct contact with and ingestion of soils. The amount of soils deeper than 1 foot
at Mill Street and 10 feet at Elm Street to be excavated for Alternatives SC-4 and SC-5 would depend upon
which of the three long term management options was selected. All of the excavated soils for these
alternatives would either be disposed of or treated off-site. After excavation, the areas would either be
capped with a RCRA composite cap, capped with a single membrane liner,  or backfilled with clean soil.

Alternatives SC-6, Thermal Desorption, SC-7, Solidification/Stabilization, and SC-8, Solvent Extraction,
would provide slightly less protection of current and future human health and the environment because the
contaminated soils would be treated on-Site and placed back in the excavation after treatment. These
treated soils, while protective of human health and the environment, would have detectable levels of
contamination whereas the clean backfill used for Alternatives SC-4 and SC-5 would not. Treatment of the
contaminated soils to a depth of one foot at Mill Street and down to 10 feet at Elm Street would reduce
risks associated with exposure to contaminants from direct contact with and ingestion of soils.

Alternatives SC-4, SC-5, SC-6, SC-7, and SC-8 would remediate the risks to human health and environment
from the soils at a depth of greater than 1 foot at Mill Street and 10 feet at Elm Street using one of
the following three long-term management options:

       •      Option 1 - Containment and Capping - Construction of a RCRA composite cap over the soils
              contaminated at a depth of greater than one foot at Mill  Street and 10 feet at Elm Street
              and a hydraulic containment system at Mill Street.

       •      Option 2 - Partial Removal and Capping - Excavation of the soils at a depth greater than
              1 foot at Mill Street and 10 feet at Elm Street that contain PCB concentrations greater
              than 500 mg/kg and treatment or disposal with the other soils,  installation of a single
              barrier cap,  and construction of a hydraulic containment  system at Mill Street.

       •      Option 3 - Additional Excavation and Soil Cover - Excavation of the soils at a depth
              greater than 1 foot at Mill Street and deeper than 10 feet at Elm Street that could cause
              an exceedance of the PCB Maximum Contaminant Level ("MCL")  in ground water,  and off-site
              treatment in a TSCA incinerator or disposal in a RCRA landfill.

Option 3 provides the greatest protection of human health and the environment because it removes all the
PCB-contaminated soil that could cause an exceedance of the PCB MCL. By removing the PCB contamination in
soils in excess of that capable of exceeding the PCB MCL. Option 3 limits human exposure to PCB
contamination through the ingestion of ground water in excess of the MCL and prevents migration of the
contamination from the Elm Street Site to the Souhegan River where both human and ecological receptors
might come into contact with it.

Option 2 would provides less protection of human health and the environment than Option 3 because it
would leave soils deeper than 1 foot at Mill Street and 10 feet at Elm Street contaminated with less than
500 mg/kg in place. This option would reguire installation of a single barrier cap over the contamination
at Elm Street and a single barrier cap with a hydraulic containment system at Mill Street. The caps at
both Elm Street and Mill Street would minimize the infiltration of precipitation but soils deeper than 10
feet contaminated with less than 500 mg/kg PCBs would be left slightly above and in contact with the
ground water table. The cap and hydraulic containment system at Mill Street would capture contaminated
ground water but soils deeper than 1 foot contaminated with less than 500 mg/kg PCB would again be left
in place.

Option 1 would provide significantly less protection of human health and the environment than Options 2
or 3 because it would leave all contamination below 1 foot at Mill Street and 10 feet at Elm Street in
place. This option would reguire the installation of a RCRA C composite cap over the remaining
contaminated soils at both Elm Street and Mill Street, as well as a hydraulic containment system at Mill
Street. The cap at Elm Street would minimize the infiltration of precipitation but high concentrations of
PCBs would be left slightly above and in contact with the ground water table. The cap and hydraulic
containment system at Mill Street would capture contaminated ground water, but all soil contaminants
deeper than 1 foot would be left in place

Alternative SC-3, Containment, would protect human health and the environment by reguiring the excavation
of approximately the top three feet of contaminated soils at both the Elm and Mill Street Sites, followed
by the installation of a RCRA C composite cap over the contamination in order to limit human and
environmental contact with the contaminants. A hydraulic containment system would also be installed at
the Mill Street Site. These caps would reduce risks associated with exposure to contaminants from direct
contact with and ingestion of soils. Capping the soil contamination that exceeds the cleanup levels for
risk-based protection reduces the potential for dermal contact with and ingestion of the contaminated
soils. However, as with Options 1 and 2 above, Alternative 3 would leave high concentrations of PCBs
-------
above and in contact with the ground water table. The contaminants could then potentially migrate from
the Site into the river, where they would pose a risk to human health and the environment. Because this
alternative neither removes nor treats the soils deeper than approximately 3 feet, it is considered to be
less protective than Alternatives SC-4 through SC-8.

Alternative SC-2, Limited Action/Institutional Controls, would provide a limited amount of protection to
human health and the environment by reguiring repair of the geotextile membrane that is currently
installed over the contamination and by physically and legally restricting the use of the Site,  to
prevent exposure, access and damage to the cap. Those areas of the Site not currently capped (edges of
the Keyes Drive, the banks of the Souhegan River and the Draper Energy property)  would reguire the
addition of cover soils and regular maintenance to minimize direct contact and incidental ingestion
exposures. The current cap is temporary and would provide neither long-term protection to human health
nor long-term containment of the soils. Contaminants would continue to leach from the soils into the
groundwater and Souhegan River, at levels which would exceed drinking water standards.

The SC-1, No Action alternative would not be protective of human health or the environment The no action
alternative would not reduce or restrict exposures to the contaminated soils and groundwater at the Site.
The risks posed by the contamination to the soils would remain at the current unacceptable levels.
Contaminants would also continue to leach from the soils into the groundwater and Souhegan River, at
levels which would exceed drinking water standards.

Compliance with ARARs. Federal environmental laws from which ARARs for Alternatives SC-3, SC-4,  SC-5,
SC-6, SC-7, and SC-8 are derived include TSCA and RCRA. The comparative analysis in the FS was conducted
before TSCA 40 CFR, Part 761 was revised. The TSCA PCB Spill Policy would be considered  (TBC)  during the
implementation of the remedial action. The state environmental regulations that are applicable or
relevant and appropriate to the alternatives presented above are the State of New Hampshire Air
Regulations and New Hampshire Revised Statutes Annotated, Title XXVI, Chapter 289. Each of these
alternatives would meet the reguirements of these ARARs.

Alternatives SC-1 and SC-2 do not have any federal ARARs because the contaminated soils would be left in
place; however, the TSCA PCB Spill Policy would be considered a TBC reguirement.  The only state
environmental regulation that would be considered an ARAR is the State of New Hampshire Air Regulations
for fugitive dusts during any excavation or repair of the geotextile liner. Alternatives SC-1 and SC-2
would not meet the intent of the TSCA PCB Spill Policy because they would leave PCBs greater than 1 mg/kg
on the Site and would not adeguately protect human health and the environment.

A brief discussion of how the alternatives meet these reguirements follows:

TSCA: The PCB Disposal Reguirements promulgated under TSCA are applicable to Alternatives SC-3 through
SC-8 because these alternatives involve storage and disposal of soils and liguids contaminated with PCBs
in excess of 50 mg/kg. The PCB-contaminated extract produced from the thermal desorption and solvent
extraction treatment  (SC-6 and SC-8)  as well as contaminated soils in Alternatives SC-3 and SC-5 would be
treated off-site in an incinerator meeting the standards of 40 C.F.R. °761.69. Soils generated by
Alternatives SC-3 and SC-4 and any soils or debris contaminated with PCBs that cannot be treated or
incinerated in Alternatives SC-5 through SC-8 and have a PCB concentration greater than 50 mg/L would be
disposed of off-site in a landfill meeting the reguirements of 40 CFR °761.75.

In Alternatives SC-6 and SC-8, the PCB-contaminated soils would be treated on-site and placed back in the
excavated area with a residual PCB contamination of 1 mg/kg. Placement of soils with PCB levels of
approximately 1 mg/kg under a 10-inch soil cover would provide a permanent and protective remedy that
satisfies the TSCA Spill Policy, and reguirements of the Part 761 landfill regulations. Long-term
monitoring of ground water wells may also be instituted, as reguired by the chemical waste landfill
regulations.

For Alternative SC-7, the contaminated soils would be solidified to reduce the mobility of the
contaminants. Under the Disposal Reguirements, 40 CFR °761.60(a)(4), 761.60(e), soils contaminated with
PCBs may be disposed of in an incinerator, chemical waste landfill, or may be disposed of by an alternate
method that provides a performance similar to that of incineration. In this case, placement of solidified
soils in the excavated pits and construction of an impermeable cap over the Site or a hydraulic
containment system would satisfy the reguirements of a TSCA landfill. The monitoring of ground water
wells would be instituted, as reguired by the TSCA landfill regulations.

Alternatives SC-3 through SC-8 would also comply with the storage reguirements of the PCB Disposal
Regulations by the construction of a storage area meeting the standards of 40 CFR °761.65.

Neither SC-1 nor SC-2 would meet the intent of the TSCA PCB Spill Policy because they would leave soils
contaminated with greater than 1 mg/kg PCBs on the Site and would not adeguately protect human health and
-------
the environment.

RCRA: The applicability of Hazardous and Solid Waste Amendments to RCRA (HSWA)  regulations as
action-specific requirements for disposal depends on whether the wastes are hazardous,  as defined under
RCRA. The wastes at the Site have not been characterized as RCRA waste but are similar to RCRA waste,
therefore RCRA is relevant and appropriate to wastes left in place. HSWA Land Disposal Restrictions do
not apply because placement does not occur.

The minimum technology standards for closure of the excavated areas are based on TSCA and RCRA landfill
regulations. In this case, landfill requirements may be relevant and appropriate for contamination left
on Site. Under the SC-4 through SC-8 alternatives, the capping options are consistent with these closure
requirements.

Executive Order 11988, Floodplain Management: This executive order sets forth EPA policy to minimize the
impact of floods and preserve the natural and beneficial value of floodplains and provides for
consideration of floodplains during remedial actions. All systems in Alternatives SC-3 through SC-8 would
be assembled and operated away from the 100-year floodplain. If Alternative SC-3 or Option 1 or 2 for
Alternatives SC-4 through SC-8 is chosen for Elm Street, the cap would be constructed with engineering
controls to prevent damage from a 100-year flood.

NH Air Regulations: Dust emissions from the Site during Alternatives SC-2 through SC-8 would comply with
the Clean Air Act and the State of New Hampshire Air Regulations for dust emissions during excavation and
transportation of the contaminated soils. Engineering controls would be used to minimize the fugitive
dust emissions, including wetting the soils and using foams.

In Alternative SC-6, the thermal desorption system would discharge between 25 and 75 scfm of treated
nitrogen carrier gas to the atmosphere. Air monitoring would be performed to ensure compliance with the
New Hampshire air regulations.

In Alternative SC-8, the solvent extraction system is a closed system to minimize air emissions but
nitrogen gas does flow through the extractor in order to create an oxygen free environment and to purge
any non-condensible gases. Air monitoring would be performed to verify that the NH Ambient Air Levels are
met.

NH Cemetery Regulations: Alternatives SC-3 through SC-8 would require demolition of the Fletcher building
in order to contain or remove all the contamination at Elm Street. In removing this building the New
Hampshire historic regulations would be applicable because of the possibility of affecting the historic
cemetery that is adjacent to the building.

Long-Term Effectiveness and Permanence. Alternatives SC-4 and SC-5 would provide the greatest long-term
effectiveness and permanence by excavating all soils to a depth of 1 foot at Mill Street and down to 10
feet at Elm Street containing contaminant concentrations greater than soil cleanup levels for risk-based
protection. The excavated soils would then be either disposed of or treated off-site. After excavation,
clean soil would be backfilled into the area. Removal of the contaminated soils to a depth of 1 foot at
Mill Street and 10 feet at Elm Street would reduce risks associated with exposure to contaminants from
direct contact with and ingestion of soils. Removing the soil contamination that exceeds the cleanup
levels for risk based protection reduces the ingestion and dermal contact risks. The long-term controls
required at the Site would be dependant upon which of the long-term management options was selected
for the soils deeper than 1 foot at Mill Street and 10 feet at Elm Street. If Option 3 is chosen for both
Elm Street and Mill Street using either SC-4 or SC-5, long-term controls would not be required because
both alternatives would meet EPA criteria for remediation of PCB contaminated Sites.

Alternatives SC-6 and SC-8 would provide slightly less long-term effectiveness and permanence because the
contaminated soils would be treated on Site and placed back in the excavation after treatment. These
treated soils, while protective of human health and the environment, would have detectable levels of
contamination, whereas clean backfill would not. Treatment of the contaminated soils to a depth of 10
feet would reduce risks associated with exposure to contaminants from direct contact with and ingestion
of soils. Treating the soil contamination that exceeds the cleanup levels reduces the total risk due to
ingestion of and dermal contact with the soil.

SC-7 would provide only moderate long-term effectiveness and permanence because, while it would reduce
the risks from ingestion and dermal contact as effectively as SC-6 or SC-8, implementation of the
alternative would not destroy or remove contamination from the Site. One specific concern is the
long-term uncertainty associated with the integrity of the solidified material and the possibility that
contaminants could leach in the future. Because of the uncertainty with solidification/ stabilization,
long-term monitoring and controls would be required for the Site.
-------
Each of these five alternatives (SC-4, SC-5, SC-6, SC-7, SC-8)  would achieve long-term effectiveness and
permanence for the soils at a depth of greater than 10 feet using one of three options:

       •      Option 1 - Containment and Capping - Construction of a RCRA composite cap over the soils
              contaminated at a depth of greater than 1 foot at Mill Street and 10 feet at Elm Street and
              a hydraulic containment system at Mill  Street.

       •      Option 2 - Partial Removal and Capping  - Excavation of the soils at a depth greater than
              one foot at Mill Street and 10 feet at  Elm Street that contain PCB concentrations greater
              than 500 mg/kg and treatment or disposal with the other soils,  installation of a single
              barrier cap,  and construction of a hydraulic containment system at Mill Street.

       •      Option 3 - Additional Excavation and Soil Cover - Excavation of the soils at a depth greater
              than one foot at Mill Street and deeper than 10 feet at Elm Street that could cause an
              exceedance of the PCB MCL in ground water,  and off-site treatment in a TSCA incinerator or
              disposal in a RCRA landfill.

Option 3 provides the greatest protection of human health and the environment because it removes all the
PCB-contaminated soil that could cause an exceedance of the PCB MCL. By removing the PCB contamination in
soils in excess of that capable of exceeding the PCB MCL. Option 3 limits human exposure to PCB
contamination through the ingestion of ground water in excess of the MCL and prevents migration of the
contamination from the Elm Street Site to the Souhegan River where both human and ecological receptors
might come into contact with it. Therefore Option 3 would not reguire extensive long-term monitoring and
controls.

Option 2 would provides less protection of human health and the environment than Option 3 because it
would leave soils deeper than 1 foot at Mill Street and 10 feet at Elm Street contaminated with less than
500 mg/kg in place. This option would reguire installation of a single barrier cap over the contamination
at Elm Street and a single barrier cap with a hydraulic containment system at Mill Street. The caps at
both Elm Street and Mill Street would minimize the infiltration of precipitation but soils deeper than 10
feet contaminated with less than 500 mg/kg PCBs would be left slightly above and in contact with the
ground water table. The cap and hydraulic containment system at Mill Street would capture contaminated
ground water but soils deeper than one foot contaminated with less than 500 mg/kg would again be left in
place. Because contamination would be left on Site, institutional controls would be reguired. Option 1
would provide significantly less protection of human health and the environment than Options 2 or 3
because all contamination below one foot at Mill Street and 10 feet at Elm Street would be left in place.
This option would reguire the installation of a RCRA C composite cap over the remaining contaminated
soils at both Elm Street and Mill Street, as well as a hydraulic containment system at Mill Street. The
cap at Elm Street would minimize the infiltration of precipitation but high concentrations of PCBs would
be left slightly above and in contact with the ground water table. The cap and hydraulic containment
system at Mill Street would capture contaminated ground water but all soil contaminants deeper than 1
foot would be left in place. Because contamination would be left on Site, long-term monitoring and
controls would be reguired.

Alternative SC-3 would provide less long-term effectiveness and permanence than the other alternatives
discussed thus far. The concern with SC-3 is that it would only remove contamination from the top 3 feet
of soils and would leave high concentrations of PCBs above and in contact with the ground water table.
The contaminants could then potentially migrate from the Site into the river, where they would pose a
risk to human health and the environment. Because this alternative neither removes nor treats the soils
to 10 feet, it is considered to be significantly less effective than SC-4 through SC-8.

Neither SC-1 nor SC-2 would provide long-term effectiveness and permanence. SC-1 would not remove or
cover any of the contamination that is on Site and therefore leaves the Site in its current state. SC-2
does cover the contamination but,  as can be seen by the continued migration of contamination, it is not
an effective long-term alternative.

Reduction of Toxicity, Mobility, or Volume through Treatment Alternatives SC-5, SC-6, and SC-8 provide
reductions in toxicity, mobility,  and volume through the treatment and ultimate destruction of the
contaminants. SC-5 reguires the excavation and off-site incineration of the contaminated soil. The
incineration would oxidize the contaminants to carbon dioxide,  water and hydrochloric acid. SC-6 reguires
the excavation and thermal desorption of the contaminated soils. Thermal desorption would volatilize the
contaminants and then condense them separately from the soil. The condensed contaminants would then be
incinerated at an off site TSCA incinerator. Similarly, SC-8 separates the contaminants from the soils
using solvent extraction and incinerates the separated contaminants in an off-site TSCA incinerator.

The amount of contamination removed and treated from the Site using one of the three alternatives
discussed above depends on the option chosen for the remediation of soils deeper than 10 feet at Elm
-------
Street and deeper than 1 foot at Mill Street. The estimated total volume of contaminated soil for the
base case at both Elm Street and Mill Street is 24,000 CY. Assuming an average PCB concentration of 1,300
mg/kg, if the PCB-contaminated soils are removed to a cleanup level of 1 mg/kg, these alternatives are
estimated to remove and treat 37,000 kg of contaminants for the base case.

Depending on the option chosen for the remediation of the remaining soils, the reduction of toxicity,
mobility, and volume would increase. If Option 1 is chosen, there would be no increase in the reduction
of toxicity, mobility, or volume through treatment because the remaining soils would be capped and left
in place. Option 3 represents the largest increase in reduction of toxicity, mobility, or volume because
all of the remaining soil with PCB concentrations that could impact ground water would be removed. The
estimated total volume of contaminated soil for Option 3 at Elm Street and Mill Street is 5,300 yd 3 and
12,000 yd 3. The resulting total contaminant removal for this option would be 10,000 kg. If Option 3 is
chosen, all remaining soils with PCB concentrations greater than 500 mg/kg would be excavated and a
single barrier cap installed. Option 3 would result in an additional 1,600 yd 3 from Elm Street and 3,200
yd 3 from Mill Street being removed, resulting in the additional removal of approximately 6,000 kg of
PCBs.

Alternative SC-7, Solidification/Stabilization would immobilize the contamination from the excavated soil
but would have no effect on the contaminant toxicity, and would increase the contaminant volume through
the addition of binding agents by approximately 20 to 25 percent. Capping of the remaining contaminants
or excavation and treatment of the remaining contaminants would reduce the mobility of the contaminants.
However, while the mobility would be decreased the level of toxicity would remain the same and the
contaminant volume would increase due to the addition of binding agents.

The other four alternatives, SC-1, SC-2, SC-3, and SC-4, would not affect the toxicity, mobility, or
volume of the contamination through treatment, with the exception of SC-3, which would result in the
removal of soils from the top 3 feet to install the cap. If those soils are incinerated rather than
landfilled, SC-3 will result in the reduction of the toxicity, mobility, and volume of a portion of the
contamination. SC-4 would remove the contamination from the Site but would dispose of the contaminated
soil in a TSCA-approved landfill. SC-3 would contain the vertical migration of the contaminants through
the installation of a cap over the contamination.

Short-Term Effectiveness. One of the major uncertainties for Alternatives SC-3 through SC-8 is the
protection of the community and Site workers while the soils are being excavated. The concern is caused
by the proximity of the residents to the Site, the high volume of vehicular traffic on Elm Street
(approximately 20,000 vehicles per day), and the high concentration of PCBs in the soils. To limit this
risk during excavation, wetting agents and other engineered controls would be used to reduce the
particulate emissions from the Site. However, the actual air emissions that would result from the
excavation is uncertain and air monitoring would be performed to ensure that the community and Site
workers were not exposed to undue risks. In order to minimize the risk to workers, trained personnel
would operate the system. The risk to residents, and/or inconvenience to the residents could also be
minimized by relocating some of the residents on Mill Street during the excavation of the Mill Street
area. Adjacent portions of Keyes Field may also need to be temporarily closed during the remedial action
if air monitoring demonstrates an exceedance.

Additional short-term risks would be presented by Alternatives SC-4 and SC-5 due to the need to transport
the contaminated soils off Site for disposal and incineration, respectively.

Alternative SC-2 would present minimal risks to the community while the geotextile membrane was being
installed. Risks to the workers would be similar to Alternatives SC-4 through SC-5 and activities
associated with these alternatives may reguire the workers to use Level C protection.

To ensure protection of the environment, all remedial alternatives would be constructed and operated
above the 100-year floodplain level. This measure would prevent accidental flooding if the water level of
the Souhegan River rose substantially. All caps would have engineering controls for protection. In
addition, storm water collection systems would be designed to collect runoff from the Site in order to
minimize the spread of contamination.

Implementation. In general, Alternatives SC-4 through SC-8 should be both technically and
administratively implementable. However, two issues do pose a potential concern regarding the ability to
implement these alternatives as described. Because the Sites are small, space consideration is the
largest consideration in implementing any of the alternative. Use of a portion of the adjacent Keyes
Field, with the Town's permission, may be considered if all operations cannot be conducted solely on the
Site itself. Consideration of the use of Keyes Field would be focused on staging of clean fill, eguipment
and construction offices, as necessary. Also related to this issue is the potential inconvenience of
closing all or portions of Mill Street, Elm Street and the Keyes Drive even temporarily during the
excavation.
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Another issue for implementing the alternatives at the Mill Street Site is the active railway that
borders the Mill Street Site. A representative from Boston & Maine Railroad met with the EPA and members
of the local businesses, and discussed allowable modification of the rail spurs running through the Mill
Street Site in order to allow the remedial action to take place while continuing to operate one rail spur
at all times. Discussions with the railroad would need to continue through the remedial design and action
to ensure the safe implementation of any of the alternatives.

An additional concern for Alternatives SC-6 through SC-8 is the ability to treat the soils to the PCB
cleanup level. Each of these technologies is considered innovative technologies, and has somewhat limited
operating experience. Because of the limited experience and the variability between Sites, treatability
studies may be reguired for each of these alternatives.

Alternatives SC-1 through SC-3 would be technically easy to implement. However, there are administrative
considerations that may impact their overall implementability. Among these considerations are the
potential for future use restrictions to be imposed as a result of the continued existence of
contamination at the Fletcher's Paint Site and potential liabilities associated with the continued
presence of PCBs in the subsurface.

Cost
-------
Comparative Cost of Source Control Alternatives
Alternative
SC-1 No Action
SC-2 Limited Action
Capital Cost (a)
   ($1996)
         $96,000
SC-3 Containment and Off-site Disposal        $6,700,000
SC-3 Containment and Off-site Incineration   $13,000,000
0 & M Cost (a)
     ($1996)

      $51,000

     $460,000

     $540,000
     $540,000
Total Cost (a)
     ($1996)

        $51,000

       $600,000

     $7,240,000
    $13,500,000
SC-4 TSCA Landfill (Base Case)
Option 1 - Elm St.
Option 1 - Mill St.
Option 2 - Elm St.
option 2 - Mill St.
Option 3 - Elm St.
Option 3 - Mill St.
SC-5 TSCA Incinerator (Base Case)
Option 1 - Elm St.
Option 1 - Mill St.
Option 2 - Elm St.
Option 2 - Mill St.
Option 3 - Elm St.
Option 3 - Mill St.
SC-6 Thermal Desorption (Base Case)
Option 1 - Elm St.
Option 1 - Mill St.
Option 2 - Elm St.
Option 2 - Mill St.
Option 3 - Elm St.
Option 3 - Mill St.
SC-7 Solidification/Stabilization (Base
Option 1 - Elm St.
Option 1 - Mill St.
Option 2 - Elm St.
Option 2 - Mill St.
Option 3 - Elm St.
Option 3 - Mill St.
$11,000,000
$510,000
$370,000
$1,200,000
$2,000,000
$2,800,000
$4,500,000
$24,000,000
$510,000
$370,000
$2, 600,000
$4,900,000
$7,500,000
$9,000,000
$11,000,000
$510,000
$370,000
$1,100,000
$1,700,000
$2,200,000
$5,000,000
Case) $7,300,000
$510,000
$380,000
$960,000
$1,200,000
$1,600,000
$3,100,000
                                                                              $470,000
                                                                                $67,000
                                                                               $67,000
                                                                               $67,000
                                                                               $67,000
                                                                             $470,000
                                                                              $67,000
                                                                              $67,000
                                                                              $67,000
                                                                              $67,000
                                                                                1 1 1 1
                                                                             $470,000
                                                                              $67,000
                                                                              $67,000
                                                                              $67,000
                                                                              $67,000
                                                                               1 1 1 1
                                                                              $470,000
                                                                               $67,000
                                                                               $61,000
                                                                                $67,000
                                                                               $67,000
                                                                                 1111
                                                           $11,500,000
                                                               $290,000
                                                              $100,000
                                                            $1,270,000
                                                            $2,070,000
                                                            $2,800,000
                                                            $4,500,000
                                                                                                               Range of Costs for SC-4,  depending
                                                                                                               on long-term management options
                                                                                                               selected
                                                                                                              $11,890,000  to
                                                                                                              $18,800,000
                                                           $24,500,000
                                                              $290,000
                                                              $100,000
                                                            $2,670,000
                                                            $4,970,000
                                                            $7,500,000
                                                            $9,000,000
                                                                                                               Range of Costs for SC-5,  depending
                                                                                                             $24,890,000  to
                                                           $11,500,000
                                                              $290,000
                                                              $100,000
                                                            $1,170,000
                                                            $1,770,000
                                                            $2,200,000
                                                            $5,000,000
                                                                                                               Range of Costs for SC-6,  depending
                                                                                                               on long-term management options
                                                                                                               selected
                                                                                                             $11,890,000  to
                                                                                                             $18,700,000
                                                            $7,770,000
                                                              $290,000
                                                              $100,000
                                                               $927,000
                                                            $1,270,000
                                                            $1,600,000
                                                            $3,100,000
                                                                                                               Range Costs for SC-7,  depending,
                                                                                                               on long-term management options
                                                                                                               selected
                                                                                                              $8,160,000  to $12,470,000
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SC-8 Solvent Extraction (Base Case)
Option 1 - Elm St.
Option 1 - Mill St.
Option 2 - Elm St.
Option 2 - Mill St.
Option 3 - Elm St.
Option 3 - Mill St.
Note:
$10,000,000
   $510,000
   $370,000
 $1,100,000
 $1,600,000
 $2,100,000
 $4,700,000
$470,000
 $67,000
 $67,000
 $67,000
 $67,000
$10,500,000
   $290,000
   $100,000
 $1,170,000
 $1,670,000
 $2,100,000
   $4,700,000
            Range of Costs for SC-8,  depending
            an long-term management option
            selected
                                                                                                                                                      $10,890,000  to
                                                                                                                                                     $17,300,000
Cost shown for Options is the amount to be added to the base case cost
////// No associated cost
(a):  Total NPV at a 7% interest rate; discount factor used dependant upon time reguired to complete remediation.
-------
Management of Migration Alternatives

Comparative Analysis of Management of Migration Alternatives

A summary of the individual evaluation of the six management of migration alternatives is presented in
Table 26. The comparative analysis of the six alternatives is presented below for each of the NCP
evaluation criteria, except the State and community acceptance.

Protection of Human Health and the Environment Alternatives MOM-3  (Air stripping with GAG Adsorption),
MOM-4 (GAG Adsorption),  MOM-5  (UV/Oxidation with GAG Adsorption), and MOM-6  (Extraction and Discharge to
POTW) ,  in conjunction with the implementation of a source control alternative, would reduce the
contamination in the ground water to below risk-and health-based ARARs in a reasonable time frame. Each
of these four alternatives would eliminate unacceptable risk related to VOCs in the contaminated
overburden in approximately 10 years by extracting and treating the contaminated ground water. Time
frames cannot be estimated for TCB and PCBs; however they are expected to take longer, and up to 100
years,  given that these two contaminants are not easily moved through the groundwater during extraction.
The ability to meet the time frames presented in these alternatives is dependent on the amount of
contamination remaining in the unsaturated and saturated zones at the completion of the source control
action,  as well as the extent of the contamination within the bedrock.

Upon achieving the remedial action objectives for Alternatives MOM-3, MOM-4, MOM-5, and MOM-6, the risk
for the ingestion of and dermal contact with ground water would be reduced.

While the interim cleanup levels established for these alternatives are consistent with ARARs or suitable
TBC criteria for groundwater, a cumulative risk that could be posed by these compounds may exceed EPA's
goals for remedial action. At the time that the interim ground water cleanup levels, newly promulgated
ARARs,  and modified ARARs that call into guestion the protectiveness of the selected alternative have
been achieved and have not been exceeded for a period of three consecutive years, a risk assessment would
be performed on the residual ground water contamination to determine whether the remedial action is
protective.

By reducing the risk in the groundwater through any of these four alternatives, the discharge of
contaminants to the surface water and sediments of the Souhegan River would also be reduced.

Alternatives MOM-3, MOM-4, MOM-5, and MOM-6 have the potential to impact the wetlands along the river
Predictive modeling conducted using the computer model described in Section 3.3.2 indicated that the
extraction system would extract river water, but the effect on the wetlands bordering the river should be
negligible.

The Limited Action/Institutional Controls alternative, MOM-2, would be protective of human health because
it reguires the implementation of institutional controls in the form of restrictions on the use of the
contaminated groundwater, as drinking water, until drinking water standards have been met. The No Action
alternative, MOM-1, would not be protective of human health and the environment because it does not
prevent the future ingestion of the contaminated groundwater. Since neither restrictions would be placed
on the use of the groundwater as a drinking water supply until drinking standards have been met, nor any
treatment or containment technologies implemented as part of the No Action alternative, the human health
risks from the ingestion of the contaminated groundwater would not be mitigated.

Both Alternatives MOM-1  (No Action) and MOM-2 (Limited Action/Institutional Controls) would not provide
any protection to the environment and would not return the aguifer to its beneficial use in a reasonable
time frame.

The No Action alternative, MOM-1 would not include the use of restrictions to prevent exposure to the
groundwater or the use of treatment to reduce the toxicity, mobility or volume of the contaminated
groundwater at the Site; and would allow the contaminated groundwater to continue to migrate off-site and
release contaminants, over time, to the Souhegan River surface waters and sediments. Contaminant
concentrations in the groundwater currently exceed drinking water standards. With both MOM-1 and MOM-2,
the contamination in the groundwater would be reduced over a very long period of time due to natural
attenuation process such as dispersion, dilution, sorption, volatilization and both biological and
abiotic degradation of the volatile contaminants.

In the absence of active remediation of the contaminated groundwater, the VOC and PCB concentrations in
the overburden, are expected to persist in excess of the drinking water standards for approximately 25
years and greater than 100 years, respectively.  Contaminant concentrations within the bedrock would be
expected to remain in excess of the drinking water standards for an even greater time frame, depending on
the full extent of contamination within the bedrock system. Depending on the source control action taken
at the Site, contaminated soils could act as a source of continuous groundwater contamination through
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leachate generation and contaminant migration. Compliance with ARARs.  Alternatives MOM-3, MOM-4, MOM-5,
and MOM-6, in conjunction with the implementation of an appropriate source control alternative, would
meet the chemical-specific ARARs in the ground water within a reasonable time frame. Each of these
alternatives would meet the ground water cleanup levels for volatile and semivolatile contaminants within
10 years.

By meeting the chemical-specific ARARs in the ground water, any of these four alternatives would reduce
the discharge of contaminants to the surface water and sediments to below the ground water cleanup levels
for these two media, and the elimination of contaminant discharge to the environment would reduce the
contaminant exposure of ecological receptors to acceptable risk levels.

The ability to meet the time frames presented in these alternatives is dependent on the amount of
contamination remaining in the unsaturated and saturated zones at the completion of the source control
action, as well as the extent of contamination within the bedrock. Assuming there is no unacceptable,
residual contamination in the unsaturated zone, MOM-3, MOM-4, MOM-5, and MOM-6 would eliminate
unacceptable risks due to VOCs in the overburden groundwater within 10 years, but could take much longer(
up to 100 years)  to reach acceptable risks due to PCB and TCB contamination in the overburden and
bedrock.

Alternatives MOM-1  (No Action) and MOM-2 (Limited Action/Institutional Controls) would each take
approximately 25 and at least 100 years to meet the chemical-specific ARARs for VOCs and PCBs,
respectively, in the ground water within the overburden, and possibly longer for the bedrock. Again,
these time frames were estimated assuming that the source of the contaminants had been removed.

Alternatives MOM-1 and MOM-2 do not have any action-specific ARARs because no action would be taken under
these alternatives. Alternatives MOM-3, MOM-4, MOM-5, and MOM-6 would all meet the action-specific ARARs,
including:

       •      State air emission regulations on the air discharge from the air stripper and the
              UV/oxidation system if ozone  is used as the oxidant

       •      State air stripper regulations on the operation and control of the air stripper

       •      State hazardous waste regulations on the management and  disposal of spent granular
              activated carbon ("GAG ")  and other treatment residuals

       •      State and federal safe drinking water and Clean Water Act regulations on the discharge
              of  the treated ground water

       •      State and federal water pollution control regulations on the discharge of water to a POTW

       •      State underground injection regulation on the reinjection of the ground water into the
              aguifer.

Long-Term Effectiveness and Permanence. Alternatives MOM-3, MOM-4, MOM-5, and MOM-6 would reduce the risk
due to VOCs in the overburden plume to acceptable limits within 10 years by extracting and treating the
groundwater. Because the PCBs and TCB are hydrophobic and adhere strongly to soils, and therefore are
less mobile in the groundwater, it will take much longer for these contaminants to reach acceptable
limits, and possibly up to 100 years.

While these ground water cleanup levels are consistent with ARARs or suitable TBC criteria for ground
water, future federal or state regulations may modify the ARARs. Therefore, at the time that these ground
water cleanup levels, newly promulgated ARARs, and modified ARARs that call into guestion the
protectiveness of the remedy have been achieved and have not been, exceeded for a period of three
consecutive years, a risk assessment would be performed on the residual ground water contamination to
determine whether the remedial action is protective.

The ability to meet the time frames presented in these alternatives is dependent on the amount of
contamination remaining in the unsaturated and saturated zones at the completion of the source control
action, which can continue to provide a source for the contamination in the ground water, as well as the
nature of the extent of the contamination within the bedrock. Assuming there is no residual contamination
in the unsaturated zone or bedrock, MOM-3,  MOM-4, MOM-5, and MOM-6 would eliminate unacceptable risks
within 10 years.

Alternatives MOM-1 and MOM-2 would each take at least 25 and greater than 100 years to reduce the VOC and
PCB contamination, respectively, in the ground water within the overburden, to within the NCP risk range.
The presence of contamination in the Fletcher's Paint Site bedrock ground water would pose an even longer
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long-term residual risk, depending on the extent of the contamination within the bedrock.

Alternatives MOM-3, MOM-4, and MOM-5 would each produce similar guantities and types of treatment
residuals that would have to treated and disposed of off-site. All residuals that would be generated
during the remediation of the ground water would be disposed of in a manner to eliminate unacceptable
risks. If metals removal is reguired, the metal hydroxide sludges from the metal precipitation unit would
be disposed of in a hazardous waste landfill, and the spent GAG would be regenerated by the vendor,
destroying adsorbed contaminants. Spent filters and any free product removed from the egualization tank
would be shipped off Site for treatment and disposal. Alternative MOM-6 would produce only minimal
residuals. Alternative MOM-6 would result in the generation of spent filters and the collection of any
free product removed from the egualization tank. Each of these residuals would be shipped off-site for
treatment and disposal. Alternatives MOM-1 and MOM-2 would not produce any residuals because no treatment
would be performed.

The active management of migration alternatives, MOM-3, MOM-4, MOM-5, and MOM-6 would be operated until
the ground water met the ground water cleanup levels, and the contaminants would be either destroyed
on-Site in the UV/oxidation system or off-site when the GAG is regenerated or the extracted ground water
is sent to the POTW; therefore, no long-term controls would be necessary. All of the technologies that
would be used in these alternatives are considered reliable.

All six management of migration alternatives would reguire five-year reviews to evaluate whether the
alternative is protective of public health and the environment. The five-year reviews would be initiated
five years after the start of the remedial action and would continue until no contaminants remain at the
Site above levels that allow for unrestricted use and unlimited exposure.

Reduction of Toxicity, Mobility, or Volume through Treatment. In alternative MOM-3, the contamination
would be treated using an air stripper to volatilize the contaminants from the ground water. The air
stripper initially transfers the contamination from the ground water to the air and then from the air to
the vapor phase GAG. The effluent from the stripper would be polished with an agueous phase GAG system to
adsorb the remaining "unstrippable" contaminants. Air stripping is a well proven technology and, based on
the results from Sites with similar contamination, would remove approximately 90 percent of the VOCs from
the ground water. The remaining contaminants would be removed by the liguid phase GAG system. The
contaminants adsorbed to the vapor and agueous phase carbon units would be irreversibly destroyed during
the off-site carbon regeneration. This treatment system would, therefore reduce the volume, toxicity, and
mobility of the contaminants.

In alternative MOM-4, the contamination would be treated using an agueous phase GAG system. Greater than
99 percent of the contaminants would be adsorbed from the extracted ground water prior to discharge of
the treated effluent. The contaminants adsorbed to the agueous phase carbon units would be irreversibly
destroyed during the off-site carbon regeneration. This treatment system would therefore, reduce the
volume, toxicity, and mobility of the contaminants.

In alternative MOM-5, the UV/Oxidation system would remove approximately 99 percent of the contamination
from the extracted ground water, based on the previous studies conducted by Arthur D. Little and
discussions with a UV/Oxidation system vendor. The UV/Oxidation system would irreversibly destroy the
contaminants directly by oxidizing the organics to carbon dioxide, water, and hydrochloric acid. The
remaining contaminants would be treated using the liguid phase GAG system and would be irreversibly
destroyed during the off-site carbon regeneration. This treatment system would reduce the volume,
toxicity, and mobility of the contaminants.

In alternative MOM-6, the discharge of the extracted ground water to the Milford POTW would result in the
destruction of greater than 95 percent of the contamination. Those metals and refractory organics would
either be collected in the sludge or discharged with the POTW effluent. The majority of the organics
contained in the sludge would be irreversibly destroyed when the sludge was composted. Any metals
captured in the sludge would not be removed, but would remain in the sludge. This treatment system would
reduce the volume, toxicity, and mobility of the contaminants. Alternatives MOM-1 and MOM-2 would not
involve the reduction of the volume, toxicity, and mobility of the contaminants through treatment.

Alternatives MOM-3, MOM-4, and MOM-5 would produce varying guantities but similar types of treatment
residuals. The spent GAG would be generated by Alternatives MOM-3, MOM-4, and MOM-5 at rates of
approximately 5.5, 18, and 0.6 tons/year, respectively, and would be recovered through off-site
regeneration. Alternative MOM-6 would result in the generation of minimal residuals, composed of any
NAPLs collected in the egualization vessel and spent filters. Each of the four active management of
migration alternatives would generate similar guantities of liguids and solids in the egualization
vessel, as well as spent filters, as all four would employ identical egualization and filtering systems.
An estimated 50 pounds of solids would be collected each year in the egualization tank that would have to
be treated off Site. Spent filters would also reguire off-site treatment or disposal. If metals removal
-------
is required the metal precipitation system would generate metal hydroxide sludges at a rate of
approximately 73 tons/year for each of these four alternatives. These sludges would be disposed of
off-site as a hazardous waste. Alternatives MOM-1 and MOM-2 would not produce any residuals because
no treatment would be performed.

Short-Term Effectiveness. The operations of the equipment for Alternatives MOM-3, MOM-4, and MOM-5 are
not expected to increase the risk to the community because the air emissions from the air stripper and
the UV/Oxidation system would be treated by GAG prior to their release to the environment. The risks to
the workers from using the acids, bases, and the hydrogen peroxide associated with the air stripper,
metals precipitation, and UV/Oxidation treatment would be minimized through the use of engineering
controls and personal protective equipment. The effluent for each of these three alternatives would be
treated with aqueous phase GAG adsorbers to remove contaminants prior to discharge. Alternative MOM-6 is
not expected to pose any short term risks to the community, as the only treatment conducted on Site is
the filtering of the extracted ground water.

Alternatives MOM-3, MOM-4, MOM-5, and MOM-6 would achieve remedial action objectives in a reasonable time
frame. Each of these alternatives would meet the VOC groundwater cleanup levels in the plume within
approximately 10 years by extracting and treating the ground water (MOM-3, MOM-4, and MOM-5), or by
extracting the ground water and discharging it for treatment (MOM-6).  While the time to reach cleanup
levels in the overburden cannot be estimated for TCB and PCBs,  the time frame is expected to be much
greater, and could be up to 100 years, due to the hydrophobic nature of these contaminants and lower
impact that a groundwater extraction system would have on these particular contaminants versus the VOC
contaminants. The ability to reach the interim cleanup levels in the overburden, is dependent on the
amount of contamination that remains in the unsaturated zone at the end of the source control action and
the extent of the contamination within the bedrock. Further bedrock studies will be necessary, once the
source control action is complete to determine the ability of and the estimated time frame for the
groundwater within the bedrock to reach the interim cleanup levels. It is estimated, however, that the
time to meet cleanup levels in the bedrock will be much longer than the time frame estimated for the
overburden. Assuming there is no residual contamination in the unsaturated zone or bedrock, Alternatives
MOM-3, MOM-4, MOM-5, and MOM-6 would meet the ground water cleanup levels for VOCs within 10 years in the
overburden.

By reducing the risk in the ground water in each of these four alternatives, the discharge of
contaminants to the surface water and sediments would be reduced to below the cleanup levels for these
two media, and the elimination of contaminant discharge to the environment would reduce the contaminant
exposure of ecological receptors to acceptable risk levels. Alternatives MOM-1 and MOM-2 would not
increase risk to the residents, workers, or the environment, however,  neither alternative would meet the
VOC and PCB ground water cleanup levels within the overburden for approximately 25 and at least 100
years, respectively, and even longer within the bedrock, depending on the extent of the contamination
within the bedrock. Implementation. The construction and operation of the air stripper, GAG adsorption,
and UV/oxidation systems for MOM-3, MOM-4, and MOM-5, respectively, can be easily implemented and are
technically capable of treating the contaminants in the ground water.  However, the UV/Oxidation system
used in MOM-5 is innovative; if the system cannot meet the ground water cleanup levels, then either MOM-3
or MOM-4 can be used in its place. Alternatives MOM-3, MOM-4, and MOM-5 can each be expanded if
additional ground water needs to be treated or the concentration of contamination is greater than
expected. No special equipment, materials, or specialists would be required for the implementation of any
of these three alternatives. Alternative MOM-6 can also be implemented, technically, and could treat more
than double the anticipated flow rate, as the POTW currently treating much less than its rated capacity.

Alternatives MOM-2, MOM-3, MOM-4, MOM-5, and MOM-6 would require state and local coordination for the
implementation of legal restrictions on the use of ground water at the Site. Alternatives MOM-3, MOM-4,
and MOM-5 would also require state and local coordination for the discharge of treated air and ground
water to the environment.

Cost
-------
Table :Comparative Cost of Management of Migration Alternatives

Cost
Capital Cost
Annual O&M
Cost
Alternative
MOM-1
No action
$0
$4,000
Alternative
MOM- 2
Limited
Action/
Institutional
Controls
$0
$0.20 million
Alternative
MOM- 3
Air Strip &
GAG
$0.49 million
$0.45 million
Alternative
MOM- 4
GAG
Adsorption
$0.37 million
$0.48 million
Alternative
MOM- 5
UV/Ox & GA
$0.62 mil!
$0.44 mill
NPV
$48,000 (a)
$2.31 million (a)
                                                                                                               Alternative MOM-6
                                                                                                                    $0.62 million
                                                                                                                    $0.31 million
$3.77 million (b)  $3.84 million  (b) $3.82 million  (b)  $2.85 million  (b)
Notes:





(a)Total NPV  (1996$) estimated over 25 years at  a  7%  interest  rate.





(b) Total NPV  (1996$) estimated over 10 years at a 7% interest rate.
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X. THE SEIiECTED REMEDY

The selected remedy is a comprehensive remedy which utilizes source control and management of migration
components to address the principal Site risks for this operable unit. Highly contaminated soils at the
Elm and Mill Street Sites which pose the greatest risk to human health based on the anticipated future
uses of the Site would be excavated, treated on-site by thermal desorption, and replaced. The
concentrations of the contaminants in the remaining contaminated soils would be protective of the
environment and prevent the future long-term spread of the contamination to the groundwater through
leaching. Management of migration will be accomplished over time through institutional controls and
monitored natural attenuation.

The selected remedy is a combination of the SC-6, thermal desorption and MOM-2, monitored, natural
attenuation alternatives presented in the FS.  Several modifications to the SC-6, thermal desorption
alternative was presented in the Proposed Plan. These modifications included an elevation of the Elm
Street subsurface soil cleanup standard from 1 mg/kg to 10 mg/kg PCB and the selection of a RCRA Subtitle
D cap at the Elm Street Site as the long-term management option for the contaminated soils left in place.
Based on public comments received on the Proposed Plan, the remedy was again modified as presented below.
For a more complete description of these changes see the Documentation of Significant Changes, Section
XII of the ROD

A.     Interim Ground Water Cleanup Levels

Interim cleanup levels have been established in ground water for all contaminants of concern identified
in the Baseline Risk Assessment found to pose an unacceptable risk to either public health or the
environment. Interim cleanup levels have been set based on the ARARs  (e.g., Drinking Water Maximum
Contaminant Levels  (MCLs),  and NH Ambient Groundwater Quality Standards (AGQS)  as available, or other
suitable criteria described below. Periodic assessments of the protection afforded by, remedial actions
will be made as the remedy is being implemented and at the completion of the remedial action. At the time
that Interim Ground Water Cleanup Levels identified in the ROD and newly promulgated ARARs and modified
ARARs which call into guestion the protectiveness of the remedy have been achieved and have not been
exceeded for a period of three consecutive years, a risk assessment shall be performed on the residual
ground water contamination to determine whether the remedial action is protective. This risk assessment
of the residual ground water contamination shall follow EPA procedures and will assess the cumulative
carcinogenic and non-carcinogenic risks posed by ingestion of the groundwater.  If, after review of the
risk assessment, the remedial action is not determined to be protective by EPA, the remedial action shall
continue until either protective levels are achieved, and are not exceeded for a period of three
consecutive years, or until the remedy is otherwise deemed protective or is modified. These protective
residual levels shall constitute the final cleanup levels for this ROD and shall be considered
performance standards for this remedial action.

Because the aguifer under the Site is a Class IIB aguifer, which is a potential source of drinking water,
MCLs established under the Safe Drinking Water Act and the NH Ambient Groundwater Quality Standards
(AGQS)  are ARARs. The New Hampshire Department of Environmental Services completed a Beneficial Use and
Value Determination on the Milford-Souhegan Aguifer in which the Fletcher's Paint Site is located. This
determination is attached as Appendix D. NHDES determined that the groundwater beneath the Site was of
medium use and value to the community and the State of New Hampshire. This finding indicates that the
groundwater beneath the Site has "medium" value as a future drinking water supply, having been a drinking
water supply in the past, and therefore drinking water standards, consistent with the use and value
determination, shall be attained in the groundwater at the Site.

Interim Cleanup Levels for known, probable, and possible carcinogenic compounds (Classes A, B, and C)
have been established to protect against potential carcinogenic effects and to conform with ARARs.
Because the MCLGs for Class A & B compounds are set at zero and are thus not suitable for use as interim
cleanup levels, MCLs have been selected as the interim cleanup levels for these Classes of compounds.

Interim cleanup levels for Class D and E compounds (not classified, and no evidence of carcinogenicity)
have been established to protect against potential non-carcinogenic effects and to conform with ARARs.
MCLs have been selected as the interim cleanup levels for these Classes of compounds.

In the absence of a non-zero MCLG, an MCL, a proposed non-zero MCLG, proposed MCL, State standard, or
other suitable criteria to be considered  (i.e., health advisory, state guideline)  an interim cleanup
level was derived for each compound having carcinogenic potential  (Classes A, B, and C compounds) based
on a 10 -6 excess cancer risk level per compound considering the future ingestion of the groundwater.  In
the absence of the above standards and criteria, interim cleanup levels for all other compounds  (Classes
D and E) were established based on a level that represent an acceptable exposure level to which the human
population including sensitive subgroups may be exposed without adverse affect during a lifetime or part
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of a lifetime, incorporating an adequate margin of safety  (hazard quotient = 1) considering the future
ingestion of the groundwater.

The table below summarizes the Interim Cleanup Levels for carcinogenic and non-carcinogenic
contaminants of concern identified in ground water.

Interim Ground Water Cleanup Levels
Carcinogenic
Contaminant of
Concern  (Class)
Volatiles:
      Interim
  Cleanup Levels
       (Ig/L)
Basis
     Level of
       Risk
Benzene  (A)
1,2-Dichloroethane  (B)
Trichloroethylene  (B)
Pesticides/PCBs:
PCB  (B)
Non-Carcinogenic
Contaminant of
Concern  (Class)
Volatiles:
         5.0                MCL
         5.0                MCL
         5.0                MCL

         0.5                MCL

Total Carcinogenic Risk

       Interim
   Cleanup Levels
         (Ig/L)             Basis
               1.7 x 10 -6
               5.3 x 10 -6
               6.5 x 10 -7

               1.2 x 10 -5

                 2 x 10 -5

              Target
             Endpoint
             of Toxicity
                              Hazard
                              Quotient
Ethylbenzene(D)
Toluene  (D)
Semivolatiles:
1,2,4-Trichlorobenzene
(D)
PCBs


Metals

Manganese
          700
        1,000
           70
                                         0.5
          180
 MCL
 MCL
                            MCL
                                                           MCL
                            Risk-
                           Based
liver and kidney toxicity       0.2
   liver  and  kidney weight
           changes               0.1
Total HI for liver and
        kidney                  0.3

reduced body weight gain
                                0.2
Total HI Body weight loss       0.2

     immune system              0.7

Total HI Immune System          0.7

  central nervous system
     (CNS)  effects              1

   Total HI CNS Effects         1
All Interim Groundwater Cleanup Levels identified in the ROD and newly promulgated ARARs and modified
ARARs which call into question the protectiveness of the remedy and protective levels determined as a
consequence of the risk assessment of residual contamination, must be met at the completion of the
remedial action at the points of compliance. At this Site, the Interim Cleanup Levels must be attained
throughout the contaminated groundwater plume, which extends from the Mill Street Site to the Souhegan
River. The exact boundary of such contaminated plume will be defined during remedial design by the
establishment of the Groundwater Management Zone, consistent with NH's Groundwater Management Policy. EPA
has estimated that the Interim Cleanup Levels for the VOC contamination in the overburden will be
obtained within 20 to 25 years after completion of an active source control component. It is expected
that the PCB contamination would persist for greater than 100 years following an active source control
component. The fractured, shallow bedrock zone will require further characterization and monitoring of
the migration of the contaminants into and through the bedrock fractures, to determine when or if the
Interim Cleanup Levels will be attained within the bedrock within a reasonable time frame. However, based
on the current understanding of the groundwater contamination within the bedrock, the restoration time
frame is expected to be greater than the 20 to 25 years estimated for the overburden for the VOCs and
remain greater than 100 years for the PCB contamination.
B.
          Soil Cleanup Levels
Soil cleanup levels have been established to address two different exposure pathways: 1) dermal contact
-------
and incidental ingestion of surface and subsurface soils, and 2) future ingestion of contaminated
groundwater.

Soil cleanup levels based on exposures through dermal contact and incidental ingestion of Surface and
subsurface soils

Cleanup levels for known and suspect carcinogens  (Classes A, B, and C compounds) have been set at a 10 -6
excess cancer risk level based on exposures via dermal contact and incidental ingestion of surface and
subsurface soils at the Site. Cleanup levels for PCBs are based on EPA's guidance entitled Guidance
Actions for Superfund Sites with PCB Contamination (PCB Guidance, EPA 1990)(TSCA Spill Policy). Cleanup
levels for compounds in soils having non-carcinogenic effects  (Classes D and E compounds) were derived
for the same exposure pathway(s) and correspond to a level that represents an acceptable exposure level
to which the human population including sensitive subgroups may be exposed without adverse affect during
a lifetime or part of a lifetime, incorporating an adeguate margin of safety (hazard guotient = 1).

Cleanup levels, based on dermal contact and incidental ingestion, were developed for two depths of soil:
0 to 1 foot across the Site; and from 1 to 10 feet at the Elm Street Site within a utility corridor(s).

Surface soils 0 to 1 foot. The cleanup level for surface soils at the Elm Street and Mill Street Sites is
protective for an adult or child resident trespassing on the property in the future, consistent with the
Town of Milford's future use expectations for the Site. The cleanup level for PCBs has been set at 1
mg/kg of PCBs. Based on the expected future uses of the Elm and Mill Street Site, this level corresponds
to a 3.0 x 10 -6 excess cancer risk level. For noncarcinogenic risks, the Hazard Quotient for 1 mg/kg PCB
is 0.4. (Appendix E contains the calculations for the carcinogenic risk and Hazard Quotient for PCBs).
The Hazard Quotient for arsenic at a cleanup level of 0.9 mg/kg is 0.02.

Subsurface soils 1 to 10 feet within the utility corridor(s) at the Elm Street Site Under an unrestricted
recreational use of the property, adults and children could receive unacceptable risks from exposure to
subsurface soils brought to the surface by future excavations. The Town of Milford has indicated that
future excavation of the Elm Street Site would be restricted to defined utility corridor(s). This will
prevent exposures to the adult and child recreational user to the undisturbed contaminated subsurface
soils. The 10 foot depth corresponds to a depth which is considered accessible in the performance of
utility placement and maintenance. The cleanup level for subsurface soil within the utility corridor(s)
at the Elm Street Site, is 25 mg/kg PCB. The cancer risk for a utility worker who might be exposed to 25
mg/kg PCB in the utility corridor(s) on an infreguent basis is 4.6 x 10 -7. For non-carcinogenic risks,
the Hazard Quotient at 25 mg/kg PCB for the utility worker, is 0.3.  (See Appendix E of this ROD for the
calculations of the utility worker cancer and Hazard Quotient).

The table below summarizes the cleanup levels for carcinogenic and non-carcinogenic contaminants of
concern in soils.

       Interim Soil Cleanup Levels For the Protection of Human Health from
                      Dermal Contact and Incidental Ingestion

Surface Soils - 0 to 1 Foot at Elm and Mill Street
Compound               Interim               Basis                 Risk at Cleanup
                       Cleanup Level                               Level (1)
                       (mg/kg)

Benzo  [a]  anthracene         2.1           Risk-Based  (1)          1.0 x 10 -6
Benzo  [a]  pyrene             0.2           Risk-Based  (1)          1.2 x 10 -6
Benzo  [a]  fluoranthene       2.0           Risk-Based  (1)          1.4 x 10 -6
PCB                          1.0        PCB Spill Policy (2)       3.0 x 10 -6
Arsenic                      0.9           Risk-Based  (1)          1.0 x 10 -6
                                             Total Risk            7.6 x 10 -6

      Subsurface Soils - 1 to 10 Feet at Elm Street Site Utility Corridor  (s)
          Compound                Interim            Basis           Risk at Cleanup
                               Cleanup Level                             Level  (1)
                                  (mg/kg)
  PCB                                25          PCB Spill Policy (2)  4.6 x 10 -7
                                                   Total Risk          4.6 x 10 -7

(1) Risk based on incidental ingestion and dermal contact with soil. See the 1994 and 1996,
    amended Human Health Baseline Risk Assessments for exposure parameters and eguations.
(2) PCB Spill Policy (40 CFR 761.60(d)) and EPA Guidance on Remedial Actions for Superfund
    Sites with PCB Contamination  (EPA, 1990)
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Soil cleanup levels for the protection of groundwater from potential soil leachate

In addition to the cleanup levels established for protection of human health from exposure to the surface
and subsurface soils, consistent with the anticipated future uses of the Site, available data also
suggest that the contaminated soils are also a source of release of PCBs to the groundwater. This
phenomenon may result in an unacceptable risk to those who ingest the contaminated groundwater in the
future. Therefore, cleanup levels were also established for Site soils, to protect the aguifer from
potential soil leachate. The Guidance for Remedial Actions for Superfund Sites with PCB Contamination
(EPA, 1990)  was considered in addressing the contaminated soils that may be contained and managed in
place over the long term.

Subsurface soils in all areas below 1 foot at the Elm and Mill Street Sites, except for the area to be
defined as the utility corridor at the Elm Street Site: Soils below 1 foot at the Elm and Mill Street
Sites, with the exception of the area to be designated as the utility corridor at the Elm Street Site,
are not expected to pose a threat to human health through direct contact given their depth or location,
based on anticipated future uses of the properties. However, contaminants at these depths could leach
into the ground water and pose a threat to human health through ingestion of ground water. The remedial
action objective for these soils is to prevent the leaching of contaminants from the soil to the ground
water that will result in the concentration of PCBs in the ground water in excess of health and
risk-based ARARs.

The Elm Street and Mill Street leachate modeling efforts reflect the apparent fate and transport issues
affecting each portion of the Site differently. At the Elm Street Site, PCB transport through the
subsurface is low, resulting in groundwater contaminant concentrations just above the drinking water
standards. At the Mill Street Site, PCB concentrations are very high and exceed what one would expect
given the fate and transport mechanisms for PCBs in soils. For soils greater than 1 foot at both the Elm
Street and Mill Street Site, PCB migration from the unsaturated soil to the water table was modeled to
determine whether current PCB soil concentrations would result in a ground water exceedance of the MCL
for PCBs in ground water (0.5 ug/L).

Elm Street

The results of a previous EPA modeling effort  (EPA PCB Guidance, 1990) were used to evaluate a PCB
concentration that could remain at the Elm Street Site and not impact the groundwater in the future above
the Interim Cleanup Level for PCBs. The results of this modeling indicate that a threat to the ground
water currently exists from the PCB contamination at the Elm Street Site. The model indicates that the
PCBs that are present in the unsaturated soils below 1 foot at the Elm Street Site will migrate to the
ground water and result in an exceedance of the MCL for PCBs, set at 0.5 ug/L PCB. If left unaddressed,
this process could continue for several hundred years because PCB migration is extremely slow. Therefore
a cleanup level of 100 mg/kg PCB which could remain in the soils at the Elm Street Site, with only a soil
cover, was set. This concentration will not result in an exceedance of the groundwater MCL for PCBs in
the future.

Mill Street

A separate modeling analysis was conducted (located in Appendix E of the FS) for the Mill Street Site due
to the high concentrations of PCBs already present in the ground water in this area, and as a result of
finding other contaminants present that are known to increase the solubility of the PCBs. This analysis
suggested that the PCB migration rate at Mill Street could be higher as a result of interaction between
the PCBs and the other contaminants found at the Mill Street Site. The modeling indicated that the PCBs
that are currently present in the unsaturated soils below 1 foot at Mill Street will migrate to the
ground water and cause an exceedance of the MCL for PCBs in the ground water beneath the Site.

Another factor at the Mill Street Site is the presence of other paint related materials that appear to
form a flocculent material  (precipitate) within the well screen of monitoring well, MW-07A. The PCB
concentration associated with this flocculent material is 1,780 ug/1 PCB (Arochlor 1242). No separate
phase DNAPL was observed during any purging of the well or sampling of this material. A 46 ug/1 PCB
concentration found in the top portion of the same groundwater sample may have been influenced by
particulates that had not settled out, and therefore may not represent the groundwater conditions around
MW-07A.

The SESOIL model for leaching, and the AT123D model for down gradient groundwater concentrations were
used to determine a soil concentration that will result in groundwater concentrations at or below the
Interim Cleanup Levels. SESOIL is a mathematical model designed for long-term hydrologic, sediment, and
pollutant fate simulations. It can describe water transport, sediment transport, pollutant transport and
transformation; soil guality; pollutant migration to groundwater; and other processes. Simulations are
performed using a specified soil column extending between the ground surface and the lower part of the
-------
unsaturated soil zone. These models were used to estimate residual soil levels that are not expected to
impair future groundwater quality. The Interim Cleanup Level for PCBs in groundwater was used as input
into the leaching model. If the predicted protective soil level was not capable of being detected with
good precision and accuracy, then the practical guantification limit was selected as the cleanup level
for soils.

Low flow data collected during Phase IB of the RI indicated that dissolved and mobile PCB contamination
was present in the groundwater at both monitoring wells located within the known source area at the Mill
Street Site (MW-07A and MW-21C).  Sampling conducted by GE in 1995 also confirmed dissolved and mobile PCB
contamination within the overburden and bedrock at the Mill Street Site.

Because of the potential for the enhanced solubility and migration of PCBs as a result of other paint
related materials found only at the Mill Street Site, EPA used a conservative approach to modeling the
concentration of PCBs that can remain in the saturated and unsaturated soils and not result in an
exceedance of groundwater Interim Cleanup Levels. The results of the modeling indicated that 1 mg/kg PCB
could remain in the soils at the Mill Street Site, with only a soil cover, and not result in an
exceedance of the groundwater MCL for PCBs in the future. Recognizing EPA's conservative approach, soil
column testing can be conducted during design to determine a site-dependent PCB concentration that could
remain in the soils at the Mill Street Site and not result in an exceedance of the groundwater MCL for
PCBs in the future. If changes are made to the Mill Street Site subsurface soil concentration in the
future, the Draper Energy subsurface soil concentrations, currently set at 1 mg/kg PCB, would also have
to be revisited to ensure that subsurface soils at the property would remain protective for future adult
and child exposures. The determination of a subsurface soil concentration at the Mill Street Site, as
well as any revisited cleanup level at the Draper Energy property, other than the 1 mg/kg PCB set in this
ROD, will be in the sole discretion of the EPA.

The long-term management controls, including appropriate engineering and institutional controls,
developed for the Elm and Mill Street portion of the Sites are presented in detail in Section 4.0 of the
FS, and described in SC-4 under the detailed analysis of the source control alternatives. While all of
the long-term management options are considered protective of the groundwater, EPA selected option 3,
soil excavation and placement of a soil cover for both the Elm Street and Mill Street Sites.

In summation,  the soil cleanup levels for groundwater leaching purposes and long-term management actions
for the Elm and Mill Street Sites are summarized as follows:

Elm Street - Excavate all subsurface soils to a concentration of 100 mg/kg PCB or to a concentration at
which leaching models and/or column testing show that infiltration through the remaining PCB soil
concentrations will not result in future ground water concentrations in excess of the 0.5,Ig/l MCL ground
water concentration for PCBs. The determination of a subsurface soil cleanup level other than 100 mg/kg
PCB, will be in the sole discretion of the EPA.

Mill Street - Excavate all soils to a concentration of 1 mg/kg PCB or to a concentration at which
leaching models and/or column testing show that infiltration through the remaining PCB soil
concentrations will not result in future ground water concentrations in excess of the 0.5 Ig/1 MCL ground
water concentration for PCBs. The determination of a subsurface soil cleanup level other than 1 mg/kg
PCB, will be in the sole discretion of the EPA.

The table below summarize the soil cleanup levels required to protect public health and the aquifer from
the leaching of contamination into the groundwater and was developed specifically for the groundwater
contaminant of concern, PCBs, which was detected above the Interim Cleanup Level for groundwater.
-------
INTERIM SOIL CLEANUP LEVEL FOR THE PREVENTION OF LEACHING TO THE GROUNDWATER FOR THE PROTECTION OF HUMAN
HEALTH

Carcinogenic               Basis for               Groundwater               PCB
Contaminant                Concern                 Risk                      Cleanup Level  (mg/kg)

ELM STREET: PCB            Groundwater             carcinogenic risk:                 100
                           MCL of 0.5 ug/1
                                                   1.2 X 10 -5

                                                   Hazard Quotient:
                                                   0.7

MILL STREET: PCB           Groundwater             carcinogenic risk:                   1
                           MCL of 0. 5 ug/1
                                                   1.2 X 10 -5

                                                   Hazard Quotient:
                                                   0.7


All of the cleanup levels for soils set forth in this ROD are consistent with ARARs for ground water,
attain EPA's risk management goal for remedial actions, and have been determined by EPA to be protective
of human health. These soil cleanup levels must be met at the completion of the remedial action at the
points of compliance: throughout the Fletcher's Paint Site wherever soil contamination levels exceed the
soil cleanup levels set in this ROD.

C. Description of Remedial Components

The preferred alternative includes excavation and treatment of the contaminated soils that present the
highest risk to public health, excavation and treatment of the remaining contaminated soils to prevent
the spread of the contamination into the groundwater, and natural attenuation and long-term monitoring of
the contaminated groundwater. The preferred alternative remedial actions would be implemented using a
phased approach that provides use of innovative technology, is cost-effective and reduces the potential
impacts to the community.

Specifically the preferred alternative includes the following actions:

SOILS

Phase 1 - Mill Street Site Cleanup:

To address the current and future risks associated with dermal contact or ingestion of the contaminated
surface and subsurface soils at the Mill Street Site, the activities would include:

       •      Excavation of approximately 1,500 yd 3  of surface soils (0 to 1 foot)  at the Mill Street
              Site to a depth of 1 foot,  wherever PCB concentrations are greater than 1 mg/kg PCB.

To address the future risks associated with ingestion of contaminated groundwater at the Mill Street Site
as a result of leaching, the activities would include:

       •      Excavation of approximately 12,000 yd 3 of subsurface soils at the Mill Street Site (1 to 20
              feet (bedrock)  below surface),  approximately 3,000 yd 3 of which are located below the water
              table,  wherever PCB concentrations remain that exceed 1 mg/kg PCB; or excavation of
              soils to a PCB concentration at which leaching models and/or soil column testing show that
              infiltration through the remaining PCB  soil concentrations will not result in future
              groundwater concentrations  in excess of the 0.5 Ig/1 MCL groundwater concentration for
              PCBs.  The determination of  a subsurface soil cleanup level other than 1 mg/kg PCB,  will be
              in the sole discretion of the EPA.

       •      Water collected from the dewatering of  the excavated soils and water collected as a result
              of lowering of the water table to conduct the excavation,  will be either treated on-site in
              a mobile unit and appropriately discharged to the Souhegan River or sent off-site to a
              treatment facility.
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       •       Treatment of approximately 13,500  yd 3  of excavated soils  by ex-situ thermal  desorption.
              The thermal  desorption unit would  be located on the Elm Street  property.  This property is
              currently secured with a fence.  Consideration may be given to the use of  the  former
              Fletcher's Paint Works building  on the  Elm Street Site  as  storage to stage and screen the
              contaminated soils prior to treatment.  Liguid PCB condensate produced from the thermal
              desorption process will be disposed of  off-site at an appropriate facility.

       •       Demolition and disposal of the Fletcher's Elm Street building prior to, or following thermal
              desorption activities.  The manufacturing portion of this building was used to store paint
              pigments  and chemicals.  While these were removed in the 1993 removal action,  gross
              contamination still exists in this facility and therefore  some  of the debris  will have to  be
              disposed  of  at an appropriate landfill  facility.  Consideration  may be reviewed for  use of
              these materials as fill material on the Site.  Decontamination of building material,  if
              warranted,  and off-site disposal will be conducted in accordance with TSCA.

       •       Off-site  disposal of all soil and  debris that is either oversized or cannot be treated
              through the  thermal desorption unit.  All contaminated soil and  debris will be disposed of  in
              accordance with TSCA disposal regulations.

       •       Backfilling  of the treated soils back onto the Mill Street Site and restoration of  the
              property  consistent with the anticipated future use of  the Site.  Specifically,  the  majority
              of the Mill  Street Site will be  paved,  physically re-aligning Mill Street. The pavement will
              reduce infiltration of precipitation, control erosion and  promote drainage away from the
              residential  properties.

       •       Regrading and repair of the storm  drainage ditch system, as necessary,  to promote surface
              water flow away from the Site. Erosion  control measures shall be incorporated into  the
              final drainage system to prevent erosion or debris from restricting future storm water
              flow from the Mill Street Site or  filling in of the drainage ditch.

Phase 2 - Elm Street Site Cleanup:

To address the current  and future risks associated with dermal contact or ingestion of  the  contaminated
surface and subsurface  soils on the Elm Street Site,  the activities would include:

       •       Excavation of approximately 2,800  yd 3  of surface soils at the  Elm Street Site to a depth  of
              1  foot, wherever PCB concentrations are greater than 1  mg/kg PCB.

       •       Excavation of approximately 1,000  yd 3  of subsurface soils,  within the utility corridor(s),
              at the Elm Street Site at depths between 1 and 10 feet,  wherever PCB concentrations are
              greater than 25 mg/kg PCB. Final location of the utility corridor(s)  within the Site will  be
              determined during design.

       •       Excavation of approximately 11,600 yd3  of remaining subsurface  sods,  with the exception of
              the "hot  spot" materials described below,  from 1 foot to the seasonally low water table,
              wherever  PCB concentrations remain that exceed 100 mg/kg;  or to a PCB concentration at which
              leaching  models and/or soil column testing show that infiltration through the remaining PCB
              soil concentrations will not result in  future groundwater  concentrations  in excess  of the
              0.5 Ig/1  MCL groundwater concentration  for PCBs.  The determination of a subsurface  soil
              cleanup level other than 1 mg/kg PCB, will be in the sole  discretion of the EPA.

       •       Excavation and off-site disposal in an  appropriate landfill of  the EB-03  "hot spot",  a
              semi-solid stain (polyamide and  polyurethane)  material.  This material is  not  amenable to the
              thermal desorption process,  as the material is comprised of polyurethane,  alkyd resins,
              etc.,  which  may affect the performance  of the thermal desorption unit.  (The actual  volume  of
              this material is estimated to be 1,000  -2,000 yd3,  and  is  considered part of  the subsurface
              excavation volume describe above.)

       •       Removal and  disposal of the 5 underground storage tanks located on the Fletcher's Elm
              Street property.  (This could take  also  place during Phase  1,  if appropriate)

       •       Treatment of the approximately 15,400 yd 3 of excavated soils by ex-situ  thermal desorption.
              The thermal  desorption unit would  be preferably located on the  Fletcher's Elm Street
              property.  This may involve the placement of the mobile  unit at  one or more locations on the
              property  during the excavation and treatment operations. Liguid PCB condensate produced from
              the thermal  desorption process will be  disposed of off-site at  an appropriate facility.
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              Backfilling of the treated soils on-site.

              Final grading of and placement of a 10 inch soil cover over the treated soils,  or placement
              of treated soils within the top foot,  which can demonstrate PCB concentrations  less than or
              egual to 1 mg/kg PCB.  Asphalt would be placed on areas designated for parking,  consistent
              with the final grading plans and the future anticipated use of the Site.  The asphalt
              covering will promote drainage and further minimize infiltration through the residual
              contamination at the Site.  Restoration and landscaping of the remaining areas,  not covered
              by asphalt.  Erosion control measures will  be incorporated into the final grading to prevent
              erosion of the cover materials off-site and into the Souhegan River.

              Institutional controls,  in the form of deed restrictions would be implemented to prevent
              unauthorized access into the subsurface. Deed restrictions would also have to implemented
              to restrict future use of the Site,  or the modification of the cover  or surface drainage
              structures in ways inconsistent with this  remedy or the anticipated future use  of the Site.
GROUNDWATER
       •       Establish a Groundwater Management Zone (GMZ)  under NH's Comprehensive Groundwater Policy.
              The GMZ sets plume boundaries within which groundwater will be monitored over time to ensure
              that the contaminant concentrations are decreasing; to ensure that the remaining
              contamination has not migrated beyond the  established plume boundaries or impacted the
              Souhegan River;  and that the covers are working and remaining effective over time.
              Institutional controls would have to be implemented to restrict the use of the groundwater
              within the GMZ while contaminant concentrations are in excess of drinking water standards.
              Further action may be necessary consistent with the NH Comprehensive Groundwater Policy.

       •       Interim Groundwater Cleanup Levels must be achieved within the GMZ and maintained for a
              period of three  consecutive years. A risk  assessment will be performed on residual
              groundwater contamination to determine protectiveness of the remedy. If EPA determined  the
              remedy is not protective,  the remedial action shall continue until protective levels are
              achieved and not exceeded for three years  or until the remedy is deemed protective or is
              modified.

General Remedy Description

The selected remedy included thermal desorption for the treatment of the contaminated soils at the Site.
Thermal desorption is an innovative technology that uses heat, at relatively low temperatures  (600 to
10005F) ,  to vaporize contaminants and conseguently, separate those contaminants from the soil. Once
vaporized, the contaminants are typically collected through condensation and concentrated condensate is
then treated off-site at a TSCA approved incinerator. This alternative significantly reduces the volume
of contaminants to be treated or disposed of, and allows the treated soil to be backfilled on to the
Site.

Thermal desorption is a different process than incineration. Thermal desorption uses heat to physically
separate the contaminants from the soil, which then reguires further treatment. Incineration uses heat to
actually destroy the contaminants.

Site Preparation. The Site preparation work for has four elements:  (1) establishment of Site security,
(2) provision for drainage, (3) clearing, and  (4) development of a staging area. Depending on the
schedule and space reguirements needed for the remediation at Elm Street and Mill Street Sites,
preparation for both sites may be completed simultaneously or one after the other. The decision would be
made during the remedial design.

The chain link fence at Elm Street would be used to secure the processing area. Additional fencing may be
reguired to complete the fence around the perimeter of the Elm Street and Mill Street Sites to restrict
public access to the treatment facilities, contaminated soils, and areas of open excavation.

Site preparation work would include provisions for controlling site drainage to ensure proper drainage of
storm water away from the Site. Erosion controls would be used to prevent uncontrolled movement of
contaminated soils into uncontaminated areas during excavation activities.

Other site preparation activities include clearing and grubbing of trees and shrubs from the Elm Street
Site along Keyes Drive and the Souhegan River and along the railroad tracks at the Mill Street Site, as
necessary. Precautions would be taken during clearing and grubbing activities to limit exposure of the
vegetation to soil contamination.
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Three utility poles located on the Mill Street Site may require relocation to allow for soil excavation
activities. The final clearing activities would involve the removal of the existing geotextile liners
that currently exist at both the Elm and Mill Street Sites.

An area would be located outside of the 100-year floodplain to stage, as necessary, heavy equipment
access roads, automobile and truck parking lots, material transfer stations,  staging areas,
decontamination areas, equipment sheds or trailers, storage tanks, worker sanitary facilities, and
treatment systems.

The water collected during staging and dewatering of the soils excavated below the water table at the
Mill Street Site would be processed in a water treatment system that would have to be installed to treat
this and any other liquid effluent from dewatering operations required during excavation. Appropriate
discharge of the treated effluent will be required. If this effluent is treated on-site, discharge could
be to the Souhegan River or to an off-site treatment facility.

The Fletcher's Paint building would also be demolished and disposed of as part of the Site preparation,
and could take place in either Phase 1 or 2 of the remedial action. In removing the building, care would
have to be taken not to disturb the cemetery that is located on the east side of the building;
coordination with appropriate officials will b e required to accommodate any concerns about Site work
activities occurring in the buffer zone of the cemetery. The structure of the building is likely to have
limited contamination and will be disposed of or decontaminated in accordance with TSCA. If any hazardous
waste or asbestos is found, it will be disposed of appropriately. The foundation is expected to be
contaminated, especially near the back (northern) area used for paint manufacturing, and may require
off-site disposal in a TSCA chemical waste landfill, or RCRA Subtitle D landfill depending on the level
of PCB contamination found, or the ability to decontaminate the materials on-site, consistent with TSCA.
Consideration may be given to the use of the decontaminated demolition debris as backfill, in accordance
with TSCA and all State and local regulations.

Excavation. The soils would be excavated in accordance with depth and cleanup levels set forth in the
ROD. Shoring may be required along the excavation at Elm Street Site to allow continued use of Elm Street
during Site operations. If necessary, traffic may have to be temporarily directed along one lane of Elm
Street if shoring is not sufficient to ensure safe driving conditions until the excavation area adjacent
to Elm Street could be backfilled. All efforts would be undertaken to limit any impact to the flow of the
Elm Street traffic.

Excavation at the Mill Street Site would also require the cooperation of the railroad to ensure that
excavation activities can be conducted while allowing continued operation of at least one railroad spur.
Some of the highest levels of contamination at the Mill Street Site are present near and potentially
under the railroad bed. Any excavation conducted will be managed to ensure that the structural integrity
and safety of the railroad bed is not compromised.

Assuming an excavation rate of approximately 20 cubic yards of soil per hour, for 8 hour days, it would
be expected to take approximately 20 weeks (770 hours) to excavate the 15,400 yd 3 of soil at Elm Street
Site and approximately 17 weeks (675 hours) to excavate the 13,500 yd 3 of soil at the Mill Street Site.
Wetting agents and engineered operating procedures will be used during excavation to minimize the
generation of particulate emissions.

Excavation of the soil at a depth greater than 10 feet at the Elm Street Site may require the
installation of vertical sheet pilings along the edge of the Souhegan River to act as a retaining wall.
As the depth of excavation drops below the elevation of the river the sheet pilings would stabilize the
river bank and reduce the infiltration of water from the river into the deep excavated areas.
Installation of vertical sheet pilings at the Elm Street Site may be difficult due to the presence of
debris-laden fill material, which was dumped along the river bank during the operation of the former
burning dump as well as during development and construction of the Fletcher's facility.

At the Mill Street Site, the flow of groundwater will be minimized during excavation below the water
table, through lowering the water table using de-watering well(s), or trenches, which would be designed
and located during the remedial design. The extracted ground water would be treated separately or
combined with the liquid effluent from the dewatered soils and processed through an on-site or off-site
treatment system.

One concern regarding excavation at any depth is the volume of debris that was dumped at the Elm Street
Site as backfill material over what was the old Town of Milford burning dump. Discussions with the
Department of Public Works Superintendent for the Town of Milford indicated that fill material containing
tree stumps, concrete blocks, large chunks of asphalt, and old tires was commonly mixed with fill
material at the Elm Street Site. Drilling operations conducted on Site during the sampling phase reported
the existence of tree stumps, concrete material, and thick rubber debris. Estimates of the debris volume
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of the soil requiring excavation range from 10 to 30 percent.

Soil, debris and liquids with PCB concentrations greater than 50 mg/kg, and which cannot be treated in
the ex-situ thermal desorption or decontaminated on-site, would be transported to a TSCA-approved
landfill. TSCA approved landfills that could potentially accept the soils in bulk form include, but are
not limited to, the following:

              USPCI,  Grassy Mountain,  Tooele County,  Utah
       •      Chemical Waste Management,  Emelle,  Alabama
       •      Chemical Waste Management,  Model City,  New York
       •      Envirosafe,  Grand View,  Idaho

Soil and debris with PCB concentrations less than 50 mg/kg, and which cannot be treated with ex-situ
thermal desorption, would be transported over the highway to one of the RCRA Subtitle D landfills in the
area. RCRA Subtitle D landfills in the region near the Fletcher's Paint Site that could potentially
accept the soils include,  but are not limited to, the following:

       •      Waste Management,  Rochester,  New Hampshire
       •      Laidlaw,  Plainsville,  Massachusetts
       •      BFI,  East Bridgewater,  Massachusetts

Thermal Desorption of Contaminated Soils. Thermal desorption is a process designed to remove organic
compounds, including PCBs, from soils, sludges, and other media by vaporizing the contaminants from the
soil into the carrier gas. The contaminants in the gas are then cooled through the use of condensers into
a liquid form and then treated. The principal residuals from thermal desorption include the remediated
soil, captured particulate, condensed liquid contaminants, and exhaust from propane heaters if used as
the primary heating source. The remedy requires the off-site disposal of the liquid condensate in
accordance with TSCA.

Pretreatment of the soil will be necessary before processing. After the excavation (or simultaneously
along with excavation), the contaminated soil would be staged and dewatered, if necessary. The
contaminated soils would be screened before desorption to enhance the efficiency of the desorber and
protect the integrity of the desorber. After screening, the soil is conveyed into the thermal desorber
for treatment. Oversized debris from the screening process will be disposed of in accordance with TSCA.

The treated soil would be discharged from the desorber, and quenched with water to cool the material and
suppress fugitive dust emissions. Typical soil discharge temperatures are between 4005F and 5005F.
Treated soils would be stockpiled until soil sampling ensured that soil cleanup levels were met.

After leaving the desorber, the carrier gas is passed through a cyclone separator where entrained
particles are removed with a minimal drop in the off-gas temperature. The dry cyclone is followed by a
wet scrubber, where the gas stream cooled to its saturation temperature. The scrubber removes a portion
of the volatilized organics as the off-gas is cooled. Recirculated scrubber water continuously passes
through a phase separator that collects any condensed light organics from the liquid surface and
discharges a bottom sludge containing solids, water and organics. The scrubber sludge is sent to a filter
press, the floating organics are drummed and sent off-site to a TSCA approved incinerator and the
dewatered solids are reintroduced in to the thermal desorber feed stream. The aqueous phase from the
filter press is also recirculated back to the phase separator.

The scrubbed gas passes to the first heat exchanger  (condenser) where it is cooled to just above ambient
temperatures. This heat exchanger would produce the bulk of the liquid condensate. The carrier gas
proceeds through a second heat exchanger for further cooling. Liquid condensates from both heat
exchangers are used as make up to the phase separator. The organic phase from the condensates are then
separated from the water.  The PCB contaminated condenser distillate is drummed and sent to an off-site
TSCA incinerator.

The carrier gas would contain residual moisture and organics which were present in the feed. A mist
eliminator traps any residual droplets entrained in the stream and the liquid is transferred to the
condensate storage tank. The gas is heated to prevent condensate, and passed through a recirculation
blower. After the blower,  a small percentage of the carrier gas is vented and the remainder is heated
before returning to the desorber. The process vent gas stream passes through a particulate filter and
carbon adsorber before being released to the atmosphere. The spent carbon would be disposed of at an
appropriate facility or regenerated. Propane fuel exhaust from the desorber burners can be vented
directly to the atmosphere without treatment.

Site Restoration. Restoration activities will include backfilling the excavated pits with the treated
soils, replacing, demolishing/disposing of any staging areas, compacting and grading the Site,
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reconstructing any existing roads, adding top soil, asphalt and hydro-seeding, as applicable. The final
surface covering and grading of the Elm Street and Mill Street properties is flexible and can be altered
in any way, consistent with the future anticipated uses of the Site.

The portion of the storm drainage line near the Mill Street Pond, which is aboveground will be repaired
during Site restoration. Specifically, drainage controls will be installed to limit soil erosion along
the ditch, while promoting drainage away from the Mill Street Site and the residential properties.

At Elm Street, the storm drainage system currently under the Fletcher's Paint Works building is not
accessible by town personnel since the system lies, in some places, 17 feet below the surface. Since
contaminated groundwater discharges through the drainage culvert during the seasonally high groundwater
table, re-routing and actual placement of the new drainage system within a utility corridor will be
necessary and actual location of the drainage system will have to be part of the remedial design. The
original drain will be filled to prevent further flow through it, and into the Souhegan River.

Air Monitoring. During the excavation and treatment operations, air monitoring would be performed to
ensure that nearby residents and on-site workers are protected. Air sampling stations would be located at
representative points throughout the Site, along the perimeter of the Site, and at sensitive receptors
outside of perimeter of the Site. Samples would be analyzed at a minimum for VOCs and PCB-contaminated
particulate.

Long-Term Monitoring Plan. The long-term monitoring plan would be designed to (1) monitor any changes in
surface soil, sediment, ground water and surface water PCB concentrations; and (2) to ensure that the
remedy remains protective of human health and the environment.

Sampling would be conducted during the remedial action until the Site soils have achieved the PCB cleanup
levels. The soil cleanup levels are expected to be attained within 5 years after the start of the
remedial action, therefore the monitoring would not be a long-term program. It would continue for
approximately 10 years which should provide sufficient data to demonstrate the removal of all
contamination, and sufficient to monitor the long-term protectiveness and permanence of the remedy.
Because of the close proximity to the Souhegan River, surface water and sediment would be included in the
long-term monitoring plan to evaluate the effectiveness of the cover to confirm that contaminants are not
migrating into these media. EPA does not anticipate that any residual hazardous substance remaining in
the soils at both Elm Street or Mill Street after the excavation, treatment, and capping will result in a
future exceedance above Interim Cleanup Levels in the groundwater. This will be confirmed during the
implementation of the long-term monitoring program.

Ground water monitoring would also be included in the long-term monitoring program to monitor the
contaminant concentrations within the Groundwater Management Zone to ensure that the contaminant
concentrations are decreasing, are not migrating beyond the boundary of the GMZ,  and are not causing
exceedances in the surface water. Groundwater monitoring will continue until Interim Cleanup Levels have
been met and maintained throughout the GMZ for a period of 3 years.

Five-Year Reviews. Five-year reviews would be performed to evaluate whether the selected remedy remains
protective of public health and the environment over time. Five year reviews are reguired whenever
contamination is left in place at the Site at the completion of the remedial action. In this cleanup
plan, contaminated soils with concentrations of 100 mg/kg PCB or less will be left in place at depths
greater than 1 foot at the Elm Street Site, with the exception of the utility corridor. The five-year
reviews would be initiated five years after the start of the remedial action and continue until
contaminants no longer remain at the Site above levels that allow for unrestricted use and unlimited
exposure. A review would also be conducted prior to remedial action completion and Site delisting.

Time to Complete Remedial Action.

Soils
The time reguired to complete the remedial action using excavation and thermal desorption would be
approximately 2 years and 6 months if the operations were seguenced with phase 1 followed immediately by
phase 2. The time reguired for each component of the remedial action is estimated as:

Site Preparation - 6 months
Construction/Startup - 3 months
Operation  (Phase 1) - 8 months
Operation  (Phase 2) - 10 months
Site Restoration - 3 months
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Groundwater
Groundwater modeling predicted that with the source of the groundwater contamination addressed, would
take approximately 25 years for the VOCs within the overburden to reach the Interim Cleanup Levels and
approximately 100 years for the PCBs to reach the PCB Interim Cleanup Level in the overburden. While the
full extent of contamination is unknown, it is expected that the bedrock contamination will take longer
than the overburden to reach Interim Cleanup Levels. As part of the monitored natural attenuation of the
groundwater, additional bedrock wells will be installed, and the extent of bedrock contamination will be
evaluated to determine when and if the Interim Cleanup Levels will be attained.

Town Issues. The selected remedy reguires that the contaminated surface and subsurface soils that present
a risk to human health are excavated, and treated to levels that are permanently protective of the human
health.

The phasing of the cleanup allows for a more efficient use of the Site properties, thereby reducing any
potential use impact on the Keyes Field . While both portions of the Site are small in size, a thermal
desorption unit can be placed on the Elm Street property during the cleanup of the Mill Street Site. If
it becomes difficult to provide adeguate space at the Site for remedial eguipment, staging areas of clean
fill, and other remedial activities, consideration will be give to the use of the Keyes Field with the
Town's permission. The ability of the cleanup to be conducted, in preference, entirely on the Elm Street
Site, will be thoroughly examined and detailed during the design.

Traffic on Mill Street may have to be temporarily rerouted during certain activities because of the small
size of the Mill Street Site and the activities involved. However, previous removal efforts were
undertaken with the closure of only one lane of the two lane road. Future utilities and replacement of
the storm drainage system would be performed during backfill operations. Access to these utilities would
be accomplished through manholes, etc. which will be designed into the cover system. Deed restrictions
would be implemented regarding access and use restrictions to the subsurface at the Elm Street Site.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Fletcher's Paint Works and Storage Facility
Superfund Site is consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy is
protective of human health and the environment, attains ARARs, or invokes an appropriate waiver, and is
cost effective. The selected remedy also satisfies the statutory preference for treatment which
permanently and significantly reduces  the mobility, toxicity or volume of hazardous substances as a
principal element. Additionally, the selected remedy utilizes alternate treatment technologies or
resource recovery technologies to the maximum extent practicable.

A. The Selected Remedy is Protective of Human Health and the Environment

The remedy at this Site will permanently reduce the risks posed to human health and the environment by
eliminating, reducing or controlling exposures to human and environmental receptors through treatment,
engineering controls, and institutional controls; more specifically this remedy will permanently reduce
the risks presently posed by human health and the environment through:

       •      Excavation of soils to a depth of one foot at both the Elm and Mill Street Sites,  and to a
              depth of 10 feet within the utility corridor at the Elm Street Site wherever contamination
              exceeds the soil cleanup,  levels set in this ROD.

       •      On-site treatment of these excavated soils by ex-situ thermal desorption.

       •      Off-site disposal of any soil,  debris or liguid contaminated with PCBs above cleanup levels
              or is too large to be effectively treated by the thermal desorption system.

       •      Appropriate off-site disposal of the PCB-contaminated oil condensate.

       •      Long-term containment of the remaining contaminated soils present at depths  greater than 1
              foot and outside of the designated utility corridor (s)  as follows:

                  - excavation and treatment on-site in the thermal desorption system of the remaining
                    soils exhibiting concentrations of PCBs greater than 100 mg/kg PCB at the Elm Street
                    Site, and 1 mg/kg PCB at the Mill Street Site; or to a PCB concentration at which
                    leaching models and/or soil column testing show that infiltration through the
                    remaining PCB soil concentrations will not result in future groundwater
                    concentrations in excess of the 0.5 ug/1 MCL groundwater concentration for PCBs. The
                    determination of a subsurface soil cleanup level other those set above for PCBs, will
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                    be in the sole discretion of the EPA.

       •       Backfilling of the treated soils on the Site,  and restoration of the Site,  including
              placement of soil  and asphalt covers,  consistent with the future uses of the Site.

       •       Natural attenuation and the long term monitoring of the contaminant concentrations  in the
              groundwater to ensure that the Interim Cleanup Levels are met within the GMZ and that
              contamination is not migrating beyond the boundaries of the GMZ,  or impacting the Souhegan
              River

       •       Institutional Controls to restrict the future  uses of the properties,  to prevent damage to
              the covers and access to the remaining contaminated soils,  and restrictions on the  use of
              the contaminated groundwater until the Interim Cleanup Levels are met and maintained.

The remedial actions, as proposed, will be protective of human health and the environment. Treatment of
the soil contaminated to a depth of one foot at both the Elm and Mill Street Sites and to a depth of 10
feet within the utility corridor at the Elm Street Site, wherever contamination exceeds the soil cleanup
levels set in this ROD, will eliminate current and future exposure risks from direct contact and
incidental ingestion.

The selection of the long-term containment option of reducing all remaining PCB contamination at the Elm
Street Site to 100 mg/kg PCB, and all remaining PCB contamination at the Mill Street Site to 1 mg/kg PCB
- or to levels which would not cause an exceedance of the PCB MCL in groundwater in the future - provides
the greatest protection of human health and the environment because it treats all the PCB contaminated
soil that could potentially impact the groundwater under the Site in the future. The determination of a
subsurface soil cleanup level other those set above for PCBs, will be in the sole discretion of the EPA.
Institutional controls will be exercised, restricting the use of the groundwater, thereby eliminating the
future ingestion exposure until  natural attenuation processes can reduce the contaminant concentrations
in the groundwater to safe levels. A long-term monitoring program will ensure the remedy remains
protective of human health and the environment.

Implementation of the selected remedy will not pose unacceptable short-term risks or cross media impacts
since the technology, while still innovative, has been successfully demonstrated at many Superfund Sites
with PCB contamination, and pilot studies may be conducted at the Site before full scale operations
begin. Phasing of the remedy allows the most use of the Site itself, thereby reducing public
inconvenience. Finally, engineering controls and air monitoring will be employed and precautions taken to
minimize potential air emissions at the Site during excavation activities.

Moreover, the selected remedy will achieve potential human health risk levels that attain the 10 -4 to 10
-6 incremental cancer risk range and a level protective of noncarcinogenic endpoints, and will comply
with ARARs and To Be Considered criteria. At the time that the Interim Ground Water Cleanup Levels
identified in the ROD and newly promulgated ARARs and modified ARARs which call into guestion the
protectiveness of the remedy have been achieved and have not been exceeded for a period of three
consecutive years, a risk assessment shall be performed on the residual ground water contamination to
determine whether the remedial action is protective. This risk assessment of the residual ground water
contamination shall follow EPA procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by ingestion of ground water. If, after review of the risk assessment, the
remedial action is not determined to be protective by EPA, the remedial action shall continue until
protective levels are achieved and have not been exceeded for a period of three consecutive years, or
until the remedy is otherwise deemed protective or is modified. These protective residual levels shall
constitute the final cleanup levels for this ROD and shall be considered performance standards for this
remedial action.

B. The Selected Remedy Attains ARARs

This remedy (modified versions of SC-6 and MOM-2) will attain or waive all applicable or relevant and
appropriate federal and state reguirements that apply to the Site. A discussion of which reguirements are
applicable or relevant and appropriate may be found in the FS report for the source control and
management of migration alternatives. A brief narrative summary of the ARARs follows. Refer to Tables 27
through 32 of this ROD for a comprehensive presentation of the ARARs and other policies, criteria and
guidances to be considered  (TBCs) that pertain to the selected remedy.

Chemical Specific ARARs

The Safe Drinking Water Act  (SDWA) Maximum Contaminant levels  (MCLs) and the State Ambient Groundwater
Quality Standards  (AGQSs) , were  used to determine appropriate Interim Cleanup levels for the groundwater
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and for the soils. The more stringent of these standards were used to establish groundwater and soil
cleanup levels for the Site.

Location Specific ARARs

Excavations at the Site will not discharge excavated or fill materials into the Souhegan River or Mill
Street Pond in accordance with the Clean Water Act, the NH Wetlands Act and the NH Dredging Rules. The
remedy is the best practical alternative and all excavation will be undertaken with control of wetland
excavation and with minimal impacts to the risk of flood loss in the floodplains, to the greatest extent
possible. Restoration will be performed following any such excavation according to the Protection of
Wetlands Executive Order No. 11990, the Protection of Floodplains Executive Order No. 11988 and the NH
Wetlands Act.

Action Specific ARARs

Toxic Substances Control Act. Toxic Substances Control Act. The Toxic Substances Control Act  (TSCA) 40
CFR Part 761, as amended, addresses the cleanup, storage and disposal of PCBs. The reguirements of TSCA's
Subpart D- Storage and Disposal Sections 761.60, 761.61, and 761.65, as amended, are applicable because
the selected remedy involves the storage and disposal of soils and liguids contaminated with PCBs.

At both the Elm and Mill Street site, PCB-contaminated surface soils to a depth of 1 foot, will be
treated on-site to a residual PCB concentration of less than or egual to 1 mg/kg and placed back in the
excavated area. At the Mill Street site PCB-contaminated subsurface soils will remain on-site at a
concentration of less than or egual to 1 mg/kg and at Elm Street, PCB subsurface soils will remain
on-site at concentrations of less than or egual to 100 mg/kg, except within the utility corridor where
the PCB concentration will be less than or egual to 25 mg/kg. The placement of soils with PCB
concentrations of less than or egual to 1 mg/kg and less than or egual to 100 mg/kg under an asphalt and
10-inch soil cover, at Elm Street and Mill Street respectively, would provide a permanent and protective
remedy that satisfies the reguirements of the °761.61(c).

Storage

While waiting to be treated, PCB remediation waste may be stored in accordance with °761.65.
°761.65(c)(9) permits bulk PCB remediation waste to be stored at the cleanup site for 180 days, subject
to the following conditions:

       •      The waste is placed in a pile designed and operated to control dispersal of the waste by
              wind,  or where necessary,  by means other than wetting.
       •      The waste must not generate leachate through decomposition or other reactions;
       •      The storage site must have a liner designed to comply with the reguirements of Section
              761.65(c) (9) (iii) .

Liguid PCBs produced from the thermal desorption treatment, in accordance with °761.65(c)(1), are
reguired to be stored for no more than 30 days. Pursuant to °761.61(c), however, the Regional
Administrator has determined that liguid PCB remediation waste may be stored for a longer period of time
than prescribed in °761.65(c)(1). This determination was based on technical, environmental, and/or waste
specific characteristics or considerations, that the proposed storage methods will not pose an
unreasonable risk of injury to health or the environment.

Disposal

Section 761.61 (a)(5)(i)(B)(2)(ii) provides that soil or debris contaminated with PCBs at concentrations
of less than 50 mg/kg shall be disposed of in accordance with °761.61  (a)(5)(v)(A), which provides the
following disposal options:

       •      a municipal solid waste landfill permitted under Part 258;
       •      a non-municipal,  non-hazardous landfill permitted under °°257.5 through 257.30;
              RCRA Subtitle C landfill permitted to accept PCB waste;  or
              a TSCA approved PCB disposal facility.

Soils or debris contaminated with PCBs at concentrations of greater than or egual to 50 mg/kg will be
disposed of:

       •      in a hazardous waste landfill approved under °3004 of RCRA;
       •      in an incinerator approved under °761.70;
       •      by an alternative disposal method approved under °761.60(e);  or
       •      in a chemical waste landfill approved under °761.75
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Liquid PCB remediation waste will either be decontaminated to the levels specified in °761.79(b)(1) or
(b)(2) or be disposed of in accordance with °761.60(a), °761.60(e), or °761.61(c).

Resource Conservation and Recovery Act  (RCRA)  and the NH Hazardous Waste Management Act and Hazardous
Waste Rules. State  (and federal as incorporated by the state) hazardous waste regulation are applicable
to actions occurring on-site which generate hazardous waste. Undisturbed waste left in place, although
not characterized, is determined to be similar to RCRA waste; therefore certain state and federal
hazardous waste regulations are relevant and appropriate for actions taken on-site to address these
wastes. RCRA Land Disposal Regulations are neither applicable nor relevant and appropriate since all
movement of contaminated soils occur on-site within an area of contamination, and placement does not
occur.

Hazardous waste generated and stockpiled onsite for longer than 90 days through excavation, demolition or
treatment will be stored in waste piles or in tanks in accordance with 40 CFR 262.34 and 40 CFR 264
Subparts J and L before final disposal. Certain closure requirements are relevant and appropriate for the
Site such as groundwater monitoring and long-term monitoring and maintenance plans. Cover requirements
are also relevant and appropriate; however as explained below, EPA is invoking the equivalency waiver for
cover requirements under CERCLA 121(d)(40(D).  In addition, certain portions of the State hazardous waste
facility siting requirements are waived pursuant to Env-Ws 353.10 as explained below.

Air Regulations. The design and operation of the thermal desorption treatment system will meet the air
pollutant emission standards and monitoring requirements under the respective Subparts P, AA, and CC of
RCRA, and the NH Administrative Code, Air Chapter 100, Parts 604-606, Env-Wm 702.11 and 702.12 as well as
the NH Env-A 1002 and 1305.

Dust and asbestos m the Site during demolition and excavation would need to comply with the Clean Air Act
and the State of New Hampshire Air Regulations for emissions during demolition,  excavation and
transportation of the contaminated soils. Engineering controls would be used to minimize the fugitive
dust emissions, including wetting the soils and using foams, as necessary.

While each thermal treatment unit varies, contaminants present in the carrier gas is assumed to be
negligible due to the pollution control devises on the unit such as condensers,  filters and the use of
activated carbon. Propane fuel, if used, should bum cleanly in the desorber and the exhaust could be
vented directly to the atmosphere. Air monitoring of the thermal treatment unit would be performed to
ensure compliance with the NH Air Regulations.

Water Regulations. The monitored natural attenuation of the groundwater will comply with the Clean Water
Act and the Safe Drinking Water Act which establish Ambient Water Quality Criteria  (AWQCs)for surface
waters and MCLs for drinking waters.  The groundwater at the Site will be monitored to ensure that the
MCLs, which are relevant and appropriate for groundwater,  are attained in the future and that the
Souhegan River Surface waters are not impacted by the contaminated groundwater and comply with the AWQCs.

Waivers

Storage Requirements
Any hazardous waste and PCB contaminated materials generated during the RI/FS has required storage and
may continue to require storage until the start of the remedial action, exceeding regulatory storage
limitations under TSCA and the State Hazardous Waste Regulations. The final disposition of these wastes
comply with ARARs, as the investigative derived wastes currently stored on the Site will be treated via
thermal desorption, consistent with the selected remedy. An interim remedy waiver pursuant to CERCLA °
121  (d)(4)(A) is being invoked for the RCRA and TSCA Storage limitations for RI/FS generated wastes since
the wastes currently stored on the Site is interim in nature and the final remedy will comply with all
ARARs for final disposition of the waste.

NH Hazardous Waste Treatment Facility Siting Requirements
The siting requirements for new facilities for hazardous waste treatment under the New Hampshire
Hazardous Waste Regulations are applicable for the selected remedy, which includes the on-site treatment
of contaminated soil and groundwater  (from the de-watering operation). The Env-Wm 353.09 siting
regulations specify various siting requirements that must be complied with or waived under Env-Ws 353.10.

During implementation of the remedy,  the siting of the thermal desorption system would likely be on the
Elm Street Site and the de-watering groundwater treatment system would likely be on the Mill Street
property.

A waiver is invoked for certain portions of the siting requirements for new facilities due to the on-site
treatment required as part of the selected remedy. Under the provisions of Env-Ws 353.10, these
requirements can be waived if it can be demonstrated clearly and convincingly that the facility will not
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pose an unreasonable risk to public health or the environment. The Administrative Record for this Site
demonstrate that the engineering safeguards of the facility will be designed to ensure normal operation,
prevent public health threatening accidents, and mitigate hazardous waste discharges to the environment.
Specifically waivers are being invoked for the siting reguirements 353.09 (b)  (2) location within a
100-year flood plain and 353.09(d)  ,  location within the specified distance to a residence, school, home
for the elderly, adjacent property line, surface water public intake system, edge of river, within a
non-bedrock aguifer with greater than 200,000 g.p.d yield and within a class A rivershed.  (See Figure 16
for Floodplain boundaries).

A waiver of the closure reguirements of Env-Wm708.02 is invoked pursuant to CERCLA ° 121 (d)(4)(D) on the
grounds that the cover systems of the selected remedy attain an eguivalent performance standard as
reguired by State regulations. At Mill Street, soil will be cleaned up to 1 mg/kg PCB and an asphalt
cover applied over the backfilled,  treated soil. At the Elm Street Site soil will be cleaned up to 100
mg/kg PCB and the cover material is a combination of soil and asphalt, thus eliminating risks from
exposure to the subsurface soils from dermal contact and incidental ingestion. The soil and asphalt cover
meet the performance reguirements of the NH Closure regulations. Specifically, the soil and asphalt cover
will be designed to promote drainage, thus minimizing the infiltration of the precipitation and the
generation of leachate. The placement of the asphalt over the majority of the Elm and Mill Street Site
meets the reguirement that the cover material be less permeable than the bottom material, which for this
Site is natural soil materials with very high permeabilities. The asphalt cover will also be designed to
control and direct run-off from the Site as well as prevent erosion of the cover materials off of the
Site and into the surrounding properties or into the Souhegan River. The cover materials will be
maintained in such a way as to ensure that these performance standards will be met at the Site.

To be Considered

The following policies, criteria, and guidances will also be considered (TBCs) during the implementation
of the source control and management of migration remedial actions:

              Toxic Substance Control Act (TSCA) ,  PCB Spill Cleanup Policy;
       •      EPA Guidance  on Remedial Actions for Superfund Sites with PCB  Contamination;
       •      EPA Groundwater Protection Strategy
       •      EPA Guidance  on Presumptive Response Strategy and Ex-Situ Treatment Technologies for
              Contaminated  Groundwater at CERCLA Sites;
       •      EPA Policy Directive  for the Use of Monitored Natural Attenuation at Superfund,  RCRA
              Corrective Action,  and  Underground Storage Tank Sites;

C. The Selected Remedial Action is Cost-Effective

In the Agency's judgment, the selected remedy is cost effective, i.e., the remedy affords overall
effectiveness proportional to its costs. In selecting this remedy, once EPA identified alternatives that
are protective of human health and the environment and that attain, or, as appropriate, waive ARARs, EPA
evaluated the overall effectiveness of each alternative by assessing the relevant three criteria—long
term effectiveness and permanence;  reduction in toxicity, mobility, and volume through treatment; and
short term effectiveness, in combination. The relationship of the overall effectiveness of this remedial
alternative was determined to be proportional to its costs.

The costs of this remedial alternative are:

                   Source Control        Management of Migration                Total Costs
                   SC-6: Thermal         MOM-2: Monitored Natural
                   Desorption            Attenuation/Institutional Controls

Capital Cost       $11,791,615           $0                                      $11,791,615

O&M Cost           $39,000               $198,380                                $237,380

Present Worth      $12,292,375           $2,439,600                              $14,731,975
Cost

The costs of this remedial alternative are presented in Appendix F. A comparison of costs associated with
the FS alternatives were presented in this ROD in Tables 25 and 26.

With the exception of the no action and limited action alternatives, all of the source control
alternatives, SC-4 through SC-8,  are protective of human health and the environment and attain ARARs.
Comparing these alternatives, EPA's selected remedy combines the most cost effective remedial components
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evaluated, and makes changes to reflect the anticipated future uses of the Site and public comment.
Specifically, the selected remedy is less expensive than the treatment alternatives presented in the FS
as a result of changes in the subsurface soil cleanup levels, and long-term management actions. The
selected remedy is cost effective in that these changes actually make the Site more protective for less
costs. In addition, a smaller volume of soil would also be excavated, while providing a higher level of
long-term permanence and protection at the Site since the concentrations of the soils remaining at the
Site are protective of groundwater from leaching with only a soil cover. While the selected remedy would
cost approximately $3 to 4 million more than a full containment remedy  (SC-3),  a full containment was not
supported by the public, the Town or the State. The selected remedy, while more costly, provides for the
complete removal of soil contamination for the protection of both human health from direct contact,
incidental ingestion and leaching of the soils into the groundwater in excess of the PCB MCL for
groundwater, reguiring only future long-term monitoring of the contaminated groundwater and institutional
controls on the future use and access to the Site and use of the groundwater as a drinking water supply.
A full containment remedy would reguire the installation and operation of a pump and treat hydraulic
control system at the Mill Street Site which would be anticipated to be operated for over 100 years, due
to the high levels of contamination at the Site, and the slow transport of that migration over time into
the groundwater.

Because the source control action reguires that all soils are to be cleaned up such that they are
protective of the groundwater in the future with only a soil cover, the limited action alternative, MOM-2
becomes the most cost-effective management of migration alternative. Active management of migration
through pump and treat  (MOM-3,4,5 and 6) would not offer significant savings on the time reguired to meet
the cleanup levels since the effectiveness of groundwater extraction for TCB and PCBs is limited. The
majority of the pump and treat alternatives cost up to $1.5 million more than monitored natural
attenuation, while offering no increase to the level of protectiveness.

D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource Recovery
   Technologies to the Maximum Extent Practicable

Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs and that are
protective of human health and the environment, EPA identified which alternative utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of 1) long-term effectiveness and permanence;
2) reduction of toxicity, mobility or volume through treatment; 3)  short-term effectiveness; 4)
implementability; and 5) cost. The balancing test emphasized long-term effectiveness and permanence and
the reduction of toxicity, mobility and volume through treatment; and considered the preference for
treatment as a principal element, the bias against off-site land disposal of untreated waste, and
community and state acceptance. The selected remedy provides the best balance of trade-offs among the
alternatives.

With the exception of alterative SC-1, SC-2 and MOM-1, all the alternatives were determined to be
protective of public health and the environment and would attain (or waive) ARARs. Source control
alternatives SC-3 - SC-8 and management of migration alternatives MOM-2 - MOM-6 were compared using the
five balancing criteria above. In general, the combination of alternatives SC-6 and MOM-2 best satisfy
these criteria and in combination, were chosen as the recommended remedy. There is no direct opposition
to the use of thermal desorption at the site, other than PRP and public interest in EPA reviewing the
potential use of an innovative form of thermal desorption, which is performed by heating wells, in-situ.
Based on the data available to date, EPA was not able to fully evaluate this technology for comparison to
the ex-situ thermal desorption technology selected in the remedy. The selected remedy provides a higher
degree of long-term effectiveness and permanence by excavating and treating all soils that could pose a
long-term threat to human health and the groundwater when compared to the containment alternative SC-3
which would leave high levels of contamination in place at the Site. Thermal desorption would similarly
reduce toxicity, mobility and volume through treatment as would SC-8, solvent extraction; but would have
less short-term impacts and implementability issues. Off-Site disposal  (SC-4),  and solvent extraction
(SC-8) had comparable costs to thermal desorption. SC-6, thermal desorption was more expensive than both
containment  (SC-3) and solidification/ stabilization  (SC-7); and less expensive than off-site
incineration (SC-5).

Monitored natural attenuation, MOM-2, does not use treatment to reduce toxicity, volume or mobility of
the contamination in the groundwater, as would MOM-3 through MOM-6. However, in combination with the
source control actions, the groundwater will attain Interim Cleanup Levels through natural processes in a
reasonable time frame, when compared to active pump and treat it is unclear how effective pump and treat
would be for the attainment of the PCB and TCB cleanup levels given their slow transport through the
subsurface. MOM-2 costs less than MOM-3 through MOM-6 while offering a similar level of protectiveness.
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E. The Selected Remedy Satisfies the Preference for Treatment Which Permanently and Significantly reduces
   the Toxicity, Mobility or Volume of the Hazardous Substances as a Principal Element

The principal element of the selected remedy is the source control action which utilizes excavation and
treatment of the contaminated soils using ex-situ thermal desorption. Thermal desorption will remove and
concentrate the contaminants in the soil, thereby permanently reducing the volume of and mobility of the
contaminants on the soil. The condensate will be transported off-site to an approved TSCA incinerator for
treatment, thereby permanently reducing the toxicity of the contaminants at the Site.

The source control action addresses the primary threat at the Site, the contamination of the surface and
subsurface soils. Treatment of the subsurface soils also permanently removes contaminants that pose a
long-term threat to the groundwater. The selected remedy satisfies the statutory preference for treatment
as a principal element by excavating, treating on-site with ex-situ thermal desorption and sending the
condensate off-site for incineration.

Treatment of the contaminated groundwater is not part of the selected remedy, however natural attenuation
processes will eventually result in the attainment of the Interim Cleanup Levels in the overburden in
20-25 years for VOCs and 100 years for PCBs. Natural Attenuation processes may result in the attainment
of the Interim Cleanup Levels in the bedrock depending upon the full extent of the contamination within
the bedrock. The groundwater monitoring program will assess the potential for DNAPL within the bedrock
system. If DNAPL is conclusively found or concluded to be within the bedrock aguifer, a Technical
Impracticality waiver may be sought for the PCB MCL within the bedrock if the waiver standards are
demonstrated.

Although the management of migration portion of the remedy relies on natural attenuation to achieve
groundwater cleanup standards, the overall remedy is effective only through the active treatment of the
soils at the Site.

XII. DOCUMENTATION OF SIGNIFICANT CHANGES

EPA issued a Proposed Plan for remediation of the Site in December 1996 and presented it to the public at
a meeting held on January 14, 1997. EPA proposed a cleanup plan that would treat the soils that presented
the highest risks to public health and treat the highly contaminated soils within the subsurface at both
Elm Street and Mill Street that posed the greatest threat to groundwater in the future. The large volume
of remaining, lesser contaminated soils would covered with a cap to prevent the spread of the
contamination into the groundwater and the groundwater would be restricted from use, and monitored until
natural processes reduced contamination levels in the groundwater to acceptable levels.

In the Proposed Plan, the main components of the source control portion of the preferred alternative
incorporated a phased approach which included:

Phase 1 - Mill Street Site:

       •      the excavation and on-Site treatment using thermal desorption,  of all contaminated soils in
              the top 0 to 1 foot at the Mill Street Site;

       •      the excavation and on-Site treatment using thermal desorption of all contaminated soils  in
              the subsurface (from 1 foot to bedrock),  wherever concentrations were greater than 1 mg/kg
              PCB,  or to a level which,  in the future,  would not result in exceedances above the interim
              cleanup levels in the groundwater.  Placement  of the treated soils on the Site,  and
              restoration consistent with the expected future use of the property.

Phase 2 - Elm Street Site:

       •      the excavation and on-Site treatment using thermal desorption,  of all contaminated soils in
              the top 0 to 1 foot at the Elm Street Site;

       •      the excavation and on-Site treatment using thermal desorption of all contaminated soils  at
              the Elm Street Site in the subsurface from 1  to 10 feet where PCBs were greater than 10
              mg/kg;

       •      the excavation of all soils at Elm Street,  below 10 feet,  with PCB concentrations greater
              than 500 mg/kg;
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       •      the placement of a single-liner cap (RCRA Subtitle D)  over the remaining contaminated soils
              at the Elm Street Site to prevent the infiltration of precipitation,  Placement of the
              treated soils on the Site,  and restoration consistent with the expected future use of the
              property

The management of migration portion of the preferred alternative included use of natural attenuation
processes and long-term monitoring to attain the interim cleanup levels in the future. Institutional
controls were also included to restrict access to groundwater, thereby preventing ingestion of the
contaminated groundwater, until drinking water standards could be met.

The soil cleanup levels and depths in the Proposed Plan were set as a result of exposure assessments
relating to discussions with the Town of Milford regarding the anticipated future uses of the properties.
Specifically, the Town of Milford anticipated that the Town would take over both the Elm Street and Mill
Street properties. The Elm Street Site would become an extension to the Keyes Field, primarily for
extended parking purposes. In addition, the Town wanted future accessibility to the subsurface for
routine maintenance and repair to the drainage system and for possible unforseen activities associated
with the Keyes Field such as the placement of utilities associated restrooms, a concession stand, and
parking light installation. It was anticipated that the entire Site would not be covered in asphalt for
parking due to the steep slope presented at the Site, but that parking would be the primary purpose of
the future use of the Elm Street property. The Mill Street Site would be used to physically move Mill
Street from its current position, further north, thereby giving additional buffer between the Mill Street
residences and the road. No future use was anticipated for the subsurface at the Mill Street Site. The
excavation reguired under EPA's 1996 Proposed Plan, totaled approximately 33,300 cubic yards of
contaminated soil and was estimated to cost $17.9 million.

EPA accepted comment on the Proposed Plan from January 15, 1997 through April 21, 1997. EPA received a
letter from the Town of Milford reguesting EPA to accept changes in the anticipated future use of the Elm
Street Site, thereby also changing the scope of the final remedy. Specifically the Town of Milford
reguested that EPA consider incorporating a utility corridor(s) scenario within the Elm Street Site,
where any and all future maintenance of any utility and culvert system could be accomplished. By
restricting the future subsurface exposure pathways to a utility corridor(s) and placing restrictions on
access and use of the remainder of the subsurface at the Elm Street Site, future human health exposure to
the subsurface soils, re-deposited onto the surface through excavation would be eliminated. The surface
of the Site would remain consistent with the prior anticipated future use as primarily a parking area
extension to the Keyes Field. The Town noted that these recommended changes could result in a decrease in
the volume of soil that reguired excavation and treatment, thereby reducing costs and short term impacts
related to implementing the proposed plan alternative.

As a result of public comment on the EPA's 1996 Proposed Plan, EPA delayed the issuance of the Record of
Decision until changes could be made with respect to the future uses of the Site, and to accept and
review data on an innovative technology proposed for review called In-Situ Thermal Desorption  ("ISTD -
Thermal Wells"). This technology is being developed by Terratherm, a subsidiary of Shell Oil. GE has
proposed the ISTD - Thermal Wells as an alternative technology to the ex-situ thermal desorption
technology.

EPA held numerous meetings to discuss the Towns comments and how the FS alternatives could be adapted to
consider the new future use changes reguested by the Town. In addition, EPA reviewed data from pilot
studies where the ISTD-Thermal Well technology has been demonstrated. GE also submitted a Focused
Feasibility Study in December of 1997, which developed FS alternatives that included a mixtures of the
use of the ISTD - Thermal Well technology and the use of containment with hydraulic control to reach the
cleanup goals for the Site.

Significant changes to the scope of the remedy were made and incorporated into this Record of Decision as
a result of public comment and the review of subseguent materials in the time period between public
comment and the issuance of the Record of Decision. The significant changes made from the Proposed Plan
to this Record of Decision include the following:

Subsurface Soil Cleanup Levels:

Under an unrestricted recreational use of the Site, adults and children could be subject to unacceptable
risks from exposure to subsurface soils brought to the surface by future excavations. The Town of Milford
has indicated that future excavation of the Elm Street Site would be restricted to defined utility
corridor(s). This will prevent exposures to the adult and child recreational user to contaminated
subsurface soils. The 10 foot depth corresponds to a depth which is considered accessible in the
performance of utility placement and maintenance. The cleanup level for subsurface soil within the
utility corridor(s) at the Elm Street Site, is 25 mg/kg PCB, and is derived from EPA's Guidance on
Remedial Actions for Superfund Sites with PCB Contamination (EPA, 1990)  (TSCA PCB Spill Policy). The
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cancer risk for a utility worker who might be exposed to 25 mg/kg PCB in the utility corridor(s)  on an
infreguent basis is 4.6 x 10 -7. For non-carcinogenic risks, the Hazard Quotient at 25 mg/kg PCB for the
utility worker, is 0.3. (See Appendix E of this ROD for the calculations of the utility worker cancer
and Hazard Quotient).

No subsurface future uses are expected for the Fletcher's Mill Street property and therefore no exposures
were evaluated. However, the Draper Energy Coal Yard portion of the Mill Street Site has anticipated
future uses as a commercial property. Because no future access restrictions will be placed on the
subsurface soils at the Draper energy portion of the Mill Street Site, these subsurface soils will be
cleaned to 1 mg/kg PCB, consistent with the surface soil exposure criteria for the Site. The 1 mg/kg PCB
cleanup standard is also consistent with the Mill Street subsurface soil cleanup standard for the
protection of groundwater through the leaching of contamination to the groundwater.

Change to the Elm Street Long-term Management of residuals:

Soils not addressed above include those below 1 foot at the Elm Street Site, with the exception of the
area to be designated as the utility corridor. These soils are not expected to pose a threat to human
health through direct contact given their depth or location, based on anticipated future uses of the
property; however, contaminants at these depths could leach into the ground water and pose a threat to
human health through ingestion of ground water. The remedial action objective for these soils is to
prevent the leaching of contaminants from the soil to the ground water that will result in the
concentration of PCBs in the ground water in excess of health and risk-based ARARs.

As a result of the PCB migration analysis, long-term management controls for the PCB contaminated soils
were developed to prevent the leaching of the contaminants from the soils in the ground water in
exceedance of the MCL for PCB s. The Guidance for Remedial Actions for Superfund Sites with PCB
Contamination  [EPA, 1990]  was considered in addressing the contaminated soils that may be contained and
managed in place over the long term through appropriate engineering and institutional controls. The
long-term management controls developed for the Elm Street Site was presented in Source Control
Alternative 4.

The 1996 Proposed Plan addressed the these Site soils by reguiring excavation wherever concentrations
were greater than 500 mg/kg PCB. This reguired an excavation of an additional 1,600 cubic yards of soils
in addition to the excavation of 18,200 cubic yards of soils associated with the human health based
cleanup levels in the top ten feet of the Site, for a total of 19,800 cubic yards of contaminated soils
reguiring excavation.

Consistent with the EPA guidance and the TSCA long-term management controls, Sites where concentrations
of PCBs remaining are 500 mg/kg or less, a single, flexible membrane liner  (FML) cap consistent with RCRA
Subtitle D would be reguired to prevent the infiltration of precipitation and the leaching of the PCBs
into the groundwater above drinking water standards. Long-term monitoring would also be reguired to
assure that the cap remains protective of the groundwater. This cap would also reguire continuous
maintenance and restrictions would have reguired to prevent access to and potential damage to the cap.

The final remedial action plan reguires that all soils at the Elm Street Site, below 1 foot with the
exception of those within the utility corridor, be excavated wherever concentrations exceed 100 mg/kg PCB
or to a PCB concentration at which leaching models and/or soil column testing show that infiltration
through the remaining PCB soil concentrations will not result in future groundwater concentrations in
excess of the 0.5 ug/1 MCL groundwater concentration for PCBs. The determination of a subsurface soil
cleanup level other than 100 mg/kg PCB, will be in the sole discretion of the EPA. The remaining soils
are protective of groundwater, but not protective of a child or adult trespasser on the Site; therefore
while institutional controls will restrict future access into these soils, a 10-inch soil cover and
asphalt are reguired to maintain a protective layer from the contaminated soils and areas of unrestricted
access. Maintenance of the soil and asphalt cover would be conducted consistent with TSCA and State
regulations. This long-term management action of a soil and asphalt cover is consistent with the TSCA
long-term management controls where PCBs are left in place at the end of a remedial action that are
greater than 25 mg/kg PCB but less than or egual to 100 mg/kg, if the Site is covered with a cap meeting
the reguirements of 761.61 (a)7 and  (a)(8).  The cover also meets the performance standards of the State
closure regulations.

The amount of contaminated soil estimated to have concentrations greater than 100 mg/kg PCB, and thus
reguiring excavation as apart of the selected remedy is 11,600 cubic yards. The total excavation for the
Elm Street Site in the final selected remedy is 15,400 cubic yards, 4,400 cubic yards less than that
estimated for the Proposed Plan.

Change in the amount of soil reguiring excavation:
-------
Under the new cleanup scenario, the   volume of soils estimated to require excavation were reduced from
the 1996 Proposed Plan   estimate of 33,300 cubic yards to the following:
Elm Street Site:

Area
0- 1 foot:
Utility Corridor,
1-23 feet:
Mill Street:

Area
0-1 foot:
1 - bedrock:
1-10 feet:
Cleanup Level
1 mg/kg PCB
25 mg/kg PCB
100 mg/kg PCB
       Soil Volume
       2,800 cubic yards
       1,000 cubic yards
       11,600 cubic yards

Total: 15,400 cubic yards
                  Cleanup Level
                  1 mg/kg PCB
                  1 mg/kg PCB
                     Soil Volume
                     1,500 cubic yards
                     12,000 cubic yards
                                                  Total: 13,500 cubic yards

The total excavation for this ROD includes 28,900 cubic yards of soil.

Reduction of Costs:

The estimated costs for the 1996 Proposed Plan were $17.9 million. Due to the time lapse from the
generation of the FS alternative cost estimates and the Proposed Plan cost estimate, which were developed
using 1995 guotes, new estimates were developed to reflect the costs associated with the Proposed Plan
using 1997 guotes. The 1997 guotes for treatment using thermal desorption indicated that the most
conservative cost for treatment was $200 per ton. This estimate was less than the 1995 most conservative
guote of $250 per ton treated. The associated cost savings of $50 per ton, reduced the Proposed Plan
costs by approximately $1.8 million, to a new 1997 cost estimate of $16.1 million ($13.8 million for the
source control and $2.4 million for the monitored natural attenuation),

In addition, to reflect the changes accepted to the future use of the Elm Street Site, described above,
EPA also developed 1997 cost estimates for the Thermal Desorption alternative. While new 1997 cost
estimates were not developed for all of the FS alternatives, it should be noted that similar cost savings
for alternatives SC-4 through SC-8 would be recognized as a result of the changes in the future land use
assumptions. Since there would be no changes in the SC-1, SC-2 or SC-3 alternatives as a result of having
no impact from the change in the future use for the Elm Street Site, no 1997 cost estimates were
developed, and therefore the 1996 costs estimates as presented in this ROD remain accurate. This
information was presented to both GE and, the town of Milford in a letter dated March 6, 1998.

The estimated total volume of soil in the selected remedy, requiring excavation and treatment using
thermal desorption is 28,900 cubic yards. Using the most conservative 1997 cost estimates for thermal
desorption, the final selected remedy has a cost estimate of $14.7 million ($12.3 million for the source
control and $2.4 million for the monitored natural attenuation). This represents a $1.4 million decrease
in costs from the 1997 Proposed Plan costs and a $3.2 million decrease from the 1996 Proposed Plan cost
estimate.

Additional Potential for Cost Savings:

Additional costs savings can be reviewed at EPA's discretion, during implementation of the selected
remedy. These additional costs savings may include all or some of the following:

1) Cost savings could be seen during implementation of the final selected remedy as a result of lower
actual per unit ton treatment costs of thermal desorption treatment. While the most conservative 1997
quote of $200 per ton was used to develop the costs associated with the final selected remedy, less
conservative costs may be realized during implementation of the remedy. The costs for thermal desorption
are becoming more competitive as the technology sees more vendors available and gains more widespread use
and acceptance. Costs of $100 per ton are not unreasonable for some Sites.

If the costs for the treatment of thermal desorption were estimated to be $100 per ton, the cost savings
of the selected remedy would be approximately 2.7 million dollars. This would result in a final cost for
the remedy of $11.4 million ($9.6 million for source control and $2.4 million for monitored natural
attenuation).

2) Leaching modeling and/or soil column testing may be conducted during design to determine a site
specific PCB concentration that could remain in the subsurface and not result in a future exceedance of
-------
the 0.5 ug/1 PCB MCL in groundwater.  While these studies may or may not be undertaken during design any
increase in the PCB soil cleanup from the 1 mg/kg PCB concentration used in the cost estimate would
realize a cost savings, if EPA determines that the PCB concentration would be protective of the
groundwater in the future. The cost saving would be realized in the decrease in the volume of soil
reguiring excavation and treatment. For example, if EPA determined that an increase to 100 mg/kg PCB
would be protective of the groundwater at the Mill Street Site, this would result in 7,600 cubic yards
less soil reguiring excavation and treatment at an additional cost savings of approximately $2.6 million.
This could result in a cost reduction to $12.1 million for the remedy  ($9.7 million for the source
control and $2.4 million for the monitored natural attenuation).

If both cost saving scenarios described above are realized for the final remedy, a total cost savings of
approximately $4.5 million could be realized, for a potential cost estimate of $10.2 million. ($7.8
million for the source control and $2.4 million for the monitored natural attenuation).

The costs associated with this Record of Decision are $1.4 million less than the 1997 Proposed Plan
costs.

XIII. STATE ROIiE

The New Hampshire Department of Environmental Services has reviewed the various alternatives and has
indicated its support for the selected remedy. The State has also reviewed the Remedial Investigation,
the Baseline Human Health Risk Assessment and its amendments, the Preliminary Ecological Risk Assessment
and the Feasibility Study to determine if the selected remedy is in compliance with applicable or
relevant and appropriate State Environmental laws and regulations. The State of New Hampshire has not
concurred with the selected remedy for the Fletcher's Paint Works and Storage Facility Superfund Site as
of the signing of this ROD. EPA anticipates that the State will concur shortly. A copy of the declaration
of concurrence will be attached as Appendix A upon receipt.

















-------
                                   TABLES
TABIiE 1 - Field Laboratory PCB Results for Elm Street Soils  (Page  1  of  4)








Location





EB-Ola
EB-Olb
EB-02a
EB-02b
EB-03a

Depth (ft. )
0.0-2.0
2.0-4.0
4.0-6.0
8.0-10.0
10.0-12.0
12.0-14.0
14.0-16.0
16.0-18.0
18.0-20.0
20.0-22.0
22.0-24.0
24.0-26.0
28.0-29.5
30.0-32.0
32.0-34.0
38.0-40.0
44.0-46.0
51.5-53.0
ADL
Sequence No.
001
002
003
004
015
016
017
018
019
020/021
022
023
024
025
027
028
029
030
Sample
Date
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
Total
PCB Cone. (mg/kg)
5.3
8.6
3.1
0.1
—
—
—
—
—
—
—
—
—
—
—
—
—
—
                 20.0-21.5
                 25.0-28.0
                                     035
                                     189
11/4/91
0.
2.
4.
6.
8.
10.
12.
16.
19.
21.
22.
24.
31.
,0-2.0
,0-4.0
,0-6.0
,0-9.0
,0-10.0
,0-12.0
,0-14.0
,0-18.0
,0-19.3
,0-22.0
,0-24.0
,0-28.0
,0-31.4
005
006
007
008
009
010
Oil
012
013
014
026
030
031
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
10/30/91
1.8
5.3
1.8
1.4
1.0
3.0
0.9
95
15
34
28
5.8
0.6
11/21/91
                                                                     l.i
1.
3.
5.
9.
11.
13.
15.
17.
23.
29.
35.
41.
45.
,0-2.5
,0-5.0
,0-7.0
,0-10.5
,0-13.0
,0-15.0
,0-17.0
,0-19.0
,0-25.0
,0-31.0
,0-37.0
,0-43.0
,0-46.5
065
064
066
067/068
069
070
071
072
073
074
075
078
081
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
11/08/91
290
150
200
6700/7900
1900
110
79
1.7
2.3
0.5
0.1
—
0.3
- = Not detected.
-------
TABIiE 1 - Field Laboratory PCB Results for Elm Street Soils  (Page  2  of  4)
Location





EB-03b
EB-04a
EB-04c
EB-05a

Depth (ft. )
1.0-2.5
3.0-5.0
5.0-6.5
7.0-9.0
9.0-11.0
11.0-13.0
13.0-15.0
15.0-21.0
13.0-15.0
15.0-17.0
17.0-19.0
19.0-21.0
21.0-23.0
25.0-27.0
30.0-32.0
35.0-37.0
40.0-42.0
42.0-44.0
44.0-46.0
0.0-2.0
2.0-4.0
4.0-6.0
7.0-9.0
9.0-11.0
11.0-13.0
17.0-19.5
19.0-21.0
21.0-23.0
23.0-25.0
25.0-27.0
27.0-29.0
29.0-31.0
31.0-33.0
37.0-39.0
43.0-45.0
45.0-47.5
48.5-49.3
0.0-2.0
2.0-4.0
4.0-6.0
6.0-8.0
8.0-10.0
10.0-12.0
12.0-14.0
18.0-20.0
24.0-26.0
32.0-34.0
40.0-42.0
42.0-44.0
ADL
Sequence No.
087
089/090
092
091
095
096
101
100
146
147
148
149
150
159
160
161
171
172/173
174
076
077
079
082
083
084
097
098
103
104
107
108
111
112/113
117
128
118
129
191
192
193
194
195
196
197
199
200
201
216
217
Sample
Date
11/13/91
11/13/91
11/13/91
11/13/91
11/13/91
11/13/91
11/13/91
11/13/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
11/20/91
11/20/91
11/20/91
11/08/91
11/08/91
11/08/91
11/12/91
11/12/91
11/12/91
11/13/91
11/13/91
11/13/91
11/13/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
11/25/91
11/25/91
11/25/91
11/25/91
11/26/91
Total
PCB Cone. (mg/kg)
370
110/130
96
51
350
170
0.8
3.2
2.8
0.3
0.6
0.1
—
—
—
—
—
— /—
—
32
18
11
9.4
1.4
2.7
0.1
--
0.7
0.3
0.1
0.1
--
— / —
--
—
—
0.4
--
—
--
—
--
—
--
—
--
—
--
—
- = Not detected
-------
TABIiE 1 - Field Laboratory PCB Results  for  Elm Street Soils (Page 3 of 4)

Location
EB-05a (con. )
EB-06a
EB-06c













EB-lla
























EB 15







Depth (ft. )
48.0-50.0
57.0-59.0
0.0-2.0
2.0-4.0
4.0-6.0
6.0-8.0
8.0-10.0
10.0-12.0
12.0-14.0
20.0-22.0
26.0-28.0
30.0-33.0
37.0-39.0
43.0-45.0
51.0-53.0
53.0-55.0
0.0-2.0
2.0-4.0
4.0-6.0
6.0-8.0
8.0-10.0
10.0-12.0
12.0-14.0
14.0-16.0
16.0-18.0
18.0-20.0
20.0-22.0
22.0-24.0
24.0-26.0
26.0-28.0
28.0-30.0
30.0-31.5
31.5-33.0
37.0-39.0
43.0-45.0
49.0-51.0
55.0-57.0
59.0-61.0
65.0-67.0
71.0-73.0
73.0-77.0
1.0-2.5
4.0-6.0
9.0-11.0
15.0-17.0
19.0-20.5
24.0-26.0
39.5-39.7
ADL
Sequence No.
211
231
202
203
204
205
206/207
208
209
210
224
225
227
228
229
230
253/254
255
256
257
258
259
260
261
262
253
264
265
266
267
269
268
270
271
272
273
274/275
276
277
278
280
049
053
054
056
055
059
061
Sample
Date
11/26/91
12/2/91
11/25/91
11/25/91
11/25/91
11/25/91
11/25/91
11/25/91
11/25/91
11/26/91
11/26/91
11/26/91
11/26/91
11/26/91
12/02/91
12/02/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/04/91
12/05/91
12/05/91
12/05/91
12/06/91
12/06/91
12/06/91
12/06/91
12/06/91
11/06/91
11/06/91
11/06/91
11/06/91
11/06/91
11/06/91
11/07/91
Total
PCB Cone. (mg/kg)
--
--
—
--
—
--
—
--
—
--
--
—
--
—
--
—
—
--
—
--
—
--
—
--
—
--
--
—
--
—
--
—
0.1
—
—
--
— I—
—
—
--
—
14.000
18
940
210
640
11
0.3
- = Not detected
-------
TABIiE 1 - Field Laboratory PCB Results for Elm Street Soils  (Page 4 of 4)
Location





EB-16
EB-17
EB-18b
SS-04

Depth (ft. )
0.0-2.0
5.0-7.0
10.0-12.0
12.0-14.0
14.0-16.0
16.0-18.0
18.0-20.0
20.0-21.5
22.0-24.0
24.0-26.0
30.0-32.0
35.0-37.0
38.0-39.5
40.0-42.0
45.0-47.0
0.0-2.0
4.0-6.5
10.0-12.0
15.0-17.0
20.0-22.0
27.0-29.0
30.0-32.0
34.0-36.0
0.0-2.0
5.0-7.0
10.0-12.0
15.0-17.0
17.0-18.5
19.0-20.5
20.5-22.0
22.0-25.0
25.0-26.5
35.0-36.5
50.0-51.5
55.0-56.5
0.0-0.5
0.5-1.0
1.0-1.5
1.5-2.0
2.5-3.0
3.5-4.0
4.5-5.0
5.5-6.0
6.5-7.0
7.0-7.5
8.5-9.0
ADL
Sequence No.
106
109
110
114
115
116
119
120
121
122
124
125
126
127
141
032
034
036
039
085
040
041
042/043
292
294
295
296
297/298
299
300
302
303
304
305
306
232
241
242
243
244
245
246
247
248
249
250/251
Sample
Date
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/14/91
11/18/91
11/04/91
11/04/91
11/04/91
11/05/91
11/05/91
11/05/91
11/05/91
11/05/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/12/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
12/03/91
Total
PCB Cone. (mg/kg)
400
2.3
5.5
8.9
8.7
0.5
—
0.1
0.1
0.1
—
--
--
—
--
18
—
45
29
170
198
10.8
3.7/3.1
0.3
—
—
—
—
—
—
—
—
—
—
—
—
1.7
1.2
0.6
0.1
—
—
—
—
—
—
Notes: Field laboratory results reported on a wet-weight basis





- = Not detected
-------
            TABIiE 2 Estimated PCB Mass, by Depth and Location

       Location                              0-2 Feet                2-10 Feet

       Elm Street

                Contaminated Soil Volume  (CY)       5,620              17,480
            Average PCB Concentration (mg/kg)         660                 460
                        PCB Mass in Soil  (kg)       4,390               9,460

       Mill Street

                Contaminated Soil Volume  (CY)       3,770               9,280
            Average PCB Concentration (mg/kg)       6,370                 620
                        PCB Mass in Soil  (kg)      28,420               6,770


                   TABLE 3 -      RESULTS OF PCB-CONGENER ANALYSIS
               Fletcher's Paint Works and Storage Facility Superfund Site

Well ID                                         MW-07A
Sub Sample Location              bottom of bailer     top of bailer
Sample ID                            GW03JH              GW04JH
Date Collected                      18-Nov-97           18-Nov-97
Date Analyzed                       3-Dec-97             2-Dec-97

Total PCBs                          1781.85               45.96

PCB Homolog Distribution  (mole percent)

Mono                                  0.00                0.00
Di                                    0.93                2.21
Tri                                  35.86               35.94
Tetra                                48.31               46.34
Penta                                12.60               12.94
Hexa                                  2.13                2.35
Hepta                                 0.16                0.20
Octa                                  0.02                0.02
Nona                                  0.00                0.00
Deca                                  0.00                0.00

Aroclor Distribution*

Aroclor 1221                          0.00                0.00
Aroclor 1242                        215.64                5.23
Aroclor 1254                         78.37                2.16
Aroclor 1260                          0.72                0.02
Aroclor 1268                          0.00                0.00

Notes:
Unless otherwise specified, units are expressed as micrograms per litre (Ig/L) or parts per billion  (ppb)
PCBs - polychlorinated biphenyls
* Concentration of indicator peaks in Ig/L. A review of the chromatograms and PCB congener distribution
indicated that the PCBs in both samples are Aroclor 1242 with slight devolatilization and biodegradation
of selected less chlorinated PCB congeners.
-------
TABIiE 4  Field Laboratory PCB Results for Mill Street Soils  (Page  1  of  2)
  Location





EB-07a
EB-08a
EB-09a
EB-lOb
EB-12
EB-13

Depth (Ft. )
0.0-2.0
2.0-4.0
4.0-5.5
6.0-8.0
8.0-10.0
10.0-12.0
12.0-12.5
0.0-2.0
2.0-4.0
4.0-6.0
10.0-12.0
116.0-118.0
20.0-22.0
26.0-28.0
0.0-2.0
2.0-4.0
4.0-8.10
8.0-10.0
10.0-12.0
12.0-14.0
15.0-16.0
22.0-23.0
0.0-2.0
2.0-4.0
4.0-6.0
6.0-8.0
8.0-9.5
10.0-12.0
16.0-18.0
18.0-20.0
24.5-26.5
30.5-32.5
1.0-3.0
9.5-11.5
15.0-17.0
0.0-2.0
5.0-8.5
10.0-12.0
15.0-16.5
ADL
Sequence No.
130
131
132
135
136/137
139
140
285
286
287
288
289
290
291
233
234
235
238
239
240
279
281
046
165
166
167
168
169
170
175
188
190
047
050
051
086
088
093
094
Sample
Date
11/15/91
11/15/91
11/15/91
11/15/91
11/15/91
11/15/91
11/15/91
12/11/91
12/11/91
12/11/91
12/11/91
12/11/91
12/11/91
12/11/91
12/02/91
12/02/91
12/02/91
12/02/91
12/02/91
12/02/91
12/06/91
12/09/91
11/20/91
11/20/91
11/20/91
11/20/91
11/20/91
11/20/91
11/20/91
11/20/91
11/21/91
11/21/91
11/06/91
11/06/91
11/06/91
11/13/91
11/13/91
11/13/91
11/13/91
Total
PCB Cone
9,700
2,300
0.3
7
6.4/5.7
8
1.3
—
--
—
--
--
—
--
7.4
0.3
0.3
—
--
—
--
—
—
--
—
--
--
—
--
—
--
—
110,000
1,700
480
11,000
12
0.4
2
-------
TABIiE 4 Field Laboratory PCB Results for Mill Street Soils (Page 2 of 2)
  Location

EB-14
EB-19
SS-01
SS-02
SS-03
"-" = Not Detected





-------
TABIiE 7
Noncarcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Mill Street and Elm Street
Adults
                                                         Page 1 of 2
Chemical
Seinivolatile Organic Compounds

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Indeno(1,2,3-c,d)Pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-1248
Aroclor-1254
Inorganics
Arsenic
Chromium
Magnesium
Manganese
Nickel
Vanadium
 Relative
Absorption
  Factor
 100%
 100%
 100%
 100%
 100%
 100%
 100%
 100%

  30%
  30%

 100%
 100%
 100%
 100%
 100%
 100%
                                                 Exposure
                                                  Factor

                                                 kg/kg/day
5-5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07

5.5E-07
5.5E-07

5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
Exposure
Cone.

1.
1.
1.
5,
1.
1.
6,
2,
1.
1.
9,
1.
1.
1.
1.
1.
mg/kg
.2E+00
. 3E+00
. OE+00
. 9E-01
.2E+00
.5E+00
.8E.01
.OE+00
.3E+02
. 1E+01
.5E+00
. 8E+01
. 8E-03
. 4E+02
. 1E+01
. 4E+01
Average
Average Reference
Daily Dose
Dose
mg/ kg/day
6.
7.
5.
3.
6.
8.
3.
1.
2.
1.
5.
9.
9.
7.
5.
7.
8E-07
OE-07
5E-07
2E-07
6E-07
4E-07
7E-07
1E-06
IE-OS
9E-06
2E-06
7E-06
8E-04
9E-05
8E-06
4E-06
mg/ kg/day
ND
ND
ND
4.0E-03
ND
ND
ND
4.0E-03
ND
ND
3.0E-04
5.0E-03
ND
5.0E-03
2.0E-02
7.0E-03
Hazard
Quotients
Exposure
Cone.
mg/kg
NC
NC
NC
8E-05
NC
NC
NC
3E-04
NC
NC
2E-02
2E-03
NC
2E-02
3E-04
1E-03
6.
6.
3.
1.
6.
8.
2.
1.
1.
1.
2.
1.
6
3.
1.
2.
4E+00
8E+00
OE+00
5E+00
7E+00
8E+00
4E+00
2E+01
3E+03
5E+02
6E+01
1E+02
.5E+03
9E+02
2E+02
6E+01
Maximum
Average Reference
Daily Dose
Dose
mg/ kg/day
3.
3.
1.
8.
3.
4.
1.
6.
2.
2.
1.
5.
3
2.
6.
1.
5E-06
7E-06
6E-06
2E-07
7E-06
8E-06
3E-06
6E-06
1E-04
5E-05
4E-05
8E-05
.6E-03
2E-04
4E-05
4E-05
mg/ kg/day
ND
ND
ND
4.0E-03
ND
ND
ND
4.0E-03
ND
ND
3.0E-04
5.0E-03
ND
5.0E-03
2.0E-02
7.0E-03
Hazard
Quotients

NC
NC
NC
2E-04
NC
NC
NC
2E-03
NC
NC
5E-02
1E-02
NC
4E-02
3E-03
2E-03
                                                                             Estimated hazard index 4E-02
                                                                             average concentration =
        Please refer to Attachment #1, and the reference for this table, for the correct
        Hazard Quotients and Hazard Index numbers associated with ths exposure pathway.
                                                                                        Estimated hazard index 1E-01
                                                                                         maximum concentration =
-------
TABIiE 7
Noncarcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Mill Street and Elm Street
Adults
                                                         Page 2 of 2
Chemical
Seinivolatile Organic Compounds

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Indeno(1,2,3-c,d)Pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-1248
Aroclor-1254
Inorganics
Arsenic
Chromium
Magnesium
Manganese
Nickel
Vanadium
 Relative
Absorption
  Factor
 100%
 100%
 100%
 100%
 100%
 100%
 100%
 100%

  30%
  30%

 100%
 100%
 100%
 100%
 100%
 100%
                                                 Exposure
                                                  Factor

                                                 kg/kg/day
5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06

5.1E-06
5.1E-06

5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06
5.1E-06
Exposure
Cone.
mg/kg
1.2E+00
1.3E+00
l.OE+00
5.9E-01
1.2E+00
1.5E+00
6.8E.01
2.0E+00
1.3E+02
1.1E+01
9.5E+00
1.8E+01
1.8E-03
1.4E+02
1.1E+01
1.4E+01
Average
Average Reference
Daily Dose
Dose
mg/ kg/day
6.
6.
5.
3.
6.
7.
3.
1.
2.
1.
4.
9.
9.
7.
5.
6.
4E-06
6E-06
1E-06
OE-06
1E-06
8E-06
5E-06
OE-05
OE-04
7E-05
9E-05
OE-05
2E-03
3E-04
4E-05
9E-05
Estimated
mg/ kg/day
ND
ND
ND
4.0E-03
ND
ND
ND
4.0E-03
ND
ND
3. OE-04
5.0E-03
ND
5.0E-03
2.0E-02
7.0E-03
hazard index
Hazard
Quotients
Exposure
Cone.
mg/kg
NC
NC
NC
8E-04
NC
NC
NC
3E-03
NC
NC
2E-01
2E-02
NC
1E-01
3E-03
1E-02
3E-01
6.
6.
3.
1.
6.
8.
2.
1.
1.
1.
2.
1.
6
3.
1.
2.
4E+00
8E+00
OE+00
5E+00
7E+00
8E+00
4E+00
2E+01
3E+03
5E+02
6E+01
1E+02
.5E+03
9E+02
2E+02
6E+01
Maximum
Average Reference
Daily Dose
Dose
mg/ kg/day
3.
3.
1.
7.
3.
4.
1.
6.
2.
2.
1.
5.
3
2.
6.
1.
3E-05
5E-05
5E-05
7E-06
4E-05
5E-05
2E-05
IE-OS
OE-03
3E-04
3E-04
4E-04
.3E-02
OE-03
OE-04
3E-04
Estimated hazard
Hazard
Quotients
mg/ kg/day



4



4


3
5

5
2
7
ND
ND
ND
.OE-03
ND
ND
ND
.OE-03
ND
ND
.OE-04
.4E-04
ND
.OE-03
.OE-02
.OE-03
NC
NC
NC
2E-03
NC
NC
NC
2E-02
NC
NC
4E-01
1E-01
NC
4E-01
3E-02
2E-02
index 1E+00
                                                                          average concentration =
                                                                          Total estimated average
                                                                          hazard index =  4E-01
                                                                                 maximum concentration =
                                                                                 Total estimated maximum
                                                                                 hazard index =    lE+OONotes:
NA = Toxicity value not available from EPA
NC = Not calculated
Adults
E = Exposure Factor  (kg/kg/day) =
SI = Soil incidental ingestion rate  (mg/day)
CF = Conversion factor  (kg/mg)
EF = Exposure freguency  (days/year)
ED = Exposure duration  (years)
AT = Averaging time, non-carcinogenic  (24 years x 365 days
RAF =  Relative absorption factor  (PCBs 30%, Inorganics 100
BW = Body weight  (EPA, 1990)  (kg)
Exposure Factor (noncarcinogenic) =
                    SI X CF X EF X ED
                       BW x AT
                                 100
                             1.OE-06
                                 140
                                  24
                               8,760
                           EPA, 1989)
                                  70
                             5.5E-07
                                           Children 1 to 6

                                           E = Exposure Factor  (kg/kg/day)=

                                           SI = Soil incidental ingestion rate  (mg/day)
                                           CF = Conversion factor  (kg/mg)
                                           EF = Exposure freguency  (days/year)
                                           ED = Exposure duration  (years)
SI x CF x EF x ED
  BW x AT
              200
          1.OE-06
              140
                6
Average, daily dose  (mg/kg/day)=exposure factor x RAF x exposure concentration
                                           AT = Averaging time, non-carcinogenic  (6 years x 365 days/ye        2,190
                                            RAF = Relative absorption factor (PCBs 30%, Inorganics 100%, EPA, 1989)
                                           BW = Body, weight  (EPA, 1990)(kg)                                       15
                                           Exposure Factor  (noncarcinogenic) =                               5.1E-06
                                           Average daily dose  (mg/kg/day)=exposure factor x RAF x exposure concentration
-------
TABIiE 8
Carcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface, Soil - Mill Street and Elm Street
               Page 1 of 2
Adults
Chemical
Seinivolatile Organic Compounds
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Indeno(1,2,3-c,d)Pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-1248
Aroclor-1254
Inorganics
Arsenic
Chromium
Magnesium
Manganese
Nickel
Vanadium
Relative
Absorption
Factor
100%
100%
100%
100%
100%
100%
100%
100%
30%
30%
100%
100%
100%
100%
100%
100%



1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
Exposure
Factor
kg/kg/da'
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
. 9E-07
                                                              Exposure
                                                                Cone.

                                                                mg/kg
 ,2E+00
 , 3E+00
 , OE+00
 , 9E-01
 ,2E+00
 ,5E+00
 .8E.01
2.OE+00

1.3E+02
1.1E+01
  5E+00
  8E+01
1.8E-03
1.4E+02
1.1E+01
1.4E+01
                     Average
             Average     Cancer    Incremental
              Daily      Potency      Cancer
               Dose
            mg/kg/day  mg/kg/day -1
2.3E-07
2.4E-07
1.9E-07
1.1E-07
2.3E-07
2.9E-07
1.3E-07
3.7E-07

7.3E-06
6.4E-07

1.8E-06
3.3E-06
3.4E-04
2.7E-05
2.0E-06
2.5E-06
7.3E-01
7.3E+00
7.3E-01
  ND
7.3E-02
7.3E-03
7.3E-01
  ND

7.7E+00
7.7E+00

1.8E+00
  ND
  ND
  ND
  ND
  ND
2E-07
2E-06
1E-07
 NC
2E-08
2E-09
9E-08
 NC

6E-05
5E-06

3E-06
 NC
 NC
 NC
 NC
 NC
Exposure
Cone.
Average
Daily
Dose
Cancer
Potency
Factor
mg/kg mg/kg/day mg/kg/day
6
6
3
1
6
8
2
1
1
1
2
1

3
1
2
. 4E+00
. 8E+00
.OE+00
.5E+00
. 7E+00
. 8E+00
. 4E+00
.2E+01
.3E+03
.5E+02
. 6E+01
. 1E+02
6.5E+03
. 9E+02
. 2E+02
. 6E+01
1
1
5
2
1
1
4
2
7
8
4
2

7
2
4
.2E-06
.3E-06
. 6E-07
. 8E-07
.3E-06
.7E-06
.5E-07
.3E-06
.3E-05
.5E-06
. 9E-06
. OE-05
1.2E-03
. 4E-05
.2E-05
. 9E-06
7
7
7

7
7
7

7
7
1





.3E-01
.3E+00
.3E+01
ND
.3E-02
.3E-03
.3E-01
ND
.7E+00
.7E+00
.8E+00
ND
ND
ND
ND
ND
                                                      Maximum
                                                                         Incremental
                                                                           Cancer
                                                                            Risk
9E-07
9E-06
4E-07
  NC
9E-08
1E-08
3E-07
  NC

6E-04
7E-05

9E-06
 NC
   NC
 NC
 NC
 NC
                                                         Estimated incremental cancer risk
                                                                 average concentration =
                                     7E-05
                                        Estimated incremental cancer risk
                                              maximum concentration =
                                                                                           6E-04
                    Please refer to Attachment #1, and the reference for this table, for the correct
                    Hazard Quotients and Hazard Index numbers associated with this exposure pathway.
-------
TABIiE 8
Carcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Mill Street and Elm Street
Children Ages 1 to 6

Chemical



Seinivolatile Organic Compounds

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Indeno(1,2,3-c,d)Pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-1248
Aroclor-1254
Inorganics
Arsenic
Chromium
Magnesium
Manganese
Nickel
Vanadium
                Page 2 of 2
         Average
 Average     Cancer    Incremental
  Daily      Potency      Cancer
   Dose
mg/kg/day  mg/kg/day -1
             Maximum
            age      Cancer     Incremental
            ly      Potency       Cancer
            s        Factor        Risk
            /day   mg/kg/day -1
100%
100%
100%
100%
100%
100%
100%
100%
30%
30%
100%
100%
100%
100%
100%
100%
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
. 4E-07
1.
1.
1.
5,
1.
1.
6,
2,
1.
1.
9,
1.
1.
1.
1.
1.
.2E+00
. 3E+00
. OE+00
. 9E-01
.2E+00
.5E+00
.8E.01
.OE+00
.3E+02
. 1E+01
.5E+00
. 8E+01
. 8E-03
. 4E+02
. 1E+01
. 4E+01
5.4E-07
5.6E-07
4.4E-07
2.6E-07
5.3E-07
6.7E-07
3.0E-07
8.7E-07
1.7E-05
1.5E-06
4.2E-06
7.8E-06
7.9E-04
6.3E-05
4.6E-06
5.9E-06
7.3E-01
7.3E+00
7.3E-01
ND
7.3E-02
7.3E-03
7.3E-01
ND
7.7E+00
7.7E+00
1.8E+00
ND
ND
ND
ND
ND
4E-07
4E-06
3E-07
NC
4E-08
5E-09
2E-07
NC
1E-04
IE-OS
7E-06
NC
NC
NC
NC
NC
6
6
3
1
6
8
2
1
1
1
2
1

3
1
2
. 4E+00
. 8E+00
.OE+00
.5E+00
.7E+00
. 8E+00
. 4E+00
.2E+01
.3E+03
.5E+02
. 6E+01
. 1E+02
6.5E+03
. 9E+02
.2E+02
. 6E+01
2.8E-06
3.0E+06
1.3E+06
6.6E+07
2.9E+06
3.9E+06
1.1E-06
5.3E-06
1.7E-04
2.0E-05
1.1E-05
4.6E-05
2.8E-03
1.7E-04
5.1E-05
1.1E-05
7.3E-01
7.3E-00
7.3E-01
ND
7.3E-02
7.3E-03
7.3E-01
ND
7.7E+00
7.7E+00
1.8E+00
ND
ND
ND
ND
ND
2E-06
2E-05
1E-06
NC
2E-07
3E-08
8E-07
NC
1E-03
2E-04
2E-05
NC
NC
NC
NC
NC
                                                                          Estimated hazard index
                                                                         average concentration =
                                                                         Total estimated average
                                                                          hazard index =  2E-04
                         2E-04
 Estimated hazard index
maximum concentration =
Total estimated maximum
 hazard index =   2E+03
                                                                    2E+03
-------
Notes:
NA = Toxicity value not available from EPA
NC = Not calculated
Adults
E = Exposure Factor  (kg/kg/day) =

SI = Soil incidental ingestion rate  (ing/day)
CF = Conversion factor  (kg/mg)
EF = Exposure freguency (days/year)
ED = Exposure duration  (years)
RAF =  Relative absorption factor  (PCBs 30%,
BW = Body weight  (EPA, 1990)  (kg)
AT = Averaging time, carcinogenic  (days)
Exposure Factor (noncarcinogenic) =
          SI X CF X EF X ED
             BW x AT
                       100
                   l.OE-06
                       140
                        24
Inorganics 100%,  EPA,  1989)
                        70
                    25,550
                   1.9E-07
Average, daily dose  (mg/kg/day)=exposure factor x RAF x exposure concentration











                                             Children 1 to 6
E = Exposure Factor  (kg/kg/day)=

SI = Soil incidental ingestion rate  (mg/day)
CF = Conversion factor  (kg/mg)
EF = Exposure freguency  (days/year)
ED = Exposure duration  (years)
 RAF = Relative absorption factor  (PCBs 30%, Inorganics 100%, EPA, 1989)
BW = Body, weight  (EPA, 1990)(kg)                                       15
AT = Averaging time, carcinogenic  (days)                           25,550
Exposure Factor (noncarcinogenic)  =                                4.4E-07
Average daily dose  (mg/kg/day)=exposure factor x RAF x exposure concentration
SI x CF x EF x ED
  BW x AT
              200
          l.OE-06
              140
                6
-------
TABLE 15
Noncarcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Drainage Ditch
                                                                                                                                                Page  1
Adults

Chemical
Semivolatile Organic Compounds
Benzo  (a) anthracene
Benzo  (a) pyrene
Benzo  (a) fluoranthene
Benzo  (g,h,i) perylene
Benzo  (k) fluoranthene
Chrysene
Indeno  (1,2,3-c,d)pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-1248
Aroclor-1254
Inorganics
Antimony
Arsenic
Chromium
Manganese
Mercury
Nickel
Vanadium
5.5E-07
5.5E-07

5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
5.5E-07
4.5E-01
2.1E-01
                                                  Average
                                          Average        Reference
                                           Daily             Dose
                                            Dose
                                         mg/kg/day       mg/kg/day
7.4E-08
3.4E-08

1.2E-05
9.7E-06
1.6E-04
1.5E-04
5. 1E-07
4 . 9E-06
ND
ND
4.3E-07
1.2E-07

4.3E-05
2.7E-05
6.4E-04
3.1E-04
1.9E-06
8.9E-06
1.3E-05
ND
ND
                                                                                                                                                                                Estimated hazard index
                                                                                                                                                                               maximum concentration =
-------
TABLE 15
Noncarcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Drainage Ditch

Children Ages 1 to 6

Chemical
Semivolatile Organic Compounds
Benzo  (a) anthracene
Benzo  (a) pyrene
Benzo  (a) fluoranthene
Benzo  (g,h,i)  perylene
Benzo  (k) fluoranthene
Chrysene
Indeno  (1,2,3-c,d)pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-124 8
Aroclor-1254
Inorganics
Antimony
Arsenic
Chromium
Manganese
Mercury
Nickel
Vanadium
4 .5E-01
2. 1E-01
                                                                                                                                        Hazard
                                                                                                                                      Quotients
                                                                       7.9E+01
                                                                       4 .9E + 01
                                                                       1.2E+03
                                                                       5.6E+02
                                                                       3.4E+00
                                                                       1.6E+01
                                                                       2.3E+01
ND
ND
                                                                                                                                                                               Estimated hazard index
                                                                                                                                                                              maximum concentration =
                                                                                                                                                                          Total lifetime hazard index
                                                                                                                                                                              maximum concentration =
-------
TABLE 16
Carcinogenic Risk Characterization
Incidental Ingestion - Current and Future
Surface Soil - Drainage Ditch
                                                                                                                                                                                                                          Page  1
Adults
Semi-Volatile Organic Compounds
Benzo  (a) anthracene
Benzo  (a) pyrene
Benzo  (a) fluoranthene
Benzo  (g,h,i) perylene
Benzo  (k) fluoranthene
Chrysene
Indeno  (1,2,3-c,d)pyrene
Phenanthrene
Pesticides/PCBs
Aroclor-124 8
Aroclor-1254
Inorganics
Antimony
Arsenic
Chromium
Manganese
Mercury
Nickel
Vanadium
1.9E-07
1.9E-07
1.9E-07
1.9E-07
1.9E-07
1.9E-07
1.9E-07
                       4.5E-01
                       2.1E-01
2.5E-08
1.2E-08
                                                                                                                                      Incremental
                                                                                                                                        Cancer
                                                                                                                                    Dose
                                                                                                                     Factor             Risk
                                                                                                                     mg/kg/day  -  1
2.6E+00
7.2E+01

7.9E+01
4 . 9E + 01
1.2E+03
5.6E+02
3.4E+00
1.6E+01
2.3E+01
                                                                                                                  Daily
                                                                       1.5E-05
                                                                       9.3E-06
                                                                       2.2E-04
                                                                       1. 1E-04
                                                                       6.4E-07
                                                                       3.1E-06
                                                                       4.4E-06
                                                                                                                                                   Incremental
                                                                                                                                                    Cancer
-------
TABLE 12
Carcinogenic Risk Characterization
Incidental Ingestion - Future
Surface Soil(1 to 10 feet) - Elm  Street
Adults
Semivolatile Organic Compounds
1,2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-1248
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
                                                                                                              Average
                                                                                                      Average        Cancer
                                                                                                                     Potency
                                                                                                                     Factor
                                                                                                                     mg/kg/day -  1
                1.8E+00
                  ND
                  ND
                  ND
                  ND
                                Incremental
                                 Cancer
                                  Risk
                                  Incremental
                                   Cancer
                                    Risk
Children Ages 1 to 6
Chemical
Semivolatile Organic Compounds
1,2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-1248
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
        Average
Average        Cancer           Incremental
               Potency           Cancer
               Factor             Risk
               mg/kg/day - 1
                1.8E+00
                  ND
                  ND
                  ND
                  ND
        Maximum
Average          Cancer
                 Potency
                 Factor
-------
TABLE 13
NonCarcinogenic Risk Characterization
Dermal Contact - Future
Surface Soil(1 to 10 feet)  - Elm  Street
Adults

Chemical
Semivolatile Organic Compounds
1, 2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-1248
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
Children Ages 1 to 6
Semivolatile Organic Compounds
1,2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-1248
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
                                                                                                               Average
                                                                                                       Dermally        Oral
                                                                                                       Absorbed       Reference
                                                                                                         Dose           Dose
                                                                                                     mg/kg/day       mg/kg/day
NC
             l.OE-02
                                                                            Maximum
                                                                    Dermally          Oral
                                                                    Absorbed         Reference
                                                                      Dose            Dose
                                                                   mg/kg/day        mg/kg/day
                                                                                                            Estimated Hazard index
                                                                                                           average  concentration =
                                                                                                                Total hazard index
                                                                                                           average  concentration =
                                                                        Estimated hazard index
                                                                       maximum concentration =
                                                                            Total hazard index
                                                                       maximum concentration =
-------
TABLE 14
Carcinogenic Risk Characterization
Dermal Contact - Future
Surface Soil(1 to 10 feet)  -  Elm Street
Adults

Chemical
Semivolatile Organic  Compounds
1, 2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-1248
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
1.1E-05
1.1E-05
1.1E-05
1.1E-05
1.1E-05
1.8E+00
  ND
  ND
  ND
  ND
                                                                                                                                           Incremental
                                                                                                                                            Cancer
                                                                                                                                              Risk
                                                                                                                          Maximum
                                                                                                                   Dermally          Cancer
                                                                                                                   Absorbed          Potency
                                                                                                                     Dose            Factory
                                                                                                                  mg/kg/day        mg/kg/day - 1
                                                                                                                       NC
                                                                                                                                       ND
                                                                                       Incremental
                                                                                        Cancer
                                                                                         Risk


















Semivolatile Organic  Compounds
1,2,4-Trichlorobenzene
Pesticides/PCBs
Aroclor-124 8
Inorganics
Arsenic
Chromium
Lead
Manganese
Vanadium
                                         Absorption
                                           Factor
                                                                                                               Average
                                                                                                       Dermally        Cancer
                                                                                      Estimated incremental cancer risk
                                                                                                average concentration =
                                                                                Total  lifetime incremental cancer risk
                                                                                                average concentration =
                                                                                                       Estimated incremental cancer risk
                                                                                                                 maximum concentration =
                                                                                                  Total  lifetime incremental cancer risk
                                                                                                                 maximum concentration =
-------
TABLE 24
Noncarcinogenic Risk Characterization
Ingestion of Drinking Water  -  Ground Water
Future - Adult s
                                         L\kg\day             mg\L
Volatile Organic Compounds                2.IE-02           5.75E-03
1,2-Dichloroethane                        2.7E-02           1.8 IE-01
Ethylbenzene                              2.7E-02           4.10E-01
Toluene                                   2.7E-02           8.47E-01
Trichloroethene                           2.7E-02           2.37E-01
Xylenes  (Total)                           2.7E-02           2.79E+00
Semivolatile Organic Compounds
1,2,4-Trichlorobenzene                    2.7E-02
Naphthalene                               2.7E-02
Pesticides/PCBs
Aroclor-1221                              2.7E-02           6.35E-03           1.7E-04              ND                   NC            1.40E-01            3.8E-03            ND
Aroclor-1242                              2.7E-02           5.93E-03           1.6E-04              ND                   NC            1.30E-01            3.6E-03            ND
Aroclor-1248                              2.7E-02           3.84E-04           1.1E-05              ND                   NC            7.40E-04            2.0E-05            ND
Inorganics
Arsenic                                   2.7E-02
Lead                                      2.7E-02
Manganese                                 2.7E-02
Notes:
Because of the uncertainty  in  inhalation  models  at this time,  EPA Region 1 suggests that this  pathway  be  gualitatively evaluated by assuming that the exposure dose  from inhalation is
egual to that received  from ingesting  2L  of ground water.  Thus,  total risk from groundwater would  be double  that from ingestion.
ND = Toxicity value not available  from EPA.
NC = Not calculated.
E = Exposure Factor  (L/kg/day)  =                                      IR x EF x ED
                                                                         BW x AT

IR = Drinking water ingestion  rate,  adult (L/day)                           2
EF = Exposure freguency  (USEPA, 1991)(days/yr)
ED = Exposure duration  (years)
AT = Averaging time, non-carcinogenic  (30 years  x 365 days/year)
BW = Body weight  (USEPA,1991)(kg)
-------
Hazard Quotients for PCB 1248 and 1254

Table 7       Ingestion of Soil - SS - Mill and Elm St. - Adults
            AVERAGE
Chemical    Add         RfD        HQ

     1248     2.1E-005    2.00E-005       1.05
     1254     1.9E-006    2.00E-005      0.095
                                           1.1 total HI for PCBs
                                           1.1 Total HI  (at bottom of table)
                                                                       Attachment #1
Chemical
 MAXIMUM
 Add
                        RfD
                                   HQ
1248
1254
   2.1E-004
   2.5E-005
                          2.00E-005
                          2.00E-005
10.5
1.25
11.8 total HI for PCBs
11.9 Total HI (at bottom of table)
TABIiE 7   Ingestion of Soil - SS - Mill and Elm St. - Child 1-6
            AVERAGE
Chemical    Add         RfD        HQ
     1248
     1254
Chemical
   2.00E-004
    1.7E-005
 MAXIMUM
 Add
                     2.00E-005
                     2.00E-005
                        RfD
                                   HQ
  10
0.85
10.9 total HI for PCBs
11.3 Total HI (at bottom of table)
     1248      2.0E-003   2.00E-005        100
     1254      2.3E-004   2.00E-005       11.5
                                         111.5 total HI for PCBs
                                         112.5 Total HI  (at bottom of Table)

TABIiE 9 - Dermal Contact - SS - Mill and Elm St.-Adult
            AVERAGE
Chemical    Add         RfD        HQ
     1248
     1254
    2.5E-004
    2.2E-005
                     2.00E-005
                     2.00E-005
 12.5
  1.1
 13.6 total HI for PCBs
 13.6 Total HI (at bottom of table)
            MAXIMUM
Chemical    Add         RfD        HQ
     1248      2.5E-003   2.00E-005
     1254      2.9E-004   2.00E-005
                                 125
                                14.5
                               139.5 total HI for PCBs
                               139.5 Total HI (at bottom of table)
TABIiE 9 Dermal Contact - SS - Mill and Elm St. - child 1-6
          AVERAGE
Chemical  Add          RfD            HQ
     1248
     1254
4-OOE-004
 3.5E-005
          MAXIMUM
Chemical  Add
                   2.00E-005
                   2.00E-005
                       RfD
                                      HQ
   20
 1.75
 21.8 total HI for PCBs
 21.8 Total HI (at bottom of table)
     1248  4.00E-003
     1254   4.6E-004
             2-OOE-005
             2.00E-005
                                       200
                                        23
                                     223.0 total HI for PCBs
                                       223 Total HI (at bottom of table)
-------
TABIiE 11 ingestion - subsurface soil - Elm St - adult
          AVERAGE
Chemical  Add

     1248   1.7E-004
          MAXIMUM
Chemical  Add
RfD

 2-OOE-005
HQ
                                            8.5
                                           21.8 Total HI
                                                          (at bottom of table)
     1248
                       RfD

             .2E-004    2.00E-005
               HQ
                                             41
                                             41 Total HI
TABIiE 11 - ingestion - subsurface soil - Elm St. - child
          AVERAGE
                                                          (at bottom of

                                                          1-6
                                                table)
Chemical  Add

     1248   1.5E-003
          MAXIMUM
Chemical  Add

     1248   7.7E-003
RfD

 2.00E-005



RfD

 2.00E-005
HQ
                                             75
                                           75.4 Total HI
                                                          (at bottom of table)
HQ
                                            385
                                          385.7 Total HI
                                                          (at bottom of table)
TABIiE 13 - dermal - subsurface soil - Elm St - adult
          AVERAGE
Chemical  Add

     1248   1.9E-003
          MAXIMUM
Chemical  Add

     1248   9.5E-003
RfD

 2.00E-005



RfD

 2.00E-005
HQ
                                             95
                                           95.0 Total HI
                                                          (at bottom of table)
HQ
                                            475
                                            475 Total HI
                                                          (at bottom of table)
TABIiE 13 - dermal - subsurface soil - Elm St - child 1-6
          AVERAGE
Chemical  Add

     1248   3.1E-003
          MAXIMUM
Chemical  Add

     1248   1.5E-002
RfD

 2.00E-005



RfD

 2.00E-005
HQ
HQ
                                            155
                                          155.0 Total HI
                                            750
                                            750 Total HI
                                                          (at bottom of table)
                                                          (at bottom of table)
-------
TABIiE 15 - ingestion - drainage ditch - adult
          AVERAGE
Chemical  Add
                       RfD
                                      HQ
     1248   7.4E-008
     1254   3.4E-008
              2.00E-005
              2.00E-005
                 0.0037
                 0.0017
          MAXIMUM
Chemical  Add
                       RfD
                                          0.005 total HI for PCBs
                                            0.1 Total HI  (at bottom of table)
                                      HQ
     1248
     1254
  4.3E-007
  1.2E-007
2.00E-005
2.00E-005
0.0215
 0.006
                                          0.028 total HI for PCBs
                                           0.43 Total HI  (at bottom of table)
TABIiE 15 ingestion - drainage ditch - child 1-6
Chemical
AVERAGE
Add
                       RfD
                                      HQ
     1248
     1254
  6.9E-007
  3.2E-007
2.00E-005
2.00E-005
0.0345
 0.016
                                          0.051 total HI for PCBs
                                            1.0 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add
                       RfD
                                      HQ
     1248
     1254
  4.00E-006
   1.1E-006
2.00E-005
2.00E-005
   0.2
 0.055
                                          0.255 total HI
                                            4.3 Total HI
TABIiE 17 - dermal - drainage ditch - adult
                                               for PCBs
                                                (at bottom of table)
          AVERAGE
Chemical  Add
                       RfD
                                      HQ
     1248
     1254
  8.5E-007
  3.9E-007
2.00E-005
2.00E-005
0.0425
0.0195
                                          0.062 total HI for PCBs
                                           0.06 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add
                       RfD
                                      HQ
     1248  5.00E-006
     1254   1.4E-006
              2.00E-005
              2.00E-005
                   0.25
                   0.07
                                          0.320 total HI for PCBs
                                           0.32 Total HI  (at bottom of table)
-------
TABIiE 17 dermal - drainage ditch - child 1-6
          AVERAGE
Chemical  Add
                       RfD
                                      HQ
     1248
     1254
1.4E-006
6.3E-007
 2.00E-005
 2.00E-005
  0.07
0.0315
                                          0.102 total HI for PCBs
                                           0.10 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add
                       RfD
                                      HQ
     1248  8.00E-006
     1254   2.2E-006
            2.00E-005
            2.00E-005
                     0.4
                    0.11
                                          0.510 total HI for PCBs
                                            0.5 Total HI  (at bottom of table)
TABIiE 19 - ing veg - drainage ditch - adult
          AVERAGE
Chemical  Add
     1248
     1254
4.5E-006
2.1E-006
RfD

 2.00E-005
 2.00E-005
                                      HQ
 0.225
 0.105
                                          0.330 total HI for PCBs
                                           0.40 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add
                       RfD
                                      HQ
     1248
     1254
2.6E-005
7.2E-006
 2.00E-005
 2.00E-005
   1.3
  0.36
                                          1.660 total HI for PCBs
                                            1.7 Total HI  (at bottom of table)
TABIiE 20 - ing - sediment - drainage ditch - adult
          AVERAGE
Chemical  Add
     1248
            1.6E-008
                       RfD

                        2.00E-005
                          HQ
                                         0.0008
                                          0.002 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add
     1248
            4.3E-008
                       RfD

                        2.00E-005
                          HQ
                                        0.00215
                                          0.009 Total HI  (at bottom of table)
-------
TABIiE 20 ing - sediment - drainage ditch - child 1-6

          AVERAGE
Chemical  Add          RfD            HQ

     1248   1.5E-007    2.00E-005        0.0075
                                          0.020 Total HI  (at bottom of table)

          MAXIMUM
Chemical  Add          RfD            HQ

     1248   4.1E-007    2.00E-005        0.0205
                                           0.08 Total HI  (at bottom of table)

TABIiE 22 dermal - sediment - drainage ditch - adult

          AVERAGE
Chemical  Add          RfD            HQ

     1248   6.5E-007    2.00E-005        0.0325
                                          0.030 Total HI  (at bottom of table)

          MAXIMUM
Chemical  Add          RfD            HQ

     1248   1.7E-006    2.00E-005         0.085
                                           0.09 Total HI  (at bottom of table)

TABIiE 22 dermal - sediment - drainage - child 1-6

          AVERAGE
Chemical  Add          RfD            HQ

     1248   3.02E-006   2.00E-005         0.151
                                          0.150 Total HI  (at bottom of table)

          MAXIMUM
Chemical  Add          RfD            HQ

     1248   8.11E-006   2.00E-005        0.4055
                                            0.4 Total HI  (at bottom of table)

Table 6-29 - ingestion - sw - souhegan river - adults - see ERA 7/1/94

          AVERAGE
Chemical  Add          RfD            HQ

     1248   1.6E-008    2.00E-005        0.0008
                                          0.001 Total HI  (at bottom of table)

          MAXIMUM
Chemical  Add          RfD            HQ

     1248   2.9E-008    2.00E-005       0.00145
                                          0.003 Total HI  (at bottom of table)
-------
Table 6-29 - ingestion - sw - souhegan river - child 1-6 - see BRA 7/1/94
          AVERAGE
Chemical  Add
     1248
            7.4E-008
                       RfD

                        2.00E-005
              HQ
                                         0.0037
                                          0.007 Total HI
                                                          (at bottom of table)
          MAXIMUM
Chemical  Add
     1248
            1.3E-007
                       RfD

                        2.00E-005
              HQ
                                         0.0065
                                           0.01 Total HI
                                                          (at bottom of table)
TABIiE 24 Ingestion - GW-Adult - see 7/1/94 BRA
          AVERAGE
Chemical  Add
                       RfD
                                      HQ
1221
1242
1248


1.7E-004
1.6E-004
1.1E-005


2.00E-005
2.00E-005
2.00E-005


8.5
8
0.55
17.1 total HI
18.1 Total HI
                                                         for PCBs
                                                         (at bottom of table)
          MAXIMUM
Chemical  Add
                       RfD
                                      HQ
     1221   3.8E-003
     1242   3.6E-003
     1248  2.00E-005
2.00E-005
2.00E-005
2.00E-005
190
180
  1
          AVERAGE
Chemical  Add
     1248
            1.6E-008
                       RfD

                        2.00E-005
              HQ
                                          371.0 total HI
                                            381 Total HI
                                         0.0008
                                          0.002 Total HI
                                 for PCBs
                                 (at bottom of table)
                                                          (at bottom of table)
          MAXIMUM
Chemical  Add
     1248
                       RfD

            4.3E-008    2.00E-005
              HQ
                                        0.00215
                                          0.009 Total HI
                                                          (at bottom of table)
TABIiE 20 ing - sediment - drainage ditch - child 1-6
          AVERAGE
Chemical  Add
     1248
            1.5E-007
                       RfD

                        2.00E-005
              HQ
                                         0.0075
                                          0.020 Total HI
                                                          (at bottom of table)
          MAXIMUM
Chemical  Add
     1248
            4.1E-007
                       RfD

                        2.00E-005
              HQ
                                         0.0205
                                           0.08 Total HI
                                                          (at bottom of table)
-------
TABIiE 22 dermal - sediment - drainage ditch - adult
          AVERAGE
Chemical  Add          RfD
                                      HQ
     1248   6.5E-007    2.00E-005
                                         0.0325
                                          0.030 Total HI  (at bottom of table)
          MAXIMUM
Chemical  Add          RfD

     1248   1.7E-006    2.00E-005
               HQ
                                          0.085
                                           0.09 Total HI  (at bottom of table)
TABIiE 22 dermal - sediment - drainage ditch - child 1-6
          AVERAGE
Chemical  Add

     1248  3.02E-006
RfD

 2.00E-005
HQ
                                          0.151
                                          0.150 Total HI  (at bottom of table)
          AVERAGE
Chemical  Add
     1248
            i.HE-006
                       RfD

                        2.00E-005
               HQ
                                         0.4055
TABIiE 24 Ingestion - GW-Adult - see 7/1/94 BRA
          AVERAGE
Chemical  Add          RfD            HQ
                                            8.5
                                              8
                                           0.55
1221 1.7E-004
1242 1.6E-004
1248 1.1E-005
MAXIMUM
Chemical Add
1221 3.8E-003
1242 3.6E-003
1248 2.00E-005










2.00E-005
2.00E-005
2.00E-005

RfD
2.00E-005
2.00E-005
2.00E-005










                                      HQ
                                           17.1 total HI for PCBs
                                           18.1 Total HI  (at bottom of table)
                                            190
                                            180
                                              1

                                          371.0 total HI for PCBs
                                            381 Total HI  (at bottom of table)
-------
APPENDIX A



Subject: Declaration of Concurrence

Dear Ms. Meaney:

The New Hampshire Department of Environmental Services (Department) has reviewed and concurs with the
"Record of Decision  (ROD) Summary for the Fletcher Paint Works and Storage Facility Superfund Site OU-1"
dated September 1998. EPA prepared the ROD in accordance with the provisions of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA)  of 1980 as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986. The ROD addresses the remedial actions necessary under
CERCLA, as amended, to manage potential threats to human health and the environment at the Fletcher Paint
Works and Storage Facility Superfund Site (Fletcher Superfund Site.)

Remedy

The Environmental Protection Agency has selected a preferred remedy for operable unit-1  (OU-1)  of the
Fletcher Superfund Site. OU-1 includes the areas identified as the Elm Street Site, the Mill Street Site,
and the drainage ditch/culvert system that flows from the Mill Street Site to the Elm Street Site and
discharges into the Souhegan River. The remedy reguires cleanup of the highest risk, primarily
PCB-contaminated soils at the surface and in the subsurface, and installation of a protective covering of
clean fill. Institutional controls will prevent exposures to soil and groundwater above appropriate risk
levels. Groundwater will be remediated by monitored natural attenuation. A second operable unit will
address river sediments and the Keyes Wellfield contamination.

Remedy Components

The preferred remedy has the following components directed at source control and management of
contaminated groundwater migration. Contaminated soils will be excavated and treated using on-site
thermal desorption. Surface soils will be remediated to PCB levels of 1 mg/kg to a depth of one foot
below the surface at Elm Street and Mill Street.

A utility corridor will be defined at the Elm Street Site where future excavation may expose subsurface
soils. Cleanup levels for PCBs are established within the utility corridor at 25 mg/kg. Any soil outside
the utility corridor will be excavated to a cleanup level of 100 mg/kg PCB the level where PCBs leaching
to the groundwater would not exceed the drinking water MCL of 0.5 ug/L. Institutional controls will
restrict direct exposures to the subsurface. Demolition of Fletcher's Elm Street facility and removal of
underground storage tanks will be reguired.  Also at the Elm Street Site, a polyamide and polyurethane hot
spot will be excavated and treated separately.

Different soil cleanup levels were developed at Mill Street because PCBs are present in groundwater at
high concentrations attributed to their increased solubility when mixed with other contaminants that are
present. Modeling resulted in a cleanup level of 1 mg/kg PCBs that could be left in soils without
leaching to the groundwater that would exceed the MCL of 0.5 ug/L.

Both soil cleanup levels may be modified by further analysis with leaching models and/or column testing.
Treated soils will be returned to the sites and covered with a soil/sand mix. Long term monitoring of
groundwater will be implemented under a Groundwater Management Zone with institutional controls to
restrict use.

Significant Changes to the Proposed Plan

EPA issued the preferred alternative of the Proposed Plan in December and presented it to the public
January 14, 1997. Changes to the scope of the remedy were made as a result of public comment that include
changing the future use assumptions for the Elm Street property and defining a utility corridor where
excavation would be allowed with limited restrictions. Soil cleanup levels were then revised to be
consistent with risk under the new anticipated uses and activities.
http://www.state.nh.us                                     TDD Access: Relay NH  1-800-735-2964
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Letter to Ms. Patricia Meaney
Re: Fletcher Superfund Site ROD - Declaration of Concurrence
September 28, 1998
Page 2

The Proposed Plan's Consistency with State's Remediation Requirements and Policies

The Department has been actively involved in the development and review of the Fletcher Superfund Site
OU-1 proposed remedy. The following discussion describes in detail the consistency of the proposed remedy
with state policies and requirements.

The proposed remedy is consistent with the Department's "Draft Guidelines for Selection of Natural
Attenuation for Groundwater Restoration under Env-Ws 410" in that it meets the guidance for use of
natural attenuation at contaminated sites and for monitoring of the natural attenuation process. Long
term monitoring and five year reviews in the ROD, which determine the remedy's protectiveness of public
health and the environment over time,  are consistent with the guidance.

The Department has reviewed the proposed remedy consistent with its Risk Characterization and Management
Policy (RCMP.) Under this policy, remedies that do not meet first tier values (S-l) in the RCMP require a
health risk assessment. The State's Bureau of Health Risk Assessment has completed this review and
concluded that the soil cleanup levels in the proposed plan appear to be protective of human health with
appropriate institutional controls. The State stresses that in order for this assessment to be valid,
institutional controls must be developed that meet the risk assumptions and they must be strictly
maintained.

Env-Ws 410

Env-Ws 410, the Department's Groundwater Protection Rules, establishes statewide groundwater quality
standards and the protocols to be used when investigating and remediating contaminated sites. It also
allows the scope and aggressiveness of remedial actions necessary to achieve these standards to be
selected based on the resource use and value of the groundwater. EPA has designated specific sections of
Env-Ws 410 as ARARs.  The ROD applies the requirements of Env-Ws 410 as follows:

       •       GMZ Establishment:  Env-Ws 410.26 requires the establishment and containment of contaminated
              groundwater within a Groundwater Management Zone (GMZ),  when violations  of Groundwater
              Quality Standards are present.  The ROD includes Env-Ws  410.26 as an ARAR and provides for
              the establishment of a GMZ with attenuation of groundwater contamination;

       •       Source  Area Treatment,  Removal  or Containment:  Env-Ws 410 requires that  sources of
              continuing groundwater contamination must be either treated or removed and,  if treatment or
              removal are not feasible,  the source must be contained.  Source areas at  both the Elm Street
              and Mill Street Sites will be excavated to remove contaminants to  levels below concern for
              leaching into groundwater such  that they will no longer be contaminant sources. The selected
              remedy  will treat the excavated soil;

       •       Groundwater Restoration:  The remedial action must restore groundwater quality to meet the
              groundwater quality criteria contained in Env-Ws 410.03.  The Fletcher Superfund Site
              Groundwater Use & Value  Determination developed under EPA Guidance and with consultation
              from the town defined this aquifer as of medium use and value.  This EPA Guidance is designed
              to assist in determining remedial objectives.  For a medium use and value designation,  the
              groundwater Remedial Action objectives generally will include the  restoration of
              contaminated groundwater to drinking water standards,  within a time frame that is reasonable
              given the particular circumstances of the site.  The source removal action and the monitored
              natural attenuation provisions  in the ROD are functionally equivalent to Env-WS 410's
              requirement for development and implementation of a remedy that will restore groundwater
              quality to statewide standards;

       •       Establishment of Performance Standards:  Final and interim objectives and criteria,
              including specific performance  standards are established for the remedial actions.  If
              the remedial actions do  not meet the performance standards,  additional action may be
              required.  The ROD defines performance standards for surface and subsurface soil zones as
              part of the remedial action.  The ROD includes Env-Ws 410's numerical groundwater quality
              standards as an ARAR and the NCP requires that these standards be  met in a reasonable
              timeframe (March 8,  1990 Federal Register,  p.  8732);
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Letter to Ms. Patricia Meaney
Re: Fletcher Superfund Site ROD - Declaration of Concurrence
September 28, 1998
Page 3

       •       Long Term Monitoring of the GMZ and Remedy Performance:  Env-Ws 410 reguires monitoring of
              the performance of remedial systems and GMZ boundary compliance.  The ROD provides for
              monitoring of the performance and effectiveness of the remedial actions as well as the
              groundwater guality at the GMZ boundary.  A comprehensive detailed review of all
              environmental monitoring data will be conducted periodically to ensure that the remedial
              action provides adeguate protection of human health and the environment and complies with
              applicable regulations.

       •       Institutional Controls; Env-Ws 410.26(e)  reguires control of the use of groundwater for
              drinking water within the GMZ either ownership of the overlying land or easement, unless an
              alternate water supply is available.  The remedy includes implementation of controls to
              restrict groundwater use while contaminant concentrations are in excess of drinking water
              standards;

Based on the partial use of the Env-Ws 410 as ARARs, the OU-1 ROD is consistent with the approach that
would be reguired to meet our groundwater remediation approach at similar sites within the State.

State Concurrence

The Department,  acting on behalf of the State of New Hampshire, concurs that the selected remedy,
described in the ROD, satisfies the reguirements of CERCLA.

In striving to maximize the effectiveness of limited public and private resources, the Department
continues to seek reasonable and practical solutions to the complex challenges associated with
contaminated site cleanups. The partnership and dedication of EPA and the Department will speed up the
achievement of our mutual environmental goals at this site. As always, the Department stands ready to
provide the guidance and assistance that EPA may reguire to take the actions necessary to protect human
health and the environment completely and cost-effectively.




cc:    Dana Bisbee,  Esg., Assistant Commissioner, NHDES
       Carl W. Baxter, P.E., NHDES HWRB
       Richard Pease, P.E., NHDES HWRB
       John Regan, NHDES GPB
       C.  Wayne  Ives, NHDES HWRB
       Michael Walls, Esg., NH AGO
       Cheryl Sprague, USEPA
       Richard Boynton, USEPA
       Lee Mayhew, Town of Milford
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                                      APPENDIX B

                                Fletcher's Paint Site
                               Responsiveness Summary

TOWN OF MILFORD, CITIZENS, AND INTERESTED PARTY COMMENTS

1.  The Town of Milford requested that the Environmental Protection Agency  (EPA) revise the Baseline
Human Health Risk Assessment  (BHHRA) to reflect the town's intention to use Elm Street as a parking lot
and to adopt institutional controls to limit the use of the property in perpetuity.

EPA Response: The EPA reviewed the Town's request to change the expected future subsurface use at the Elm
Street Site. In the selected remedy, EPA incorporates the Towns comment by limiting future utility
maintenance to within designated utility corridors at the Elm Street Site.

The risks presented in the FS and in the Proposed Plan reflect the assumption that in the future, adult
and children could be exposed to subsurface soils which were re-deposited on the surface as a result of
future excavation or maintenance work. The cleanup levels presented in the Proposed Plan reflected this
assumption. Limiting the future excavation potential to within the confines of a utility corridor(s),
along, with restrictions placed on unauthorized access into the subsurface at the Elm Street Site as well
as surface restrictions on the future use of the Site, eliminate the exposure pathways of dermal contact
and ingestion.

EPA considered the TSCA Spill Policy in setting a cleanup level within the utility corridor to 25 mg/kg
PCB for the protection of a utility worker who may infrequently access the corridor to perform
maintenance and repair.

The surface exposures would remain the same, adult and child exposure through dermal contact and
incidental ingestion, since the future use assumption that the Site would become an extension to the
Keyes Field recreation area, primarily for the purposes of additional parking would not change.

The remainder of the soils in the subsurface at the Elm Street Site would require long-term management
controls and institutional controls for the protection of the groundwater. This is also consistent with
the Town's desire, set forth in a letter to the EPA dated March 13, 1998. The selected remedy requires
that the subsurface soils, with the exception of the utility corridor, be excavated and treated by
thermal desorption wherever concentrations exceed 100 mg/kg PCB, or which through modeling and/or soil
column testing show that the PCB MCL of 0.5 ug/1 in groundwater will not be exceeded in the future. The
determination to alter the cleanup level to any concentration other than the 100 mg/kg PCB will be to the
sole discretion of the EPA.

The 100 mg/kg PCB soil cleanup level is based on a leaching analysis of the soils where only a soil cover
is needed to protect the groundwater from future leaching of the PCBs into the groundwater above drinking
water standards. Erosion and drainage controls will be mostly provided through placement of asphalt over
a large portion of the property, consistent with the parking consistent with the future anticipated
parking use for the Elm Street Site. Because the soil concentrations remaining in the subsurface are not
protective for adult and children users of the Site, minimum 10-inch soil cover as well as 6 inches of
asphalt, consistent with TSCA where PCBs will remain in the surface with PCB concentrations of greater
than 25 to less than or equal to 100 mg/kg PCBs will be required. Institutional controls in the form of
deed restrictions will also be required to prevent unauthorized access to the contaminated subsurface
soils in the future, and to protect the integrity of the cover materials.

2.  The Town of Milford expressed concern about the potential for Dense Non-Aqueous Phase Liquid (DNAPL)
and requested additional studies be conducted.

EPA Response: In undertaking the RI studies at the Site, EPA has always been concerned about the possible
presence of dense non-aqueous phase liquids ("DNAPL"). PCBs are characterized a highly viscous DNAPL,
when compared to other more familiar chlorinated solvent DNAPLs such as TCE and PCE. EPA has also been
concerned with the potential presence of organic contaminants (other than PCBs) that might have enhanced
the mobility or solubility of the PCBs in the past, and which may still be enhancing their movement
through the soils at the Site. The presence of DNAPLs at the Site, whether free-phase or residual,  could
cause long-term contamination of the ground water. EPA believes that the selected remedy takes into
consideration the potential for DNAPL at the Site.

At the Elm Street Site, there was no evidence that there is currently, or had been in the past, any
organic compounds that may have increased the mobility of the PCB contamination. At the Mill Street Site,
however, there is significant evidence that there has been enhanced PCB transport. It is unclear however,
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if the factors that increased the solubility and mobility of the PCB through the subsurface in the past,
continues today. The high PCB concentrations in the groundwater at the Mill Street Site could either be
as a result of PCB, DNAPL, or the result of other paint related compounds found in the subsurface that
have the potential to enhance the transport of the PCBs through the subsurface and/or increase the
solubility of the PCBs in the groundwater.

DNAPL sites also are often characterized by having contaminant concentrations that do not generally
decrease with depth at the site, but are rather sporadic or increasing concentration with depth, with the
majority of the contamination usually lying below the water table. This is because of the dense, less
viscous nature of most DNAPLs and the higher capacity to retain contamination within the soil pore areas
in the saturated zone. EPA observed during the RI that PCB contamination decreases with depth at the Mill
Street Site with approximately 94% of the mass of PCBs at the Site residing in the top 4 feet. This
information, combined with the percent level contamination levels found within the surface soils as a
result of liquid PCBs being released to the surface, yet the lack of any visual DNAPL on the soils,
indicates that there is residual PCB DNAPL in the surface soils at the Site. Residual DNAPL is

While that data is unclear whether or not any of the PCB DNAPL has entered into the bedrock,
approximately 20 feet below( data from the RI indicate PCBs contamination within 5 feet of the bedrock
surface), calculations show that less than 1% of the PCB mass at the Mill Street Site currently lies
below the water table.

The extent of the contamination within the bedrock is uncertain given the limited available bedrock data
and the nature of contaminant movement within shallow fractured bedrock systems. While specific PCB
congeners have the ability to travel greater distances form the source area, in general, most PCB sites
are not characterized by large plumes of PCB contamination. The data is unclear as to whether or not PCBs
have migrated away from the source area at the Mill Street Site.

A chlorinated DNAPL plume typically reflects a concentration in the groundwater of between 1 and 10% of
the effective solubility of the compound found in the original DNAPL. PCBs are hydrophobic compounds and
therefore the PCBs are less likely to move into the groundwater from the soils. At the Mill street Site,
the PCB concentrations found in the overburden at MW-07 were 10 and 12 ug/1 and up to 270 ug/1 in MW-21C,
a bedrock well on the Site. These numbers exceed the 1-10% general rule of thumb since the PCB solubility
for Arochlor 1242  (the prevalent groundwater PCB contaminant) is approximately 100 ug/1. The actual
effective solubility of the PCBs in the groundwater could be even less than the 100ug/l since information
obtained from past Fletcher employees revealed that the PCBs released onto the Site were often mixtures
of PCBs with other solvents.  The effective solubility would take into account the mole fraction of the
PCBs in the original mixture.

EPA believes that the high PCB concentrations found in the groundwater at the Mill Street Site reflect an
enhanced solubility of the PCBs as a result of interactions with other paint related compounds also
likely released as liquids to the surface at the Mill Street Site. This is not to say that DNAPL could
not also be affecting the groundwater quality at the Site to some degree. However, a sample of the
flocculent material taken from MW-07 A reported to have 1,780 ug/1 PCB (Arochlor 1242)  without any visual
observation of DNAPL. This appears to reflect an extremely high affinity of the PCBs to this material.
EPA believes that the majority of the compounds that comprise the floe will be removed during the
excavation of the soils and the dewatering action needed to excavate the soils below the water.

The selected remedy sets surface and subsurface soil cleanup levels for the protection of human health
through dermal contact, incidental ingestion and ingestion of contaminated groundwater. The selected
remedy also requires the establishment of a Groundwater Management Zone  (GMZ) consistent with NH's
Comprehensive Groundwater Management Policy which requires that the groundwater be monitored to ensure
that the contaminant concentrations are decreasing, are not moving beyond the boundaries established by
the GMZ,  and are not impacting the Souhegan River. Long-term monitoring of the contaminated groundwater,
including monitoring of the groundwater within the bedrock, will be conducted until the Interim cleanup
levels are met in the future for a period of three consecutive years. Future actions may be necessary,
consistent with the NH Comprehensive Groundwater Policy.

An additional comment was made by one of General Electric's  (GE's) consultants that the observed enhanced
vertical PCB migration may have been caused by the drilling process. However, this concern is
unsubstantiated. Continuous soil samples were collected in each of the borings at Mill Street Site. Each
of the soil samples was collected using a split-spoon sampler in advance of the drill bit. In other
words, elevated PCB concentrations were determined to be present in the subsurface in advance of the
drill bit. Therefore all detected soil contamination was present throughout the soil column prior to
drilling. Further, monitoring well, MW-07, was only drilled to 12.5 feet with hollow stem augers (a
relatively destructive technique). At 12.5 feet, a boulder was encountered and a 4-inch diameter steel
casing was set. The remainder of the hole was drilled through a 3-inch casing using drive and wash
techniques. Therefore, the more contaminated upper portion of the hole was cased-off from the lower
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portion of the hole during drilling and well installation activities. In addition, a steel casing at
monitoring well, MW-21C, was set down to bedrock, before drilling through the grout into bedrock for
installation of the bedrock well. As such, the bedrock was isolated from potential overburden
contamination by way of the steel casing.

3.  The Town of Milford reguested that the differences between clean up standards for Norwood PCB
Superfund Site, and Fletcher Paints be evaluated to understand the discrepancy. The stricter standard for
Fletcher results in a more expensive and extensive cleanup than that proposed for Norwood, but there is
no compelling public health or environmental risk warranting the need

EPA Response: Cleanup levels for each Superfund site are based on the anticipated future uses for the
site. Exposure pathways and receptors also vary at each site. It is the evaluation of these factors that
determine how the cleanup levels are set for each site.

In determining the exposure receptors and pathways at each site, the risk assessment must address the
site specific current and future uses and exposures on the site. For example, the exposure pathway on the
main portion of the Norwood Site was anticipated to be used for commercial future uses. At the Fletcher's
Paint Site, however, the future use anticipated is that the surface of the Site would be considered
recreational. The Fletcher's Paint Site is abutted by residential homes and in close proximity to schools
and the Keyes Field. The risk assessment reflects potential exposure scenarios for adult and child
trespassers freguenting the Site for recreational purposes. Because the Site abuts residential
properties the exposure parameters used to calculate the risks assumed that the adult and child
trespassers would freguent the Site 140 days per year.

Two final notes of difference at the two Sites: 1) is that the Norwood Site has been, and is currently
operating a multi-million dollar groundwater extraction and treatment system at the site and 2)  the
Norwood remedy calls for containment of the contaminated soils on the commercial property and cleanup of
the remaining soils, consistent with the exposure pathways present for that site. The pump and treat
operations were considered in the determination of the Norwood soil remedy. The largest portion of the
Fletcher's Paint site (23,600 out of 28,900 yd3) is being cleaned up to standards that are protective of
human health through ingestion of contaminated groundwater. Because the source control action addressed
all contaminated soil which could impact the groundwater in the future, monitored natural attenuation was
selected as the most cost effective management of migration action for the groundwater. Stringent capping
reguirements as well as additional pump and treat operations would have had to be implemented if soils
were left in the subsurface at the Fletcher Site that were not protective of the groundwater in the
future.

4.  The Town of Milford reguested that the EPA increase the subsurface clean up standard for Mill Street
from 1 ppm to 500 ppm. They believe the lower standard is not necessary and may result in cleanup that
could mobilize PCBs in the ground water zone. PCB cleanup levels consistent with land use would speed up
the site remedial action and eliminate potential problems such as space limitations to installing thermal
desorption eguipment, or the In-Situ Thermal Desorption - Thermal Well ("ISTD- thermal Wells) technology.
The town is particularly concerned with the impact on the Keyes Field area, a public park. At Norwood,
additional room was reguired to operate a treatment system; and the Town is concerned that this could
also occur at Fletcher and cause an unacceptable encroachment on the nearby Keyes Field and other site
areas.

EPA Response: In response to the comment concerning increasing the subsurface cleanup level at Mill
Street from 1 to 500 mg/kg, please see the EPA's response to Comment 1, since the Town now supports a 100
mg/kg PCB cleanup level for the subsurface, consistent with the selected remedy.

EPA agrees with the Town that any remedial action will be staged with the primary goal of minimizing the
use of Keyes Field, and minimizing inconvenience to the public. In addition, if Keyes Field is used for
storage, only clean soils, construction eguipment, and supplies will be stored there, with prior
agreement from the Town. The phasing approach was incorporated into the selected remedy will allow
maximum use of the Site property itself for cleanup activities. By phasing the cleanup, the Elm Street
Site can be used to stage the eguipment and staging of soils needed for the Mill Street operation. Once
the Fletcher's Paint building has been removed, the Elm Street Site should be sufficiently large enough
to house a small mobile thermal desorption unit, even if that unit needs to be moved once or even twice
during the operation to maximize the use of the site, without going "off-site" onto other properties.

While the Town proposed comment that the subsurface cleanup level should be elevated from 1 to 500 mg/kg
PCB, the EPA received comment from the Town on March 13, 1998, stating that the Town, in consideration of
information received from the EPA, now recommended a 100 mg/kg PCB cleanup standards for the subsurface
soils, outside of the utility corridors at the Elm Street site. The cleanup level for these soils cannot
be compared to any levels set at the Norwood Superfund site, since the level represents a concentration
protective of the groundwater and not human health, as were the basis for all of the Norwood soil cleanup
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levels not included under the containment area. NHDES determined that the ground waters beneath the
Fletcher's Paint Site were of value to the Town and the State as a potential drinking water supply and
therefore drinking water standards are reguired to be met in the future in the groundwater at the Site.
Soil standards at the Elm and Mill Street Sites reflect concentrations that can remain in the subsurface
soils, with only a soil cover, and not impact the groundwater in the future in excess of the PCB MCL of
0.5 ug/1

5.  The Town of Milford, State Representative Durnham, and various residents believe that it is essential
to consider ISTD-Thermal Well data. They believe that the additional time to assess innovative
technologies such as the ISTD -Thermal Wells is okay because there is no immediate risk to public health
or the environment posed by current site conditions. Some residents are concerned about the schoolyard
adjacent to the site and the transport of soils in its vicinity and potential spreading of the soil, as
well as the resulting disruption. They believe on this basis that ISTD-Thermal Wells should be considered
Another resident believes, the EPA should oversee the ISTD-Thermal Wells process and implement a vigorous
testing program, but that it is important that the contamination be removed Oil the other hand, one
resident believes the lack of data regarding the ISTD-Thermal Well process will only delay implementation
of the remedial activities.

EPA Response: EPA granted extensions to the Remedy decision process to review data from Terratherm's
ISTD-Thermal Well technology. Specifically, EPA extended the public comment time period on the Proposed
Plan for a total of 3 months and granted an additional 3 month delay in making a remedy decision
specifically to review submittal of data on the ISTD Thermal Well technology. This data was actually not
submitted to the EPA till 3 months after the end of the original 6 month delay in the schedule.
Regardless, EPA did not move forward with the selected remedy till after completing our review of the
data available to date on the technology.

One of EPA's national experts on thermal remediation has reviewed the data on the technology and visited
one of the demonstration sites (Missouri electric Works),  where the ISDT-Thermal Wells were being tested
for the cleanup of PCBs. EPA's expert reviewed the thermal blanket test version of the ISTD technology as
well as the Cape Girardeau, Missouri Electric Works and Mayer Island Thermal Well demonstration reports.
These two demonstrations are the only PCB related demonstrations of the ISTD -Thermal Well technology to
date whose data was made available to the EPA for review.

EPA's complete review of the ISTD -Thermal Well technology for the Site is available in the
Administrative Record for the Site. This Administrative Record is available at the Wadleigh Memorial
library and at EPA's record Center in Boston, Massachusetts. The conclusions from EPA's thermal expert,
after review of the ISTD - Thermal Well data for a total of over two years (since the concept of the
technology was first brought to EPA's attention) concluded that while some improvements have been made to
the ISTD-Thermal Well technology with each demonstration,  there remains guestions as to the
protectiveness and effectiveness of the technology. Specifically EPA remains concerned about the release
of contaminants during the operation of the technology into the ambient air.  Data from the demonstrations
show that the ambient air concentrations were elevated during the operation of the technology. While
these ambient air concentrations may have been protective of workers on the site, based on OSHA
standards, the concentrations would have exceeded the NH Ambient Air Level for PCBs, and therefore would
not be protective of human health at the Fletcher's Paint Site, in a similar situation. EPA is extremely
concerned about the ambient air results since both the Elm And Mill Street Sites are small in size and
residences, schools and Route 101A are in close proximity. Any operation at the Site would have to meet
the NH's ambient air standards for the protection of the general public.

Another concern relates to the lack of data from the previous demonstrations that can compare with the
conditions at the Fletcher's Paint Site. EPA is concerned about the nature of the fill materials at the
Elm Street Site, where the majority of the site is not soil, but fill material comprising of ash, tree
stumps, ceramics, glass and tires. In addition a large deposit of resin-like material was also found on
the Elm Street Site. The Mill Street Site presents an additional problem as some of the soils reguiring
remediation are located below the water table. No data submitted on the ISTD- thermal Well technology
indicated the ability of the technology to successfully remediate these materials or operate successfully
in these types of situations.

While EPA agrees that the ISTD-Thermal Well technology would be less invasive in that large volumes of
soil would not have to be excavated to conduct the remediation, there are facets on the implementation of
the technology that EPA does not believe were revealed to the public at the informational public meetings
held by GE and Terratherm. Specifically, it appeared to the EPA that the public  believed that this
technology would "not be seen or heard", when compared to the ex-situ thermal desorption technology
selected by the EPA. The ISTD-thermal Well technology reguires that a well be driven into the subsurface
to complete the necessary cleanup. These wells would be located every 5 to 10 feet apart and operate at
extremely high temperatures to accommodate heat losses and yield temperatures high enough to result in
the desorption of the contaminants at the points between the wells. While this would be done in 3 stages
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according to Terratherm, this represents a potential for hundred of wells placed on the Elm Street Site
alone. The operation of the treatment system would be for 24 hour days for approximately 40- 60 days for
each cycle. The noise from this operation is very similar to the ex-situ thermal desorption units,
however the ex-situ units can be "shut down" if desired after 8,10, 12 or 16 hours of operation, thereby
reducing or eliminating noise inconvenience during the night. GE also reported in their December 1997
Focused Feasibility Report that the operation of the Thermal Wells would include excavation of all soils
around the entire perimeter of the Elm Street site, a distance of 8 feet from the boundary of the Site.
These soils would be then treated on-site, away from the perimeter.

The costs for the ISTD-Thermal Well technology compare well with the selected remedy, when the same
cleanup levels are used to compare the use of the technology in a complete remedial alterative. The
estimated time to complete the remedial action also compared well to the selected remedy when again, the
same cleanup standards are applied.

EPA will consider new data on the ISTD Thermal Well Technology as it becomes available. EPA does not
believe further delay is warranted to wait for additional data on the ISTD-Thermal Wells, since other
viable, cost-effective innovative technologies, such as the ex-situ thermal desorption technology, are
currently available to safely meet the cleanup criteria at the Site.

6.  The Town of Milford and a resident reguested that EPA consider an asphalt multi-layer cap in the Elm
Street parking area and the Mill Street right-of-way to address PCB, PAH, VOC and metals contamination.
At Norwood the remedial conclusions were that cover soil and an asphalt multi-layer cap are suitable
containment options to protect the public health and environment from PCB exposure.

EPA Response: The selected remedy reguires the excavation and treatment of the surface soils to a depth
of 1 foot wherever soil cleanup levels are exceeded; the excavation and treatment of soils within
designated utility corridor(s) on the Elm Street Site wherever PCB concentrations exceed 25 mg/kg PCB,
and the excavation and treatment of all the remaining soils at the Elm Street site wherever
concentrations exceed 100 mg/kg PCB. As stated previously, the Town in a letter dated march 13, 1998 now
supports the 100 mg/kg cleanup level for the subsurface.

Placement of an asphalt multi -layer cover  (EPA assumes the comment refers to a RCRA Subtitle C or
Subtitle D cap) would be protective of human health and the environment if in conjunction with a
long-term hydraulic containment system for Mill Street Site. Hydraulic containment would be reguired
because contaminated soils would be allowed to remain in place at concentrations that would impact the
groundwater over time. The cap would only prevent the leaching of the contaminants from the unsaturated
soils. This alternative is feasible and was presented by EPA in the FS as Source Control 3 - Containment.

Asphalt alone will not prevent the infiltration of precipitation through the remaining contaminated
soils, Asphalt cracks over time, and is susceptible to chemical degradation, frost heaves and other
environmental and maintenance related factors that would allow over time, even with the best maintenance,
the infiltration of precipitation. At 500 mg/kg PCB, any infiltration through the subsurface would be
expected to result in a groundwater concentration exceeding the MCL of 0.5 ug/1 PCB- Therefore asphalt
alone at these concentrations is not protective to the environment.

Containment measures will be reguired at the Site as part of the selected remedy to promote drainage off
of the Site, reduce leachate generation by minimizing the infiltration of precipitation and control
erosion of the cover materials.

While containment is less expensive than the selected remedy, EPA considered the selected remedy to offer
a greater overall protectiveness, as well as a higher level of long term permanence and protectiveness
when compared to the containment alternative. The selected remedy also meets the criteria of reduction
in mobility, toxicity and volume through treatment. EPA believes that the selected remedy is cost
effective when compared to the containment alternative because high levels of hazardous substances will
not be left on the Site at the completion of the selected remedy and groundwater will be managed through
a Groundwater Management Zone as part of NH's Comprehensive Groundwater Management Policy.

7.  Representative Durnham is concerned about stockpiling contaminated soil in Keyes Park.

EPA Response EPA agrees that stockpiling contaminated soils on the Keyes Field would be a concern. EPA
phased the cleanup approach in both the Proposed Plan and the selected remedy to maximize the use of the
site itself for remedial activities and minimize any use of the Keyes Field. All remedial action
conducted at the Fletcher's Paint site will be staged with the primary goal of minimizing the use of
Keyes Field, and should additional space be reguired for storage, only clean soils, construction
eguipment, and supplies would be temporarily stored, with permission of the Town. It is not anticipated
that the Keyes Field would be heavily impacted during the cleanup action, outside of the need to close a
portion of the Keyes Drive during cleanup of the contaminated soils that physically surround the upper
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portion of the Keyes Drive. Certain remedial actions may also be able to be undertaken during times when
the Keyes Field is used the least, to minimize any impact.

The use of Keyes Drive as an access to the Keyes Field during the operation of the Elm Street cleanup
will be dependent on the size and layout of the treatment unit and excavation reguired, as well as the
need to consider the safety of both the workers and the users of the Keyes Field. Of most concern is the
residents walking or riding bicycles in close proximity to the operating vehicles at the site All actions
will be thoroughly reviewed during design to minimize any impacts to the users of the Keyes Field.

8.  Milford Power Eguipment is concerned that the disruption resulting from the cleanup will impact
business, and yet they will receive no compensation.

EPA Response: EPA is also concerned about community disruption during the remedial action, and the
changes made to the Proposed Plan and incorporated into the selected remedy should reduce, minimize or
eliminate many of the disruptions. But with all remedial actions, there is bound to be some disruption,
particularly to those closest to the operations. EPA, as well as General Electric have shown at this site
that action can be accomplished with minimal disruption. Five cleanup actions have taken place so far at
the site, all undertaken successfully. The "white suits" mentioned in this commentary, as well as other
protective measures such as personal breathing apparatus, are reguired by the site workers to keep their
clothing free from contaminated soil and are not meant to scare away potential business for the abutters.
EPA will be happy to work with this company, and any other company, during the cleanup action, as was
done during the previous cleanup actions at the Mill Street site, by keeping the business and the
community at large appraised of upcoming and completed work and any anticipated inconveniences in the
community.

9.  A resident expressed concern about the culvert and reguested that the culvert be upgraded.

EPA Response: The selected remedy includes upgrading the culvert and the drainage ditch such that the
long-term drainage from the Mill Street site is away from the site and the adjacent residential homes.
While remedial action is not warranted for the protection of human health in the drainage ditch that runs
from the Mill Street Pond to the enclosed system under the Elm Street site, improvements on the flow in
the drainage system are reguired to ensure proper drainage away from the Mill Street Site, and to ensure
that the system has the capacity to handle the flow at peak times.

The portion of the culvert that transverses Elm Street site will be removed (filled) and replaced, giving
the Town access to the culvert for future maintenance. The proposed path of the new culvert is to run
along Elm Street to and down Keyes Drive and then to the Souhegan River.

10. Donahoe Lumberyard (abutter to site) expressed concern that the Proposed Remedial Action Plan does
not address contamination beneath his property, (ground water issue)

EPA Response: The selected remedy does include the reguirement that the Interim Cleanup Levels set for
the groundwater be met throughout the entire plume of contamination which spreads from the Mill Street
site to the Souhegan River, including the groundwater beneath the above mentioned property. EPA has
selected a limited action remedy for the management of this groundwater contamination whereby natural
processes are allowed over time to degrade, absorb, and disperse the contamination until the cleanup
levels are reached. It is estimated that it will take approximately 20 to 25 years for the VOC
contaminant levels in the overburden to reach the cleanup levels, and over 100 years for the PCB
contamination to reach its cleanup level. While the full extent of the contamination is not yet known,
and more information will be gathered during design, it is anticipated that it will take longer for the
bedrock contamination to reach cleanup levels due to the intricate nature of the flow through the
bedrock. To date, no DNAPL has been confirmed within either the overburden or bedrock systems, though it
is assumed that residual DNAPL, which is currently trapped and no longer mobile, is present in the top
several feet of the soils due to the presence of percent level contamination.  These soils will be
addressed through excavation and treatment, thereby eliminating this source of continuing groundwater
contamination.

The ground water contamination at the Fletcher's Paint site does not currently pose a risk to human
health because the aguifer that is contaminated is not being used by the town as a drinking water supply
and the depth of the aguifer makes exposure unlikely. In discussions with the State and the Milford town
officials, there was agreement that the ground water beneath the Fletcher's Paint site is a potential
drinking water supply but that it would not be immediately needed; therefore,  institutional controls
would be placed on the contaminated ground water to restrict its future use, until the cleanup levels
were met in the future.

11. One citizen is concerned about the potential reduction in income occurring from the visual detraction
of his property as a result of the treatment facility, construction eguipment, and piled soils that would
-------
be present during remediation.

EPA Response: EPA phased the implementation of the cleanup action to maximize the use of the Site and
minimize and use or disturbance to surrounding properties. Any excavation will be staged with the primary
goal of minimizing the use of Keyes Field. If Keyes Field is reguired to be used, with the Towns
permission, an attempt will be made to store only clean soils, construction eguipment, and supplies in
areas that will minimize their visibility. It is anticipated that these storage areas would be located as
far from residences as possible. In addition, engineering controls will be in place during all remedial
activities to minimize air emissions, and the EPA would reguire the remedial actions to be monitored for
PCBs, dust, and noise at the fence line (i.e. property boundaries).  The EPA is confident that the
remedial actions can be implemented without greatly impacting the surrounding community.

Any remedy selected that involves active remediation will likely result in some temporary disruption of
the current site appearance. The selected remedy is expected to take just over 2 years to implement.
However, over the long term these measures are necessary to protect human health and the environment and
will ultimately result in the site having a better appearance than it has currently. The only
alternatives to active remediation is either No Action or Monitoring and Institutional Controls. Neither
of these alternatives complies with the National Contingency Plan (NCP) evaluation criteria. These two
alternatives fail to achieve protectiveness over the period of time that contamination would remain
present at the site, fail to comply with applicable or relevant and appropriate reguirements, fail to
provide a permanent remedy, fail to be effective over the short and long term, and they do not reduce the
toxicity, mobility, or volume of contamination. The NCP also indicates that reliance on institutional
controls is the least desirable option to provide protection of public health, since such controls can be
changed or ignored over time.

12. A former citizen and police officer commented that he had observed discharges to the Souhegan River
as a result of Fletcher's Paint activities as early as 1966. In addition, he also observed drum
disposal/burial in the parking lot and area that was later built on and he is concerned that it took as
long as it did for the site to be closed.

EPA Response: The Fletcher's Paint Site has been investigated by the EPA since 1984, as a result of the
closure of the Keyes Municipal Well. The site was officially listed on the National Priorities List in
1989. Testing performed on the subsurface during the RI indicated the presence of 5 underground storage
tanks, but no buried drums were observed at the Site. Future cleanup actions will take this observation
into consideration when conducting explorations into the subsurface.

Many cleanup actions have already occurred at the Site, thus removing the most immediate threats to human
health posed by the Site. These actions included:

       •      Removal of 863 drums of hazardous substances in 1988 and the placement of a geotextile
              fabric over the parking areas of the Elm Street and Mill Street sites to mitigate the
              potential environmental and  health threats,  and to prevent off-site migration of PCBs;

       •      Placement of fence at the perimeter of the Elm Street  site in 1991 to prevent unauthorized
              access onto the property;

       •      Removal of hazardous substances found inside the Elm Street facility as well as the
              demolition and disposal of the Mill Street building in 1993.  This included the removal of
              750 bags of dry paint pigments,  327 drums of hazardous substances,  10 bags of friable
              asbestos and 2,500 miscellaneous substances;

       •      Removal of contaminated surface soils on residential properties across from the Mill Street
              Site in 1995; and

       •      Removal of contaminated surface soils on the property  located in front of the Elm Street
              cemetery so that a Korean War memorial could be placed there.

What remains at the Site is contamination that poses a long-term threat to human health and the
environment.

13. A citizen is concerned that the remedy is being implemented without regard to input from the people
of the town. This citizen would prefer that the EPA wait for results from the tests on the thermal
blanket and also suggests that it may be prudent to actually test the blanket under conditions similar to
Milford's. It is preferred that the remediation be done right the first time.

EPA Response: EPA includes public acceptance as one of its evaluation criteria for selecting a remedy. In
addition, EPA has held many public informational meetings on the nature of the contamination at the Site,
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the potential community impacts, and the FS alternatives. These public meetings were to gather public
comment prior to EPA issuing the Proposed Plan for the cleanup of the site prior to making a decision on
the remedy. With respect to the selected remedy,  a thorough evaluation has been conducted with the
primary goal of ensuring that human health and the environment are protected, both during implementation
and in the future.

Please refer to comment 5 above for EPA response to issues relating to the use of ISTD-Thermal Wells at
the site.

14. A citizen supports the EPA actions to cleanup the contamination using thermal desorption. The cleanup
could potentially spur economic development and also provide beneficial future use of the Keyes Municipal
well.

EPA Response: EPA believes that the use of ex-situ thermal desorption is the best option for the cleanup
of the contaminated soils at the Site. Treatment of the soils is consistent with EPA's preference for the
use of treatment to eliminate principal health threats at the site, and to reduce the toxicity, mobility,
and volume of the hazardous substances at the Site. Thermal desorption, while considered an innovative
technology, has been used successfully at many Superfund Sites for the cleanup of PCB contaminated soils.

The future use of the Keyes Well is in guestion though as the monitored natural attenuation called for as
part of the selected remedy will take approximately 25 years for the VOCs to reach cleanup standards and
100 years for the PCBs to reach its cleanup standard. The contamination present in the Keyes Well Field
will be addressed as part of Operable Unit two for the Site. Th determination to allow for monitored
natural attenuation in the selected remedy was in part based on a review of the Town's future foreseeable
drinking water needs and the active restoration of the upgradient Savage Well. Should the Keyes Well
Field be used in the future as a drinking water supply, well head protection measures would also have to
be considered.

General Electric/Potential Responsible Party Comments

II.    Cover Letter to Comments on EPA's Proposed Remedial Action Plan

15.    GE believes that EPA's proposed remedies for Mill and Elm street properties do not adeguately take
into account the significant potential physical risks of injury or fatality  (due to truck traffic,
excavation eguipment, etc.)

EPA Response:  While the ChemRisk calculations are correct and reasonable for the chance of a reportable
motor-vehicle accident over the course of the project lifetime, they have been incorrectly interpreted as
representing the chance of a fatal accident. Moreover, this estimate of a fatal accident has then been
compared to the increase in individual risk from the chemicals on site. A more appropriate assessment and
comparison is provided below.

ChemRisk used a basic accident rate of 1 per 400,000 miles or 2.5 x 10 -6 per mile. The corresponding
fatal accident rate is 1.8 per 100,000,000 miles or 1.8 x 10 -8 per mile (Accident Facts, National Safety
Council, 1994) . If the rate for large trucks were used, rather than that for all vehicles, the number
would be slightly greater, about 3 x 10 -8 per mile. For the estimated 800 total miles associated with
the execution of the project, the estimated risk is, therefore, 2.4 x 10 -5 or 2.4 chances in 100,000.
This is about 100 times lower than the number assumed by GE in their statements. Because of the potential
to increase the standard at the Mill street site for the protection of groundwater, the potential also
therefore exists to reduce the volume reguiring excavation at the Mill street site, thereby reducing the
number of trucks and the miles traveled transporting those soils to the Elm Street site for treatment and
back.  An increase of the Mill Street subsurface standards from the 1 mg/kg PCB to 100 mg/kg PCB  (if EPA
determines is acceptable) would decrease the soil volume excavated from 13,500 cubic yards to 5,900 cubic
yards, a 7,600 cubic yard decrease. At 15 cubic yards per truck, traveling to and from Elm Street, this
would potentially reduce the number of truck trips by 500 (one way), thereby further decreasing the risk
of accident at the site.

It should also be noted that this risk is the total chance of a fatality, not the increase in risk per
person in the neighborhood or on the roads of concern. The same heavy truck statistics indicate that most
of the fatalities involve persons other than the truck drivers and that the average number of fatalities
per accident is roughly 1. Assuming that there are 100 people who might use the sidewalks or the roads in
guestion while the trucks are in use, the increase in risk to one of those individuals would therefore be
roughly 2.4 x 10 -5/100 or 2.4 x 10 -7 (2.4 chances in 10,000,000). If there are more people than this
who could be at risk, the risk per individual would decrease.
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16.    EPA's proposed remedy for the Mill Street property is likely to he ineffective and may actually
exacerbate existing conditions by mobilizing and spreading PCBs in the subsurface (due to the presence of
DNAPL in the subsurface).

EPA Response: EPA disagrees that Mill Street remedy is likely to be ineffective since the majority of
contamination presenting a known source to the groundwater would be remediated. Construction activities
would result in enhanced ground motion, however, the property is adjacent to a major railway which over
time has had the potential to enhance any DNAPL transport to a much greater extent than the expected
construction activities. The railway is active several times a day transporting propane and gravel
through Milford.,  It is also possible that the ground motion generated by the railway has facilitated the
current vertical extent of contamination currently observed at Mill Street Site, therefore, remediation
would limit the volume of material available for further transport through the subsurface.

If it is determined that excavation activities would facilitate an enhanced transport of the PCBs through
the subsurface, engineering controls can be used to offset the action, thereby protecting the bedrock.
Engineering controls such as horizontal barriers or even freezing technigues have been used with
excavation when facilitated transport during excavation is expected. EPA believes, however that because
the majority of the contamination at the Mill Street Site resides in the top few feet, and since no
free-phase DNAPL has been visually observed at the Site, that excavation of the contaminated soils is
feasible. The use of engineering controls will be considered during remedial design.

17.    EPA's proposed remedy for the Elm Street property does not recognize the Town of Milford's
intended future use of the Elm Street property as a parking lot and realistic risk assessment exposure
scenarios.

EPA Response: EPA disagrees with this comment and has worked closely with the Town of Milford over the
years to develop a reasonable future use scenario for both the Elm and Mill Street Sites. In doing so,
the EPA has altered the Baseline Risk Assessment several times to reflect the Town's anticipated future
uses. The selected remedy also incorporated the Town's latest comments whereby the town would prefer to
see a designated area for subsurface utilities over a more accessible general use of the subsurface at
Elm Street, as was previously related to the EPA. Please refer to comment 1 for more details on how the
selected remedy meets the Town's anticipated future uses for the site.

18.    The Proposed Plan does not adeguately take into account stakeholder inputs oil the remedy because
it is proposing a remedy that is more costly than necessary without any corresponding increase in
protection of public health and the environment. The proposed remedy is inconsistent with the intent of
Superfund reform initiatives to implement fairer, faster and more efficient remedies.

EPA Response: EPA disagrees with the commentor's suggestion that stakeholders inputs were not considered.
The entire development of the remedy involved many public meetings, presentations of alternatives,
presentations of community impacts, not to mention the numerous meetings and discussions with GE and the
Town of Milford, both of which are a PRP at this site. Public input and comment as well as the Town's and
GE's input have been considered and where appropriate, incorporated into the selected remedy,

Specifically, EPA has worked with the Town and the State of NH in developing the anticipated future uses
of the Site, such that the cleanup goals would be appropriate and consistent with CERCLA and to the
extent practicable, the NCP.

EPA has to consider the nine criteria specified in the NCP in selecting a final remedy. These criteria
include overall protection of human health and the environment, meeting ARARs, long-term permanence and
protection of the remedy,  short term impacts, implementability, the reduction of the mobility, volume and
toxicity of the hazardous substances through treatment and both State and public acceptance, as well as
cost-effectiveness. Costs alone are not sufficient reason for selection of a remedy.

While several alternatives had estimated present worth costs that were less than the selected remedy,
they did not meet the criteria when compared to the selected remedy. Specifically, the no action and
limited action source control alternatives were not protective of human health. The containment
alternative, supported by GE for the Mill Street portion of the Site, does not meet EPA's preference of
addressing principal threats through treatment, and would reguire extensive long-term operation of a
groundwater extraction and treatment system. Since the POTW was not able to consider accepting the
extracted groundwater at the time of the selection of the remedy, the groundwater would have to be
treated on-site to levels consistent with surface water discharge criteria. Because the containment
alternative left wastes in place below the water table, a groundwater treatment system would have been
reguired to operate for as long as the wastes remained, which would have been greater than 100 years.
While a feasible cleanup alternative, EPA did not receive any supporting comments for the containment
alternative from any party other than GE. The remainder of the cleanup, alternatives that employed the
use of treatment,  compared favorable in cost with thermal desorption alternative.
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EPA also disagrees that the selected remedy is inconsistent with EPA's fairer, faster and cost effective
policies since the selected remedy has costs and estimated cleanup time frames comparable to other
treatment technologies, including the ISTD-Thermal Well technology, and is $1.5 million less expensive
than the Proposed Plan cost. EPA believes that the selected remedy is cost effective since the remedy
reguires the treatment of all soils that pose the greatest long-term threat to human health and the
environment without reguiring a continuous, long-term pump and treat operation using hydraulic controls
to contain the contamination at the site for more that 100 years.

19.    Consider Alternative Remedial Action Plan (ARAP) which will (1) result in eguivalent protection of
human health and the environment (2) be less disruptive to Milford residents  (3)  will be completed at
significantly lower cost than EPA 's plan. Reguest EPA's serious consideration of the Alternative Plan,
including the Terra Therm In situ Thermal Desorption (ISTD) technology.

EPA Response: GE's proposed alternative cleanup plan is less expensive that the EPA's Proposed plan or
the selected remedy because GE's plan does not meet the same cleanup standards reguired in the selected
remedy for the protection of human health and the environment. Further GE's proposed alternative does not
meet the NH Env-Ws 410 regulations which reguire the treatment and removal, if feasible, or containment
of sources at the Site.

EPA invited GE to submit a Focused Feasibility Study which incorporated cleanup standards that were used
by the EPA in the review of the selected remedy  (including the Town's comment on changes to the
subsurface soils at the Elm Street Site). GE submitted such a report in December 1997.

The EPA's review of GE's FFS alternative concluded,, in summary, that 1)  contamination left in place, in
the subsurface at the Mill Street Site is inconsistent with NE's EnvOWs 410 regulations; 2) that GE's
containment alternative that did comply with NH's Env-Ws 410 regulations, was similar to EPA's
containment alternative as described in the FS and 3)  that insufficient information was available to
review the use of the ISTD-Thermal Well technology in an alternative against the nine criteria.

The FFS report and EPA's full evaluation of the alternatives proposed in the report can be found in the
Administrative Record available at the Wadleigh Memorial Library in Milford or at the EPA records center
in Boston, Massachusetts.

20.    EPA should consider as part of the remedy decision the results of additional field work that would
he conducted to characterize ground water conditions at Mill Street.

EPA Response: The only field work undertaken after the release of the Proposed Plan was the sampling of
monitoring well MW-07A for flocculent material. This material was tested for the presence of PCBs.  The
effort was conducted by GE in November of 1997 and the results reported to the EPA in May, 1998. This
information was considered in the selection of the remedy as the data indicated that the flocculent
material found in MW-07A contained 1,780 ug/1 PCB.  This concentration of PCB in the flocculent material
is extremely high given the fact that DNAPL materials were not identified in the presence of this
material during sampling. This would suggest that the PCBs at the site are very soluble in the paint
related compounds that make up the flocculent material. While EPA agrees with GE's position that once in
the flocculent state, which apparently is present only in the well screen,  the PCBs are not mobile.
However, EPA believes that the PCBs are or were solubilized into the paint related compounds at the
surface where the contamination was introduced in liguid form. Because the soils data at MW-07A indicate
that PCB concentrations fall off drastically before reaching the water table, and finding the floe
materials at the bottom of the well screened interval  (just above the water table to just above the
bedrock) , suggests that the PCBs are moving into and with the paint related materials at the surface and
are transported down the soil column. Further EPA believes that these materials are entering the well
screen at the water table, and with the presence of the iron, is precipitated out in the presence of
ambient air in the well screen forming what we have referred to as the flocculent material.

No other field studies were undertaken during the interval from the Proposed Plan (December 1996) and the
issuance of this ROD (September 1998). Further investigations are warranted during design on the full
extent of the contamination within the bedrock. Only one bedrock well is located in the Mill Street Site,
with the next closest bedrock well was on the Elm Street site adjacent to the river, 700  yards away.
There is some guestion outstanding of the potential presence of DNAPL within the bedrock. Please refer to
comment 2, for EPA's response relating to the potential for DNAPL at the Site. EPA believes it has
sufficient information at hand to select a remedy at this time.

21.   EPA should consider results off field tests currently underway on Terratherm's ISTD technology.

EPA Response: EPA has considered the data made available to date on Terratherm's ISTD-Thermal Well
technology. Please refer to comment 5 for more information related to EPA's review of the ISTD-Thermal
Well technology
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III.   GE/PRP Comments on EPA's Proposed Remedial Action Plan

Mill Street Properly

22.   GE agrees that removal of soil on the Draper Energy property is appropriate but they believe that
the proposed cleanup criterion of 1 ppm is too low and based on unrealistic assumptions. GE proposes a
PCB cleanup criterion of 6 ppm for these soils.

EPA Response: EPA set a surface soil cleanup standard at the Site at 1 mg/kg PCB, based on the TSCA Spill
Policy for unrestricted access in residential areas. While the Draper Energy property is a commercial
property, it is adjacent to residential areas. The exposure pathway considered dermal contact and
incidental ingestion and receptor were assumed to be adult and child trespassers.

EPA met with GE and the Town of Milford in August of 1996 following the release of the FS.  EPA accepted
GE comment suggesting changes to the assumptions used in the risk assessment. Using changes suggested by
GE and accepted by the EPA, the 1 mg/kg PCB soil cleanup level represents a 3 x 10 -6 excess cancer risk
and a hazard guotient of 0.4. EPA does not see any further justification to move off of the 1 mg/kg PCB
soil standard recommended in the TSCA Spill Policy given the potential exposure pathways and receptors at
the Site.

23.   The removal of soils front the Mill Street property is unnecessary and that a multi-layer cap with
deed restrictions to prevent future excavation of soils beneath the cap is the appropriate remedial
measure. GE sites the Sullivans Ledge Explanation of Significant it Differences and Norwood PCB site
Amended ROD as support for their claim where PCB concentrations of 1200 ppm and 70 ppm respectively were
allowed to remain under a cap.

EPA Response: Please refer to EPA's response to comment number 6.

24.  Implementation of EPA's method will he very difficult because of special construction measures that
will he reguired including railway and road stability, excess water when excavating soil below the water
table, and operating heavy eguipment in limited space.

EPA Response: The EPA recognizes that the excavation of soils at the Mills Street Site will be a complex
operation. The excavation will be performed in a manner that will be protective of human health and
minimize the impact on the surrounding community.

During the design and implementation of the remedy,  all of the factors mentioned in the comment will be
considered. Monitoring for PCBs, dust, and noise at the fence line of the Mill Street site will be
reguired. If the levels for PCBs, dust, or noise are exceeded at the fence line, the remedial action will
be shut down and additional engineering controls will be put in place. Based on past removal actions at
the Mill Street Site and EPA's extensive history of excavation as part of remedial cleanup actions at
other Superfund Sites, the EPA is confident that excavation of the contaminated soils can be carried out
without significant impacts to the surrounding community.

25.  GE believes that the 500 ppm soil cleanup criterion selected for the Elm Street. Site should be
applied at Mill Street.

EPA Response: Please refer to EPA responses to comments 4 and 6.

26.  GE believes, that excavation of soil is not reguired if chemicals are contained beneath a cap and
within a hydraulic containment system.

EPA Response: Please refer to EPA's responses to comments 4 and 6.

27.  GE believes that if their proposed alternative is selected it will produce much less impact to
nearby residents, the cost will he significantly reduced, the remedy will be egually protective of human
health and the environment as the EPA's Proposed Plan, and will he consistent with Region I approaches at
other sites  (Sullivan's Ledge, and Norwood PCBs).

EPA Response: Please refer to EPA's responses to comments 4, 6 and 23.

28.  EPA has not adeguately identified or considered the potential risks of injury or fatality to
construction workers, truck drivers and pedestrians that may result from implementing the Proposed Plan.

EPA Response: Please refer to EPA's response to comment 15.
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29.  Noise and dust impacts associated with the implementation of the Proposed Plan are a concern.
Although engineering controls will be implemented to minimize dust, noise would remain a nuisance.

EPA Response: Please refer to EPA's response to comment 5 and 23 regarding noise issues at the Site
during remedial action.

30.  The in-situ thermal desorption process has not been given sufficient consideration by the EPA.

EPA Response: Please refer to EPA's response to comment 5 regarding the ISTD-Thermal Well technology,

Elm Street Property

31.  GE believes that underground utility lines should be plugged and relocated along Keyes Drive as part
of the remedial action.

EPA Response: EPA agrees with the comment and the selected remedy incorporates a utility corridor, whose
exact location will be best determined during design. However EPA agrees that locating the utility lines
along the Keyes Drive is the most reasonable.

32.  The proposed surface soil cleanup criteria of 1 ppm for unrestricted off-site properties is
unnecessary and should be changed to 6 ppm. In addition, GE believes that excavation and off-site removal
of soils on the Elm Street property is unnecessary and that placement of a multi-layer cap, the
implementation of deed restrictions, and the planned relocation of utilities will provide adeguate
protection to human health and the environment.

EPA Response: Please refer to EPA's responses to comments number 1,4,6, and

33.  The removal of subsurface soils (1 to 10 feet)  with PCB concentrations greater than 10 ppm is based
on unrealistic assumptions for future site use. They state that the Town's planned future use for the
site, the Towns willingness to restrict future use of the site, and the relocation of utilities are
sufficient to provide adeguate protection of human health and the environment.  GE believes that EPA's
assumptions regarding risks are flawed in that they assume that subsurface soil will be brought to the
surface where routine and prolonged soil contact by children and adults will occur. GE evaluated
potential risks resulting from utility worker, inadvertently puncturing the cap and being exposed to PCBs
1 day/year over a 25 year time period and found that, given this scenario, the acceptable soil
concentrations would be 943 mg/kg(ppm).

EPA Response: Please refer to EPA's response to comment 1 regarding changes to the subsurface future use
at the Elm Street Site. EPA set 25 mg/kg PCB as the cleanup level for soils within the utility corridor
at the Elm Street Site. This cleanup level was derived from the TSCA Spill Policy, and is protective of
utility workers from dermal contact and incidental ingestion of the contaminated soils. EPA agrees that
by limiting future excavations to within the designated utility corridor, subsurface soils will not be
re-deposited onto the surface in the future. The selected remedy incorporates this scenario, and also
reguires restrictions across the Site preventing unauthorized access into the subsurface.

34.  With regard to the excavation of stain-like material at Elm Street, GE believes that the application
of the in situ thermal desorption process should be evaluated for this area. If the process is proven
inappropriate, then soils in this area would be excavated and disposed off-site.

EPA Response: Please refer to EPA's response to comment number 5. To date no data has been submitted to
the EPA regarding the potential ability of the ISTD-Thermal Well to successfully remediate these
materials.
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Table 27: Fletchers Paint Site, Milford, New Hampshire, Chemical - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Action, Thermal Desorption Treatment
Medium

Soil
Potential Federal
 Requirement

Toxic Substance Control
Act  (TSCA) PCB Spill
Cleanup Policy
(40 CFR Part 761, Subpart
 G)
      Requirement  Synopsis

 Pertains  to  recent  PCB  spills  (of  50
 ppm PCB or qreater  and  occurrinq
 after 5/4/78)  and establishes
 cleanup qoals  for sites dependinq
on use and accessibility.
  Action to be taken to Attain
      ARAR

 These quidelines will be used
 in establishinq qoals for the
 cleanup of the contaminated
 soils dependinq on location,
 potential for exposure and
 concentration of PCBs.
   Status

    To Be
    Considered
Soil
EPA Guidance on
Remedial Actions for
Superfund Sites with PCB
Contamination  (1990)
 Describes  the  recommended
 approach to  evaluatinq  and
 remediatinq  Superfund sites with
 PCB  contamination.
The quidance set forth in this
document will be considered
 when establishinq remediation
qoals for PCB-contaminated
media.
                                                                                                                            To  Be
                                                                                                                            Considered.
Ground
Water
 Safe Drinkinq Water Act
 (SDWA) Maximum
Contaminant Levels
 (MCLs)
 (40 CFR 141.11-141.16,
141.61, 141.62)
 Provides  enforceable  cleanup
 standards for a number of common
 orqanic and inorqanic
 contaminants. These levels
 requlate  the  concentration of
 contaminants  in drinkinq water
 supplies.
SDWA MCLs will be attained
in accordance with the
manaqement of miqration
alternative(s) selected as part
of the remedy.
 Relevant and
Appropriate.
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Table 27: Fletchers Paint Site, Milford, New Hampshire, Chemical - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Action, Thermal Desorption Treatment
Media
Ground
Water
Ground
Water
Potential Federal
Requirement

EPA Ground Water
Protection Strategy
EPA Final Groundwater
Use and Value
Determination Guidance
 Requirement Synopsis

 Provides  classification  and
restoration of qround water based
on its vulnerability,  use,  and value.

This regional guidance establishes
 an  approach allowing  States  to  play
a pivotal role in determining the
 relative "use" and "value" of site
 groundwater resources. The
 determination of the aquifer as a
 "high",  "medium",  or "low" use
 aquifer impacts the appropriateness
 of restoration time periods and the
 extent of restoration of the
 contaminated groundwater plume
 as called for in the remedial
 alternatives.
Action to be Taken to Attain
 ARAR

   This  strategy will be
   considered in conjunction
   with  the  federal  SDWA  and

   The Site's groundwater
   aquifer was determined to be
   of "medium" use and value.
  The source control actions
   selected  meet the goals  of  the
   guidance  for medium use  and
   value aquifers, by providing
  for the  future attainment of
  groundwater cleanup levels
   within  a  reasonable time
   period.
Status

To  Be
Considered.
 To  Be
 Considered
Surface
Water/
Ground
Water
 SDWA Non-Zero MCL
 Goals (MCLGs)
 (40 CFR 141.50-141.51)
  Provides nonenforceable health
  goals  for  public water systems.
  EPA has promulgated non-zero
  MCLGs for specific contaminants
  SDWA Non-Zero MCLGs
  will be attained in accordance
  with the management of
  migration alternative(s)
  selected as part of the remedy.
 Relevant  and
 Appropriate
-------
Table 27: Fletchers Paint Site, Milford, New Hampshire, Chemical - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Action, Thermal Desorption Treatment
              Potential State
              Requirement
 Requirement Synopsis
Action to be Taken to Attain
 ARAR
                                     Status
Media
Surface      Clean Water Act  (CWA) ,
Water        Ambient Water Quality
             Criteria (WQC)  for
             Protection of Human
             Health and Aquatic Life
  AWQCs  are  developed under the
  CWA as  quidelines  from which
  state develop water quality
  standards  for protection of human
   health and aquatic orqanisms.
  AWQCs will be attained in
  surface waters at the end of
   the  remedial  action,  either
   throuqh natural attenuation or
   active remedial measures.
Relevant and
Appropriate.
              Potential State
Media         Requirement

Ground        New Hampshire
Water         Groundwater Protection
              Requlations; Ambient
              qroundwater Quality
              Standards (AGQS)
              (Part Env-Ws 410.03,
              Feb. 1993)
 Requirement Synopsis

 Establishes criteria for qround
water  quality  (AGQSs);  states  that
qround water may not  contain
 contaminants above the numerical
 concentrations set in Env-Ws
410.05.
Action to be Taken to Attain
 ARAR

  Remedial actions will be
  required to treat affected
  qround water  or to  eliminate
  discharqe to  the qround water.
  Any  discharqes to qround
  water must not cause any
  deqradation to surface water
   (the Souheqan River)  so as  to
  violate surface water quality
  standards in  adjacent surface
  waters
  Status

 Applicable.
Ground        New Hampshire
Water         Groundwater Protection
              Requlations
              (Part Env-Ws 410.05,  Feb
              1993)
 Establishes qround water discharqe
 criteria which  include  the MCLs
  (and MCLGs) adopted by the
,  Water  Supply and  Pollution
  Control Division.
  The remedial action will
  eliminate discharqe of
  contaminants,  includinq
  VOCs,  PCBs,  and  inorqanic
  contaminants,  resultinq  in
  qround water contamination
  concentrations above  state
  MCL and MCLG levels.
  Applicable.
-------
Table 28 :  Fletcher's Paint Site, Milford, new Hampshire, Location -Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Action, Thermal Desorption Treatment
Medium

Sediment
Wetlands
Potential Federal
  Regulation

 Clean Water Act (CWA)
Section 404(b)
(40 CFR 230; 33 CFR
320-330)
 Protection of Wetlands
 (Executive Order No.
11990) 40 CFR 6,
Appendix A  (Policy on
Implementing E.O. 11990)
     Requirement  Synopsis

States that no discharge of
dredged  or  fill  material  shall be
permitted if there is a practicable
alternative that has less  adverse
impact on aguatic ecosystem
 provided the alternative does not
 have other significant adverse
 environmental conseguences.

Reguires that Federal agencies
preserve and enhance natural  and
beneficial  values of wetlands and
minimize the destruction  and
loss  or degradation of wetlands.
Action to be taken to
   Attain ARAR

    Excavations at the  site will
    not discharge dredged or
    fill materials into the
    wetlands.
  Status

 Applicable.
   The alternative will be
   implemented with control
   of wetlands excavation to
   the greatest extent
   possible. Any excavation
   in the wetlands  will  meet
   the reguirements of this
   Executive Order,
   Mitigation will  follow any
   such excavations.
Applicable to
excavation and
treatment of
contaminated soils
and sediments from
wetland areas.
Floodplains   Floodplain Management
              (Executive Order No.
              11988)  40 CFR 6.302(b)
              and 40 CFR 6, Appendix
              A  (Policy on
              Implementing E.O. 11988)
                             Reguires that Federal agencies
                             reduce  the risk of flood loss,
                             minimize impacts of floods,  and
                             restore and preserve the natural
                             and  beneficial value of
                             floodplains.
                                         The  alternative will be
                                         implemented  to minimize
                                         the  impacts  to the  risk  of
                                         flood  loss to the greatest
                                         extent possible. Any
                                         activities in the
                                         floodplains will  meet the
                                         reguirements  of this
                                         Executive Order.
                                         Mitigation will follow any
                                         such excavations.
                                     Applicable.
Surface       Fish and Wildlife
Water         Coordination Act
               (16 USC 661-666)
                           Reguires the protection of fish or
                           wildlife resources related to
                           actions that control or modify
                            water bodies.  U.S.  Fish and
                            Wildlife Service must be
                            consulted if any federal agency
                            proposes to modify water bodies.
                                         The  alternative will be  in
                                         compliance with this
                                         regulation.  The U.S. Fish
                                         and  Wildlife Service has
                                         been consulted.
                                     Applicable.
-------
Table 28 :  Fletcher's Paint Site, Milford, new Hampshire, Location - Specific Applicable or Relevant and Appropriate
Regulations (ARARs) for the Source Control Action, Thermal Desorption Treatment
Medium             Potential State
                   Requirement

Wetlands      Dredging and Control of
              Runoff
              (RSA 485-A:17);
              Dredging rules: Env-Ws
              Part 415
       Requirement Synopsis

Establish criteria for conducting
any activity in or near state
surface waters which may
adversely affect water quality.
 Action to be taken to
    Attain ARAR

Excavations near the
Souhegan River will
comply with these
requirements.
 Status

Applicable.
Wetlands      New Hampshire Wetlands
              Act
              (RSA 482-A,  Env-Ws
              300-400,600,700)
Established to minimize physical
alteration to wetlands  so their
beneficial functions  can be
 preserved.
Remedial activities in
wetlands located in or
adjacent to the site will
comply with these
wetlands protection
requirements.
Applicable.
-------
Table 29: Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium

Air



Air
      Potential Federal
       Requirement

      Resource Conservation and
      Recovery Act (RCRA)
      (40 CFR 265 Subpart P)

      RCRA
      (40 CFR 264, Subpart AA)
Air
      RCRA
      (40 CFR 264,  Subpart
Air
RCRA
(40 CFR 264, Subpart CC)
Asbestos National Emission
         Standards for Asbestos
         (40 CFR 61; Subpart M)
Soil    Toxic Substance Control
        Act (TSCA)
        (40 CFR 761)
                                                Requirement Synopsis
Requlations contain requirements
for air pollutant emissions from
thermal units.
                                        Action to be Taken to
                                                Attain ARAR
 The  alternative  shall meet
 the  requirements  set forth
in this subpart.
Requlations  contain  air pollutant   The  alternative  shall meet
emission standards for process
vents,  closed vent  systems,  and
control devices  at  hazardous
waste  treatment,  storaqe,  and
disposal facilities.

Establishes  desiqn  specification
 and monitorinq requirements for
equipment  that contains  or
contacts hazardous  wastes  with
orqanic concentrations of  at least
10%  by weiqht
                                                                              the  requirements  of  these
                                                                              requlations  set forth  in this
                                                                              subpart. Appropriate if they
                                                                              are  not.
 The  thermal  desorption
 equipment will be
 desiqned, and monitorinq
 conducted, to comply with
 this requirement.
Would establish emission controls    The  thermal  desorption
 for tanks, containers, and surface  equipment will be desiqned
impoundments  havinq a volatile        to  comply with this
concentration equal to or qreater     requirement
 than 500 ppmw.
                                   Requlations  contain  requirements
                                   for inspectinq and demolishinq
                                   structures that may  contain
                                   asbestos and disposinq of that
                                   material found to contain
                                   asbestos.
                                  All materials that contain PCBs at
                                   concentrations  of 50  ppm or
                                   qreater  shall be  disposed of  in an
                                   incinerator or  in a  chemical  waste
                                   landfill or,  upon application,  usinq
                                   a disposal method to be approved
                                   by the EPA Reqion in which  the
                                   PCBs  are located.
                                      Structure(s) will be
                                      inspected  and  demolished
                                      and  any material
                                      containinq asbestos
                                      disposed of in accordance
                                      with these requirements.

                                      Followinq  thermal
                                      desorption,  effluent will be
                                      incinerated off site in
                                      accordance with these
                                       requlations,
    Status

Relevant and
Appropriate
                                      Applicable if
                                      threshold levels are
                                      met;  Relevant and
  Applicable if
  threshold levels are
  met; Relevant, and
  Appropriate if they
  are not.
                                        Applicable  if
                                        threshold levels  are
                                        met;  Relevant and
                                        Appropriate if they
                                        are  not.

                                        Applicable  if
                                        asbestos-containinq
                                        material found in the
                                        Fletcher's  Elm Street
                                        Paint works is
                                         scheduled  for
                                         demolition.

                                       Applicable if PCB
                                       concentrations are 50
                                      ppm or qreater.
-------
Table 29 Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium
Soil
Soil
Soil
Soil
Soil
Potential Federal
 Requirement

 TSCA - 40 CFR
 761.65(c) (9) ,
 761.65(c) (9) (iv)
 761.61(c),  Storage and
 Disposal of Bulk PCB
 Remediation Waste
            TSCA 40 CFR
            761.65(c)(1)  and
           761.61(c),  Storage and
            Disposal of Liguid PCB
            Remediation Waste
  TSCA Spill Policy
  (40CFR 761.60[d])
  Guidance on Remedial
  Actions for Superfund
  Sites with PCB
  Contamination
  (OSWER Directive
  9355.4-01,  August,  1990)

  Guidance Document:
  Final Covers on Hazardous
  Waste Landfills and
  Surface Impoundments,
  July 1989
  (EPA/530-SW-89-047)
Reguirement Synopsis

 This regulation allows for the
 temporary storage of bulk PCB
 and remediation wastes,  for a duration
 not to exceed 180 days.  The EPA
 Regional  Administrator can
 approve alternate storage and
 disposal  methods consistent with
 the "risk-based option".

 These regulations address the
 storage and disposal reguirements
 for the remediation of PCB wastes
 at facilities where liguids have
 been contaminated by a PCB spill.
 Generally,  liguid wastes  must be
 disposed  of within 30 days.  The
 EPA Regional Administrator can
 approve alternate storage and
 disposal  methods consistent with
 the"risk-based option".
    Action to be  Taken to
    Attain ARAR

     Reguirements will be met.
      Status

Applicable
 Policy establishes guidelines for
 spill cleanups to different levels
 depending on  spill location,
 potential for exposure, and
  concentration of PCBs actually
 spilled.

 Guidance establishes  an approach
 for evaluating and remediating
 PCB contamination at  Superfund
 Sites.
                                                                     Storage  reguirements will
                                                                    be complied with, or
                                                                     grounds  for a waiver will
                                                                     be met.
                                 Applicable if PCJ3
                                 concentrations are 50
                                 ppm or greater.
The Policy will be
considered in determining
cleanup  levels for  PCBs.
 This  guidance will be
 considered  in determining
 cleanup  levels  and
appropriate technologies,
                                                                                                                  To Be Considered
    To Be Considered
  Guidance establishes design
  specifications  for landfill  closure
  that meet RCRA 264  Subpart G
  (Subtitle C Landfill)  closure
  reguirements.
  This  guidance will be
 considered when designing
  the final  cover.
                                                                                                                   To Be Considered
-------
Table 29: Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium       Potential Federal
             Requirement

Ground       Clean Water Act  (CWA),
Water        Section 402, National
             Pollutant Discharge
             Elimination System
             (NPDES) 33 USC 1342;
             40 CFR 122-125, 131

Ground       Guidance of Use of
Water        Monitored Natural
             Attenuation at Superfund,
             RCRA Corrective Action
             and Underground Storage
             Tank Sites
             (OSWER Directive
             9200.4-17, Dec, 1997)
                            Requirement Synopsis

                            These standards govern discharge
                            of water into surface waters.
                            Guidance establishes
                            implementation guidelines for
                            monitored natural attenuation
                            remedies.
                                       Action to be Taken to
                                       Attain ARAR

                                       Discharge from the water
                                       treatment plant associated
                                       with the dewatering of the
                                       Mill Street soils, will meet
                                       AWQCs.
                                       This guidance will be
                                       considered during the
                                       design and performance of
                                       the long-term monitoring
                                       of the groundwater.
                                Status

                                Applicable
                                To Be Considered
Ground       Guidance on the
Water        Presumptive Response
             Strategy and Ex-situ
             Treatment technologies for
             Contaminated
             Groundwater at CERCLA
             Sites  (EPA 540-R-96-023,
             Oct 1996)
                            Guidance establishes design
                            specifications for implementing
                            presumptive groundwater
                            remedial actions.
                                       Guidance will be
                                       considered during the
                                       development of the long-
                                       term groundwater
                                       monitoring program and
                                       future bedrock studies.
                                To Be Considered
Soil
             RSA Chapter 147-A, New
             Hampshire Hazardous
             Waste Management Act
             and Hazardous Waste
             Rules
             (Env-Wm 100-1000)
                            State Hazardous Waste
                            Management Standards operated
                            in lieu of federal RCRA Subtitle
                            C requirements.
                                       Management of hazardous
                                       wastes will comply with
                                       the substantive standards of
                                       these regulations.
                                 Individual sections
                                 summarized below.
Soil
Soil
Siting Requirements
(Env-Wm 353.09) and
Variances to Siting
Requirements (353.10)
             Env-Wm 708.03(d) and
             (d) (1)
Provision establishes siting
requirements and variances for
hazardous waste facilities near
geologic fault areas and flood
plains and sets forth state
procedures for identifying the
boundaries of the flood plains.

Outlines operational requirements
for proper and safe management
and conditions for containers and
tanks.
The thermal desorption           Waived
treatment facility will be
constructed in compliance
with siting requirements or
variance criteria.
                                                                   This alternative will            Applicable.
                                                                   conform with the proper
                                                                   and safe usage of tanks and
                                                                   containers in accordance
                                                                   with these requirements.
-------
Table 29: Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations  (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium

Soil




Soil
Soil
Ground
Water
Potential State
Requirement

Env-Wm 702.09
Operation Requirements
for Hazardous Waste
Facilities
(Env-Wm-708.02)
UST Requlations and
Guidelines
(ENV-Ws 411.18)
Nondeqradation of Ground
water to Protect Surface
Water
(Env-Ws 410.03)
Requirement Synopsis

Establishes desiqn requirements
for hazardous waste facilities.
Establishes a variety of
requirements relatinq to operation
and closure of hazardous waste
facilities.
The NHDES must be notified
prior to scheduled closure or
removal of USTs. Hazards and
potential contamination must be
assessed, and the NHDES must
inspect site and approve of
closure.
Provides that qround water shall
not contain any contaminant at
concentrations such that natural
discharqe of that qround water to
surface water results in a violation
of surface water quality standards.
Action to be Taken to
Attain ARAR

The thermal desorption
treatment facility will be
constructed in accordance
with desiqn requirements.

Facility construction,
operation, closure, and
post-closure will meet
these requirements.
To excavate the first ten
feet of PCB-contaminated
soil, it will be necessary to
remove five USTs. This
alternative will comply
with the requlations and
quidelines if UST removal
is performed.

The remedial action will
eliminate or prevent any
discharqes to qround water
resultinq in a violation of
surface water quality at
adjacent surface waters or
renderinq qround water
unsuitable for drinkinq
water
Status

Applicable.
Applicable to
operation of a
facility: Waived for
closure requirements
dependinq on action.

Applicable.
Applicable.
Ground
Water
Env-Ws 410.26
Groundwater Manaqement
Zone  (GMZ)
These provisions set forth
requirements for a GMZ
established under 410.03. The
requirements include inter alia,
isolations, institutional controls,
monitorinq, restoration of
qroundwater quality, methods of
establishinq GMZ boundaries, and
means of restrictinq qroundwater
extraction.
Monitorinq, institutional
controls and other actions
taken to remediate the
GMZ will be consistent
with this requirement.
Applicable
-------
Table 29: Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium       Potential State
             Requirement

Ground       Env-Ws 410.30 Water
Water        Quality Sampling,
             Analysis and Monitoring
Ground       Env-Ws 410.31  (a)
Water        Groundwater Monitoring
             Wells
                            Requirement Synopsis

                            Provides requirements for surface
                            water and groundwater sampling,
                            monitoring and analysis.
                            Requires monitoring wells to be
                            designed, installed and
                            decommissioned in accordance
                            with the practices of two
                            referenced guidance
                                       Action to be taken to
                                       Attain ARAR

                                       Surface water and
                                       groundwater sampling,
                                       monitoring and analysis
                                       will comply with these
                                       requirements.

                                       Monitoring wells will be
                                       designed, installed and
                                       decommissioned consistent
                                       with the practices in the
                                       guidance documents
                                       referenced.
                                 Status

                                 Applicable.
                                 Applicable.
Air
Air,
Ground
Water
NH Administrative Code,
Air, Chapter 100, Parts
604-606
Env-Wm 702.11 and
702.12
Establishes standards for the
release of VOCs, particulate
matter, and other hazardous air
pollutants.

Provisions establish ground water
monitoring requirements and
authorize the requirement of other
environmental monitoring.
Thermal desorption               Applicable.
equipment will be
constructed to comply with
these emission standards.

Ground water and air             Applicable.
emissions monitoring will
be conducted as necessary
during remediation.
-------
Table 29: Fletcher's Paint Site, Milford, New Hampshire: Action - Specific Applicable or Relevant and Appropriate
Regulations (ARARs) for the Source Control Actions, Thermal Desorption Treatment.
Medium       Potential State
             Requirement

Air          Env-A 1002
                            Requirement Synopsis

                            Establishes prevention, abatement,
                            and control procedures for
                            fuqitive dust emissions due to
                            construction and excavation.
                                       Action to be taken to
                                       Attain ARAR

                                       This alternative will follow
                                       these procedures to
                                       maintain dust control
                                       durinq remediation
                                       activities.
                                 Status

                                 Applicable.
Air
             Env-A 1305
Surface
Water
Surface
Water
Standards for
Classifications of Surface
Waters of the State
(NH Water Quality
Criteria Standards, RS
Chapter 149:3, Ws 400,
Parts 430-439)
Water Quality Standards
 (Env-Ws 437) ;
NH Antideqradation
Policy
 (Env-Ws 439)
Establishes requirements for
technoloqy and for air impact
analysis with respect to devices
emittinq requlated substances.

Requirements include the
prohibition of disposal of wastes
that will lower the quality of any
surface water below the minimum
requirements of surface water
classification. Included are
environmental-based standards for
contaminants associated with
specific classes of water.

States that no persons shall place
or discharqe pollutants into any
waters of the state unless the
discharqe complies with effluent
standards and limitations, and will
not deqrade existinq water quality.
Discharqes from any new
or modified facility will
comply with these
requirements.

Discharqe of pollutants to
surface waters will meet
applicable standards.
                                                                                                    Applicable.
Applicable.
Discharqes of pollutants to
surface waters will meet
applicable standards
Applicable.
-------
Table 30: Fletcher's Paint Site, Milford, New Hampshire, Chemical - Specific Applicable or Relevant and Appropriate
Requirements (ARARs) for the Management of Migration, Limited Action/ Institutional Controls
Medium

Soil
Soil/
Ground
Water
Potential Federal
Requirement

Toxic Substance Control
Act  (TSCA) PCB Spill
Cleanup Policy (40 CFR
Part 761, Subpart G)
EPA Guidance on
Remedial Actions for
Superfund Sites with PCB
Contamination  (1990)
Requirement Synopsis

Pertains to recent PCB spills (of
50 ppm PCB or qreater and
occurrinq after 5/4/78)  and
establishes cleanup qoals for
sites dependinq on use and
accessibility.

Describes the recommended
approach to evaluatinq and
remediatinq Superfund sites with
PCB contamination.
Action to be Taken to Attain
ARAR                                Status

Temporary cover system will         To Be
be maintained; institutional        Considered
controls will be placed on the
property restrictinq uses and
activities on the properties.
Guidance will be considered         To Be
when establishinq lonq-term         Considered.
manaqement activities.
Ground       Safe Drinkinq Water Act
Water        (SDWA) Maximum
             Contaminant Levels
             (MCLs)  (40 CFR
             141.11-141.16, 141.61,
             141.62)
Ground       EPA Ground Water
Water        Protection Strateqy
                             Provides enforceable cleanup
                             standards for a number of
                             common orqanic and inorqanic
                             contaminants. These levels
                             requlate the concentration of
                             contaminants in drinkinq water
                             supplies.

                             Provides classification and
                             restoration of qround water based
                             on its vulnerability, use, and
                             value.
                                      SDWA MCLs will be attained
                                      throuqh natural attenuation.
                                    Relevant and
                                    Appropriate.
                                      This strateqy will be considered
                                      in conjunction with the federal
                                      SDWA and New Hampshire
                                      Water Quality Standards.
                                    To Be
                                    Considered.
-------
Table 30: Fletcher's Paint Site, Milford, New Hampshire, Chemical - Specific Applicable or Relevant and Appropriate
Requirements (ARARs) for the Management of Migration, Limited Action/ Institutional Controls
Medium

Surface
Water/
Ground
Water
Potential Federal
Requirement

SDWA Non-Zero MCL
Goals  (MCLGs)  (40 CFR
141.50-141.51)
Requirement Synopsis

Provides nonenforceable health
qoals for public water systems.
EPA has promulqated non-zero
MCLGs for specific
contaminants.
Action to be Taken to Attain
ARAR

SDWA Non-Zero MCLGs will
be attained throuqh natural
attenuation.
Status

Relevant and
Appropriate.
Surface
Water
Ground
Water
Clean Water Act  (CWA) ,
Ambient Water Quality
Criteria  (WQC) for
Protection of Human
Health and Aquatic Life
EPA Final Groundwater
Use and Value
Determination Guidance
AWQCs are developed under the
CWA as quidelines from which
state develop water quality
standards for protection of
human health and aquatic
orqanisms.

Provides a ratinq system for the
State to establish restoration
qoals for a qroundwater aquifer
based on its vulnerability, use
and value.
AWQCs will be attained in           Relevant and
surface waters at the end of        Appropriate.
remedial action throuqh natural
attenuation.
This quidance was considered in     To Be
conjunction with the federal        Considered
SDWA and the New Hampshire
Groundwater Protection Rules in
order to determine qroundwater
cleanup levels. The aquifer was
classified as medium value. The
limited Action/ institutional
Control actions selected are
consistent with this.
Ground       New Hampshire
Water        Groundwater Protection
             Requlations, Ambient
             Groundwater Quality
             Standards  (AGQS)
             (Part Env-Ws 410.03, Feb
             1993)

Ground       NB Groundwater
Water        Protection Requlations
             (Part Env-Ws 410.05, Feb.
             1993)
                             Establishes criteria for qround
                             water quality  (AGQS),  states that
                             qround water may not contain
                             contaminants above the
                             numerical concentrations set in
                             Env-Ws 410.05.
                             Establishes qroundwater
                             discharqe criteria which include
                             the MCLs  (and MCLGs) adopted
                             by the NH WSPC Division.
                                      Ground waters will be allowed to
                                      naturally attenuate.
                                    Applicable.
                                      Groundwater will be allowed to
                                      naturally attenuate and will be
                                      monitored until standards have
                                      been met.
                                    Applicable.
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Table 31: Fletcher's Paint Site, Milford, New Hampshire, Location- Specific Applicable or Relevant and Appropriate
Regulations  (ARARS) for the Management of Migration, Limited Action/Institutional Controls
Medium

Sediment
Wetlands
Floodplains
Potential Federal
Requirement

Clean Water Act  (CWA)
Section 404(b)
(40 CFR 230; 33 CFR
320-330)
Protection of Wetlands
(Executive Order No.
11990) 40 CFR 6,
Appendix A (Policy on
Implementing E.O. 11990)

Floodplain Management
(Executive Order No.
11988) 40 CFR 6.302(b),
40 CFR 6, Appendix A
(Policy on Implementing
E.O. 119880
Requirement Synopsis

States that no discharge of dredged
or fill material shall be permitted if
there is a practicable alternative that
has less adverse impact on aquatic;
ecosystem provided the alternative
does not have other significant
adverse environmental
consequences.

Requires that Federal agencies
preserve and enhance natural and
beneficial values of wetlands and
minimize the destruction and loss or
degradation of wetlands.

Requires that Federal agencies
reduce the risk of flood loss,
minimize impacts of floods, and
restore and preserve the natural and
beneficial value of floodplains.
Action to be taken
to Attain ARAR

No actions will be
taken as part of this
alternative.
     Status

Applicable.
No actions will be
taken as part of this
alternative.
No actions will be
taken as part of this
alternative.
Applicable to excavation
and treatment of
contaminated soils and
sediments from wetland
areas.

Applicable.
Surface      Fish and Wildlife
Water        Coordination Act
             (16 USC 661-666)
Medium       Potential State
             Requirement

Wetlands     Dredging and Control of
             Runoff
             (RSA 485-A:17);
             Dredging rules: Env-Ws
             Part 415
                              Requires the protection of fish or
                              wildlife resources related to actions
                              that control or modify water bodies.
                              U.S. F& WL Service must be
                              consulted if any federal agency
                              proposes to modify water bodies.
                              Requirement Synopsis

                              Establish criteria for conducting any
                              activity in or near state surface
                              waters which may adversely affect
                              water quality.
                                         No actions will be
                                         taken as part of this
                                         alternative.
                                         Action to be taken
                                         to Attain ARAR

                                         No actions will be
                                         taken as part of this
                                         alternative.
                                    Applicable.
                                    Status

                                    Applicable.
Wetlands     New Hampshire Wetlands
             Act
             (RSA 482-A, Env-Ws
             300-400, 600,700)
                              Established to minimize physical
                              alteration to wetlands so their
                              beneficial functions can be
                              preserved.
                                         No actions will be
                                         taken as part of this
                                         alternative.
                                    Applicable.
-------
Table 32: Fletcher's Paint Site, Milford, New Hampshire, Action - Specific Applicable or Relevant and Appropriate
Requirements (ARARs) for the Management of Migration, Limited Action/ Institutional Controls
Medium

Surface
Water
Ground
Water
Potential Federal
Requirement

Clean Water Act; Sections
301-304
Safe Drinking Water Act;
40 CFR - Part 141
Requirement Synopsis

Establishes Ambient Water Quality
Criteria (AWQC)  standards for
presence of contaminants which
could adversely affect aquatic
orqanisms.

Establishes Maximum Contaminant
Levels  (MCLs)  for toxic chemicals
public drinkinq water systems.
Action to be Taken to
Attain ARAR

Surface waters will be
allowed to naturally
attenuate and will be
monitored until standards
have been met.

Ground waters will be
allowed to naturally
attenuate and will be
monitored until standards
have been met.
Status

Applicable.
Applicable.
Ground       Guidance of the Use of
Water        Monitored Natural
             Attenuation at Superfund,
             RCRA Corrective Action
             and Underqround Storaqe
             Tank Sites
             (OSWER Directive
             9200.4-17, Dec, 1997)
                              Guidance is intended for the
                              implementation of monitored natural
                              attenuation remedies.
                                        The quidance will be
                                        considered when desiqninq
                                        and implementinq the
                                        lonq-term monitorinq
                                        proqram for the
                                        qroundwater.
                                    To be
                                    Considered
Ground       Guidance on the
Water        Presumptive Response
             Strateqy and Ex-Situ
             Treatment Technoloqies
             for Contaminated
             Groundwater at CERCLA
             sites  (Oct, 1996)
             (EPA 540-R-96-023)
                               Guidance establishes desiqn
                               specifications for implementinq
                               presumptive qroundwater remedial
                               actions.
                                         Guidance will be
                                         considered durinq the
                                         development of the lonq
                                         term monitorinq proqram
                                         and future bedrock studies.
                                    To be
                                    Considered
             Potential State
Medium       Requirement

Ground       Env-Ws 410.07, 410.09,
Water        and 410.10. Prohibited
             Discharqe, Groundwater
             Discharqe Zone,
             Groundwater Discharqe
             permit Compliance Criteria
                               Requirement Synopsis

                               Prohibits discharqes to qroundwater
                               without use of BAT; requires controls
                               on use of qroundwater within
                               discharqe zone; sets limits on
                               discharqes to qroundwater
                                         Action to be taken to
                                         Attain ARAR

                                         Remedial measures
                                         involvinq discharqes to
                                         qroundwater must comply
                                         with these requirements.
                                     Status

                                     Applicable if
                                     treatment
                                     effluent  (from
                                     the de-waterinq
                                     action) is
                                     discharqed to
                                     the qroundwater.
-------
Table 32: Fletcher's Paint Site, Milford, New Hampshire, Action - Specific Applicable or Relevant and Appropriate
Requirements (ARARs) for the Management of Migration, Limited Action/ Institutional Controls
Medium

Ground
Water
Ground
Water
Ground
Water
Potential State
Requirement

Env-Ws 410.26
Groundwater Management
Zone  (GMZ)
Env-Ws 410.30
Water Quality Sampling,
Analysis and Monitoring
Env-Ws 410.3 1  (a)
Groundwater Monitoring
Wells
Requirement Synopsis

These provisions set forth
requirements for a GMZ established
under 410.03. The requirements
include inter alia, isolation,
institutional controls, monitoring,
restoration of groundwater quality,
methods of establishing GMZ
boundaries, and means of restricting
groundwater extraction.

Provides requirements for surface
water and groundwater sampling,
monitoring and analysis.
Requires monitoring wells to be
designed, installed and
decommissioned in accordance with
the practices of two referenced
guidance.
Action to be Taken to
Attain ARAR

Monitoring, institutional
controls and other actions
taken to remediate the
GMZ will be consistent
with this requirement.
Surface water and
groundwater sampling,
monitoring and analysis
will comply with these
requirement.

Monitoring wells will be
designed, installed and
decommissioned consistent
with the practices in the
guidance documents
referenced.
 Status

 Applicable
Applicable
Applicable
-------
               UNITED STATES ENVIRONMENTAL

                    PROTECTION AGENCY

                 STATE OF NEW HAMPSHIRE

                   PUBLIC HEARING RE:
            FLETCHER'S PAINT SUPERFUND SITE
                         TOWN HALL
                  MILFORD, NEW HAMPSHIRE

BEFORE: RICHARD C. BOYNTON, AS HEARING OFFICER

                      Wednesday, January  29,  1997
                      7:00 P.M.
                      Volume I
                 MARIANNE KUSA-RYLL
         REGISTERED PROFESSIONAL REPORTER
               JUSTICE HILL REPORTING
       252 JUSTICE HILL ROAD, P.O. BOX  610
        STERLING, MASSACHUSETTS 01564-0610
  TELEPHONE  (508) 422-8777 FAX  (508) 422-7799
-------
 1                                INDEX

 2
       SPEAKERS:                                                PAGE
 3
       Richard C.  Boynton,  Hearing officer                       3
 4
      Jill Siebels,  Project Manager
 5     General Electric                                         12

 6     Jack Hirsch,  Ph.D.,  Vice President, Technology
      TerraTherm Environmental
 7     Services,  Inc.                                            14

 8     Edward Frankavitz,
      Milford Consignment Outlet                                19
 9
      Handwritten speech by
10     Justin Danhof                                            21

12

13

14

15

16

17

18

19

20

21

22

23

24
-------
 1                        PROCEEDINGS





 2





 3                   HEARING OFFICER BOYNTON:  I am going





 4     to welcome everybody  to  the hearing for the





 5     Fletcher's Paint Superfund Site.  I  am Dick





 6     Boynton from the EPA  New England Regional Office





 7     in Boston.





 8                  Before I begin the  hearing,  I want to





 9     make an announcement  about our Project Manager,





10     Cheryl Sprague.  She had  a baby girl on Super Bowl





11     Sunday.  The baby's name  is Courtney,  and she is





12     7 pounds,  2 ounces, and  20 inches long,  and





13     everybody is doing fine; but that is  why Cheryl





14     can't be here, but she did call  this  afternoon  at





15    the office.





16                  And to  my  left  is Roger  Duwart, our





17     Project Manager  from  the New Hampshire section.





18     Roger will be helping us with the Fletcher's Paint





19     Site while Cheryl is  at  home with the baby.





20                 The  purpose  of tonight's  meeting is to





21     accept oral comments  on  the proposed  cleanup plan





22     for the Fletcher's Paint Site. I'll serve as the





23     hearing officer.





24                 The  proposed,  plan was  made public  on
-------
 1     December 27,  1996,  and was discussed in some





 2     detail at the meeting here on January 14,  1997.





 3     The public comment  period began on January 15th,





 4     and is scheduled to end on February 18th.




 5                The hearing will be conducted as





 6     follows: First,  I will give you a brief overview





 7     of the proposed plan,  and I will accept comments





 8     for the record.




 9                 If you  wish to comment,  please fill





10     out the cards and leave them for me. I already





11     have some cards here.  Please use the microphone





12     in the center of the room, state your name,  and




13     spell your last name for our court stenographer.





14     I am asking that you limit your comments to





15     15 minutes. If your statements take more than





16     15 minutes, please  summarize your important




17     points,  and provide me with a copy of the text





18    and the comments, and the text will be transcribed




19     into the hearing record.





20                 After the comments have been heard,  I




21     will close the hearing. Written comments may be





22     mailed to our Boston office at the address of the





23     proposed plan,  and  must be postmarked no later





24     than February 18th. All of the oral comments, and
-------
 1     the comments received during the comment period,





 2     will be responded to in a responsiveness summary,





 3     which will be included with the decision for the





 4     remedy,  for the site.  We call it a record of





 5     decision.





 6                  Are  there  any questions  about  our





 7     proceedings before,  we begin?





 8                  We won't  be responding to your





 9     comments tonight.  Those responses will be in





10     writing in response  to your comments.





11                  Are  there  any guestions  at all  before





12     we start?





13                  First, let me just move  over here.





14                  AUDIENCE PARTICIPANT:  Can we  turn up





15     the volume on this.  It's not clear.





16                  HEARING  OFFICER BOYNTON:   To refresh





17     everybody's memory,  I'm going to go over the site





18     and put up an agenda.  I already did an introduction.





19     I'll talk  guickly about the site description, the





20     cleanup alternatives that we looked at,  and  our





21     proposed cleanup plan, and then we will take oral





22     comments for the record.





23                  First, a picture of the  site,  and this





24     is the Mill Street property, which is  a very
-------
 1     condensed area.  This shaded area represents the





 2     contaminated groundwork;  and as you see here,  this





 3     is the Fletcher  Paint property, and the building,





 4     and then Keyes Field is out here,  and the road is





 5     down here.





 6                   Very  guickly,  the cleanup alternatives





 7     that we looked at for our dealing with the





 8     contamination at the site are as follows:       For the





 9     soil cleanup,  we put that no action is reguired to





10     do that,  but that gives us the background to





11     compare the other alternatives against. Then it





12     means what it says, no action for the site.





13                   The limited action would be involved





14     with monitored and  restricted use of the site.





15     There would be some costs associated with that.





16                   Then  we  look at the  containment





17     solution,  which  includes  a flexible membrane cap,





18     removal of about three feet of soil,  and a





19     flexible membrane cap to  prevent infiltration of





20     water,  rainwater to the site, with vertical





21     barriers to   protect  the groundwater from carrying





22     contamination from the site.





23                   COURT REPORTER:  Excuse  me.  I'm





24     having trouble hearing you with people walking
-------
 1     by.  Could you move the microphone over,  please.





 2     Perhaps that will help.





 3                   Thank  you very much.





 4                   HEARING  OFFICER  BOYNTON:   So we  look





 5     at a containment remedy,  which includes  a cap, a





 6     flexible membrane liner,  vertical barriers  to





 7     prevent the groundwater from entering the site,  to





 8     prevent it from leaving the site, the groundwater





 9     and discarding it,  in this case,  in the  river.





10                   And then we  looked  at  off-site





11     disposal alternatives. That would be excavation





12     of the soil,  putting it in trucks or railcars, and





13     transporting it to an approved hazardous waste





14     landfill,  or to a hazardous materials incinerator





15     for destruction.





16                   Then lastly,  we  looked at  an on-site





17     alternative.  We looked at low temperature thermal





18     desorption,    which  is a process  like a  non-contact





19    heating in an oven,  and driving the volatiles from





20     the soil into a situation where we can condense





21     them,  and consolidate them, and take them off site





22     for disposal. That leaves us with clean  soil.





23                   We also  looked at





24    stabilization/solidification of the soil, the
-------
 1    contaminated soil,  which entails mixing them with





 2     additives like cement,  fly ash,  or asphalt,  to





 3     contain the contamination so it would actually fix





 4     it in place,  but that still involves a volume




 5     increase in the amount of material you have  to





 6     deal with,  and it  also involves placing a cap over





 7     it.





 8                   Then we  looked at  solvent  extraction.




 9     This is basically  a  washing of the soil with a





10     solvent or a surfactant,  and then concentrating





11     that solvent and contamination into a solid  for





12     off-site disposal. It reguires a lot of soil




13     handling and a lot of use of solvent.





14                   And  then we looked at how  we're  going





15     to clean up the groundwater, and we got into a





16     situation where if we had to do that, we looked at




17     a no-action alternative  for comparison.





18                 We looked at a limited action, which





19     means we would monitor it for the foreseeable





20     future, foreseeable  background basically,        and




21     restrict the use of  the  groundwater, maybe use it





22     as a portable water  supply or -- I don't think you





23     can use it for an  industrial supply anyway.





24                  Then, lastly, we looked at a treatment
-------
 1     alternative,  which is pumping the groundwater





 2     directly into the ground,  air stripping,  where you





 3     put it through a situation where you pump air





 4     through it,    drive  the volatile contaminants  on  to




 5     the air stream,  and that  would activate it into an





 6     activated carbon and gaseous state,       and remove the





 7     contaminants  that collect on the carbon.





 8                   Again,  the  second  alternative was just




 9     passing the  liguid phase  through the granular





10     activated carbon,  and then recycling and





11     regenerating  the carbon.





12                   Lastly,  we  looked  at ultraviolet




13     radiation and some kind of oxidant to actually





14     destroy the  contaminants  in place,  and for that we





15     would use ozone or man-made — some  kind of





16     chemical as  an oxidant.




17                   That is  what we  looked at in the whole





18     gamut when we begin to compare all the alternatives.





19                   Then I  should talk a little  bit





20     briefly about the proposed plan, the preferred




21     cleanup plan,  which we broke into two phases,





22     dealing with  the Mill Street property first,  which





23     we thought was more  concentrated or  contaminated.





24     And,  basically,  at Mill Street,  what we are
-------
 1     proposing to do is move about 15,000 yards of





 2     contaminated soil,  and truly bring them to the Elm





 3     Street site,  and treat them with the thermal





 4     desorption unit,  which as I mentioned before is




 5     like a large oven that can separate the PCBs from





 6     the soil.





 7                  And also  in Phase I,  we would demolish





 8     and take the Fletcher's Paint Works building off




 9     the Elm Street site and dispose of the rubble at





10     an approved landfill,  and remove the five





11     underground storage tanks that are currently





12     located on the Fletcher's Elm Street property.




13     This would be probably a process of somewhere from





14     25 to 30 weeks we estimate, once we design what we





15     are going to do and begin activity.





16                  And then  the second phase,  after we




17     complete the Mill Street clean up,  would be to





18     deal with the contaminated soils on the Elm Street





19     property,  and this involves treatment of about





20     29,000 yards of contaminated soils, the way we




21     estimate it,  and we also would treat these on-site





22     with the thermal desorption unit,  the same unit





23     that we use on Elm Street,  and we would





24     excavate -- there are  some highly contaminated
-------
 1     soils and wastes in the area,  and we would





 2     excavate those and dispose of  them off-site;  and





 3     then we would place an impermeable,       flexible cap





 4     in the drainage area asphalt,      and we would assist





 5     with that,  and the idea behind this  would be  it





 6     wouldn't restrict the use of the property for some





 7     industrial purposes.





 8                  AUDIENCE PARTICIPANT: What  date  are





 9     we talking about here now for  the second phase,





10     realistically?





11                  HEARING OFFICER BOYNTON: A  couple





12     years at least before we Clean up that.  And then





13     we believe that if we carry out this proposed





14     plan, according to the way we  estimate it,  that  we





15     would not have to come treat the groundwater. We





16     can naturally attenuate that over time.  So that





17     would mean we would still monitor the groundwater





18     to see what was there,  what was happening with it,





19     and we think it would probably be 30 or  40 years





20     before the groundwater would clean up.





21                  AUDIENCE PARTICIPANT:  So those cubic





22     yards  that you have  already treated at  that  point





23     in time should be able to be put back down?





24                 HEARING OFFICER BOYNTON: Those would
-------
 1     go back on the site.





 2                   So  that was  — basically,  I  just





 3     wanted to do that to  refresh everybody's memory of





 4     what the proposed plan  looked like,  and now we




 5     will get into the comments.





 6                   I would like to  also mention we have a





 7    couple of people here: Matt Leahy,  from Senator





 8     Judd Gregg's office in  New Hampshire;  and Donna




 9     Gamache from Senator  Smith's office  is also here.





10                   Hi,  Donna.





11                   Now,  for  people  that would like to get





12     on the record, if they  will  take the opportunity




13     to come up from General Electric.





14                  JILL SIEBELS: Good evening.  My name





15     is Jill Siebels,  S-I-E-B-E-L-S,  and  I  am the





16     Remedial Project  Manager from General  Electric.




17                   Thanks. I  am not used  to doing too





18     many things.





19                   I appreciate the opportunity tonight





20     to present our view regarding the  appropriate




21     remedy for the site,  but because this  is a





22     community meeting, I  am going to keep  this brief,





23     and just make a statement regarding  our efforts to





24     date.  GE is preparing detailed written comments
-------
 1     on the proposed remedy that we will submit to EPA





 2     before the end of the comment period.





 3                   First and  foremost, we are committed





 4     to identify a remedy  protective of  both human




 5     health and the environment. To that end, we are





 6     interested in evaluating Shell's in situ thermal





 7     technology for use at the site.  The development





 8     of the in situ technology is moving ahead  guickly,




 9     and that makes it sure to be the most  appropriate





10     remedy to be applied  at  this site.





11                   We  appreciate that the community  has





12     been dealing with this process for  guite a long




13     time now; and because of the development of the





14     ISTD,  which is in situ thermal desorption





15     technology,  because it's so close,  we  believe it





16     is in everyone's  best interest to think about




17     the evaluation for technology before a remedy





18     is selected at the site.





19                   As  I  said,  we recognize  that  this is





20     your meeting,  and we  want to make sure that




21     everyone has the  chance  to provide  comments or ask





22     guestions of the  EPA. However,  we are  more than





23     willing to share  -- sorry.  We are more than





24     willing to share  our  thoughts with  the community
-------
 1     once we have completed our evaluation;  and to that





 2     end,  anyone who is interested in obtaining





 3     additional information can come up to me with your





 4     name and address,  or we will have a sign-up sheet





 5     that we can put over on the table,  and  we are





 6     still in the of process of putting together written





 7     comments,  but we will share them with anyone who





 8     is interested,  or sit down with you if  you are





 9     interested in that.





10                   Thank  you.





11                   HEARING OFFICER BOYNTON:  Thank you,





12     Jill.





13                   Now, Jack Hirsch from Shell  Oil





14     Company.   Jack.





15                   JACK HIRSCH:  Good evening. My name





16     is Jack Hirsch — that is H-I-R-S-C-H — and I am





17     an employee of Shell Oil Company,  which is the





18     inventor of the technology, and also Shell is the





19     owner of its subsidiary, TerraTherm, which is





20     offering this service of the in situ thermal





21     desorption technology.





22                   I appreciate  the opportunity to  be





23     here tonight. I wanted to perhaps clarify some of





24     the questions that we believe were raised at the
-------
 1     meeting on the 14th of January.





 2                   And  the  first question is: Where are





 3     we in terms of development of the technology?





 4                   And  several  things  have happened since




 5     the last time we met with you,  and among them we





 6     had essentially completed the project  that we were





 7     doing at our test  facility in Houston,  Texas, and





 8     we thank the town  and the state for sending




 9     representatives down to observe the operation down





10     there,  and also where we shared the results with





11     you.  We are still  finalizing  the results from





12     that work; and when it's complete,  we  will be




13     sharing that with  you up here.





14                   In addition, the  in situ  thermal





15     desorption technology is being commercially





16     applied full-scale in Portland,  Indiana. That is




17     a 150-well project that is ongoing as  we speak.





18     We are currently in the final heating  stages of





19     that project. That is a contaminate of PCE at a





20     depth of about 20  feet.




21                   TerraTherm is also  developing





22     proposals for full-scale site remediations for





23     numerous sites nationally. The technology,  while





24     still being tested to provide performance and
-------
 1     refinements   and  other  cost  data  to  allow us  to





 2     make the commercial application as efficient





 3     as possible,  we assure you the testing is not





 4     delaying its  use in the  environmental




 5     marketplace.





 6                   There were some guestions,  I believe,





 7     concerning the technology and how it's -- where





 8     it's been used for PCBs, polychlorinated




 9     biphenyls.     The  in  situ thermal  desorption





10     technology was successfully demonstrated on  PCBs





11     at the Glens  Falls Dragstrip site, that is a





12     New York State Super Fund site,  in 1996.




13                   It's   currently mobilizing the





14     eguipment to  the Missouri Electric Works, which is





15     an NPL listed Super Fund site in Cape Girardeau,





16     Missouri,  where we will  be doing a demonstration




17     test,  which we will complete by the end of March,





18     this year.     The  eguipment we are already mobilizing





19     on the site as we speak. We will have the





20     full-scale eguipment on  the site February 10th,




21     and the contaminant treatment process, the same





22     for both the  thermal wells and thermal blankets,





23     demonstrated  more than six 9's destruction





24     efficiency for polychlorinated biphenyls.
-------
 1            The  owner  of  the  Missouri  Electric





 2     Works site  has made  the  site available for people





 3     that might  want to come  tour the  site during our





 4     operation.  We will be letting you know when that




 5     would be convenient; and perhaps  again,  like you





 6     did in Houston,  you can  come join us there to see





 7     what is going on.





 8                   Another guestion that  was  raised




 9     were byproducts of incomplete combustion of





10     polychlorinated biphenyls,  such  as dioxins.





11     Would they  be produced by this technology?





12                   In  situ thermal desorption is




13     different from incineration in a  very fundamental





14     way. During incineration,  products of incomplete





15     combustion  may be formed when portions of  the





16     contaminants pass through low temperature  regions




17     toward the  base of the flame. With in situ





18     thermal desorption,  however,  the  contaminants are





19     desorbed within the  soil and are  transported





20     through a uniformly high temperature region




21     surrounding the heating  elements.  At the





22     temperatures used in the in situ  thermal





23     desorption  process,  the  destruction rate of any





24     byproducts  is greater than the rate at which they
-------
 1     are formed,  and the majority,      about 99 percent of





 2     the contaminants and byproducts,  are destroyed





 3     within the soil themselves.  So not only is it in





 4     situ thermal desorption,  but it's also in situ




 5     thermal destruction.





 6                  Any residual contaminants or





 7     byproducts,  as they exist in the  vapor phase, are





 8     drawn  through the  vacuum extraction system to the




 9     flameless thermal oxidizer where  the destruction





10     process is completed. Because of  the uniform high





11     temperature   profiles both  surrounding the heating





12     elements in the soil, and contained within the




13     thermal oxidizer,    all  of  the desorbed vapors  are





14     exposed to the same high temperatures for nearly





15     instantaneous destruction of contaminants, with





16     minimal formation of byproducts.




17                          The  process  was  tested at the New York





18     site and showed better than six 9's of destruction





19     efficiency,  for not only the contaminant PCB, but





20     also any byproducts that might have been formed.




21                        Finally,  I  believe there was  a





22     guestion as to whether the technology might fit on





23     a small site, and also the social impact of it,





24     noise and such. The in situ thermal desorption
-------
 1     technology is very quiet,  produces no odors or





 2     dust,  and that is the in situ process.  The small





 3     demonstration unit itself is self-contained on a





 4     single tractor trailer,  so a single,  40-foot-long





 5     trailer contains all the equipment.       The





 6    full-scale unit is complete on three tractor





 7     trailer beds, taking up  approximately a tenth of





 8     an acre of space.





 9                   This  concludes  the  questions  which I





10    feel were raised. If there are more,  then we will





11     hang around afterwards to answer  them,  and I





12     appreciate the opportunity.





13                 Thank you.





14                   HEARING OFFICER BOYNTON:  Thank you,





15     Jack.





16                   EDWARD FRANKAVITZ:  My name  is Edward





17     Frankavitz.    I  own Milford  Consignment outlet,  and





18     I really had more questions  at this  point in





19     time.





20                   And one being,  I  notice  some





21     contaminants run all the way from Mill Street to





22     Elm Street,    and yet nothing is  being  done





23     throughout that entire region in  there.





24                  Why is that?
-------
 1                  HEARING OFFICER BOYNTON: Tonight's





 2     hearing is to receive  comments.  We will  respond





 3     to the comments and questions  in our





 4     responsiveness  summary.  So if  you wanted to make





 5     comments now,  for the  record,  do that,  and I will





 6     close the hearing,  and I will  talk to you about --





 7                  EDWARD FRANKAVITZ:  Primarily,  I





 8     needed answers  to the  questions  so I could have my





 9     comments. So possibly  I  will speak later.





10                  HEARING OFFICER BOYNTON: We  will  talk





11     after the hearing.





12                  Is  there anyone else that  would like





13     to make a comment for  the record?





14                  Then  I will  close  the hearing. This





15     hearing is closed.





16





17                  (There was  a discussion off the





18     record. )





19





20





21





22





23





24
-------
 1           HANDWRITTEN SPEECH PREPARED BY JUSTIN DANHOF:





 2





 3                  Hi. My name  is  Justin  Danhof.  I am





 4     an 8th grade student here in town.





 5                  For the  last couple of months, we have





 6     been studying the different  sites and the reason





 7     for worry.  I think  that we all agree that there





 8     is a problem,  and that is why we are all gathered





 9     here tonight.  Now that we have decided to clean





10     up the sites,  some  guestions come to mind.





11                  How much of  the soil do  we clean up?





12     I'm not stupid.  I  realize that the  EPA,  in the





13     end,  is going to do what they want  to do. I would





14     just like the EPA to keep the best  interest of us,





15     the citizens of  Milford,  in  mind when they do make





16     their decision.





17                  The problem that we are  faced with





18     here is a chronological problem,  so I  do not





19     believe that it  would  be in  our best interest to





20     just wait around for an    unstable idea that could





21     possibly pose a  risk to    us, the  citizens of





22     Milford.





23                  In conclusion,  I would just like to





24     wish the EPA good luck,  and  thank you for your
-------
 1     time.





 2





 3                   (Whereupon,  at  7:22  p.m.,  the  hearing





 4     was adjourned.)




 5





 6





 7
 9





10





11





12




13





14





15





16





17




18





19





20





21




22





23





24
-------
 1                        CERTIFICATION





 2





 3                         I, Marianne  Kusa-Ryll,  Registered





 4     Professional Reporter,  do hereby certify that the





 5     foregoing,  transcript,  Volume I, is a true and





 6     accurate transcription of my stenographic notes





 7     taken on Wednesday,  January 29,  1997.





 8





 9





10                                                      





11





12





13





14





15





16





17





18





19





20





21





22





23





24
-------
                                     APPENDIX C

                             ADMINISTRATIVE RECORD INDEX             10/09/98
                               FIiETCHER'S PAINT WORKS             Page     1
                                 All Operable Units

01.03  SITE ASSESSMENT - SITE INSPECTION/INVESTIGATION

       Title:      Potential Hazardous Waste Site, Site Inspection Report, Fletcher's Paint Works.  [Elm
                   Street Site]
       Addressee:  DONALD SMITH - U.S. EPA REGION I
       Authors:     JOHN A. GOLDEN, JR - NUS CORPORATION
       Date:       April 15, 1986
       Format:      FORM                         No. Pgs:   17
       AR No.      01.03.1                      Document No.  000002

       Title:      Fletcher's Paint Works Final Site Inspection Report.  [Elm Street Site]
       Addressee:  DONALD SMITH - U.S. EPA REGION I
       Authors:     JOHN A. GOLDEN, JR - NUS CORPORATION
       Date:       September 5,  1986
       Format:      REPORT, STUDY                No. Pgs:   24
       AR No.      01.03.2                      Document No.  000001

       Title:      Potential Hazardous Waste Site, Site Inspection Report, Fletcher's Paint Storage
                   Facility. [Mill Street Site)
       Addressee:  DAVID NEWTON - U.S. EPA REGION I
       Authors:     JAMES S. YOUNG - NUS CORPORATION
       Date:       December 30,  1986
       Format:      FORM                         No. Pgs:   14
       AR No.      01.03.3                      Document No.  000003

       Title:      Final Site Inspection, Fletcher's Paint Storage Facility. [Mill Street Site]
       Addressee:  U.S. EPA REGION I
       Authors:     JAMES S. YOUNG - NUS CORPORATION
       Date:       January 6, 1987
       Format:      REPORT, STUDY                No. Pgs:   15
       AR No.      01.03.4                      Document No.  000004

01.05  SITE ASSESSMENT - CORRESPONDENCE RELATED TO SITE ASSESSMENT

       Title:       Letter from Edward J. Schmidt, NHDES, to Lee Mayhew, Town of Milford Administrator,
                    (July 12, 1993). Concerned status of two facilities.
       Addressee:   LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
       Authors:      EDWARD J SCHMIDT - N.H. DEPT. OF ENVIRONMENTAL
                    SERVICES
       Date:        July 12, 1993
       Format:       LETTER                      No. Pgs:   2
       AR No.       01.05.1                     Document No.  000226

01.06  SITE ASSESSMENT - HAZARD RANKING SYSTEM PACKAGES

       Title:       Attachments I-VIII Draft Sampling Task/Summary Report, Fletcher's Paint Works.  [Vol.
                    2 of the H.R.S. Package] [Available in Records Center]
       Addressee:   U.S. EPA REGION I
       Authors:      NUS CORPORATION
       Date:
       Format:       REPORT, STUDY               No. Pgs:   187
       AR No.       01.06.1                     Document No.  000006

       Title:       National Priorities List Superfund Hazardous Waste Site Listed Under CERCLA as
                    Amended in 1986: Fletcher's Paint Works Plant and Storage.
       Date:        1986
       Format:       FACT SHEET,  PRESS RELEASE   No. Pgs:   1
       AR No.       01.06.2                     Document No.  000025
-------
       Title:       Hazard Ranking System Package, Fletcher's Paint Works and Storage Facility, Milford,
                    New Hampshire. [Vol. 1]  [Available in Records Center]
       Addressee:   U.S. EPA REGION I
       Authors:      NUS CORPORATION
       Date:        January 25, 1988
       Format:       REPORT, STUDY               No. Pgs:   179
       AR No.       01.06.3                     Document No.  000005

02.01  REMOVAL RESPONSE - CORRESPONDENCE

       Title:       Concurrence on June 22,  1993, Action Memorandum to Fund SACM Early Removal Action.
       Addressee:   JANIS K. TSANG - U.S. EPA REGION I/ESD
       Authors:      PHILIP J. O'BRIEN - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        August 13, 1993
       Format:       LETTER                      No. Pgs:   2
       AR No.       02.01.1                     Document No.  000007
       Title:       Letter from Charles Berube, NHDES, to Jill Siebels, General Electric,
                    Encloses sampling & analysis data letter report.
       Addressee:   JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Authors:      CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        July 3, 1996
       Format:       LETTER                      No. Pgs:  1
       AR No.       02.01.2                     Document No.  000242
         *Attached to Document No. 000241 In 02.03
                                                                        (July  3,  1996)
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
 Letter from Cheryl Sprague, US EPA RI, to Jill Siebels, General Electric,  (August  6,
 1996).  EPA Comments on voluntary soil removal work plan by ESE.
 JILL SIEBELS - GENERAL ELECTRIC COMPANY
 CHERYL L. SPRAGUE - U.S. EPA REGION I
 August 6, 1996
 LETTER                      No. Pgs:  4
                    02.01.3
                                                Document No.  000247
       Title:      Letter from Charles Berube, NHDES, to Jill Siebels, General Electric,  (August 7,
                   1996). Comments regarding GE's voluntary soil removal work plan.
       Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Authors:     CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:       August 7, 1996
       Format:      LETTER                       No. Pgs:  1
       AR No.      02.01.4                      Document No.  000240
         *Attached to Document No. 000239 In 02.06

       Title:      Letter from A. Lee Gustafson,  Environmental Science & Engineering, Inc. to Cheryl
                   Sprague,  US EPA RI,  (August 9, 1996). Response to EPA comments.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     A. LEE GUSTAFSON
       Date:       August 9, 1996
       Format:      LETTER                       No. Pgs:  1
       AR No.      02.01.5                      Document No.  000234
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Facsimile from A. Lee Gustafson, ESE, to Cheryl Sprague, US EPA RI,
Fax of comments which followed by mail.
CHERYL L. SPRAGUE - U.S. EPA REGION I
A. LEE GUSTAFSON
August 9, 1996
CORRESPONDENCE               No. Pgs:  1
(August  9,  1996)
                   02.01.6
                                                Document No.  000236
         *Attached to Document No. 000234 In 02.01
       Title:      Letter from A. Lee Gustafson, ESE, to Cheryl Sprague, Charles Berube, Lee Mayhew,
                   (August 12, 1996) .  Revised work plan enclosed.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     A. LEE GUSTAFSON
       Date:       August 12, 1996
       Format:      LETTER                       No. Pgs:  2
       AR No.      02.01.7                      Document No.  000237
-------
       Title:      Letter from Lee Mayhew, Town of Milford Administrator, to Jill Siebels, General
                   Electric, (September 6, 1996) .  Korean War Memorial removal.
       Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Authors:     LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
       Date:       September 6, 1996
       Format:      LETTER                       No. Pgs:  1
       AR No.      02.01.8                      Document No.  000233

       Title:      Facsimile from Jill Siebels, General Electric, to Cheryl Sprague, US EPA RI,
                   (September 27, 1996) .  Draft completion work report, Korean War Memorial.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Date:       September 27, 1996
       Format:      CORRESPONDENCE               No. Pgs:  1
       AR No.      02.01.9                      Document No.  000231

02.02  REMOVAL RESPONSE - REMOVAL RESPONSE REPORTS

       Title:      Site Assessment,  Fletcher's Paint Works, Milford, New Hampshire.  [Elm Street and Mill
                   Street]  [original Photos Available in Records Center]
       Addressee:  U.S. EPA REGION I
       Authors:     ROY F. WESTON, INC.
       Date:       November 23, 1987
       Format:      REPORT, STUDY                No. Pgs:  44
       AR No.      02.02.1                      Document No.  000008

       Title:      Fletcher's Paint Facility Drum Inventory and Sampling. [Original  Photographs Available
                   in Records Center]
       Addressee:  U.S. EPA REGION I
       Authors:     ROY F. WESTON, INC.
       Date:       December 10, 1987
       Format:      REPORT, STUDY                No. Pgs:  40
       AR No.      02.02.2                      Document No.  000009

       Title:      Removal Program Preliminary Assessment/Site Investigation for Fletcher's Paint Works
                   Site, Elm Street.
       Addressee:  U.S. EPA REGION I
       Authors:     ROY F. WESTON, INC.
       Date:       August 1991
       Format:      REPORT, STUDY                No. Pgs:  41
       AR No.      02.02.3                      Document No.  000010

       Title:      Removal Program Preliminary Assessment/Site Investigation for Fletcher's Paint Works
                   Site, Mill Street, Milford, NH.
       Addressee:  U.S. EPA REGION I/BSD
       Authors:     ROY F. WESTON, INC.
       Date:       August 1991
       Format:      REPORT, STUDY                No. Pgs:  48
       AR No.      02.02.4                      Document No.  000026

       Title:      Addendum to Removal Program Preliminary  Assessment/Site Investigation for Fletcher's
                   Paint Works Site  (Mill Street).
       Addressee:  U.S. EPA REGION I/BSD
       Authors:     ROY F. WESTON, INC.
       Date:       June 1992
       Format:      REPORT, STUDY                No. Pgs:  62
       AR No.      02.02.5                      Document No.  000029
       Title:      Chronological Summary of Site Visit Conducted April 20, 1993, by Joseph A. Resca, Roy
                   F. Weston, Inc., (April 27, 1993).
       Addressee:  FILE
       Authors:     JOSEPH A. RESCA - ROY F. WESTON, INC.
       Date:       April 27, 1993
       Format:      REPORT, STUDY                No. Pgs:  42
       AR No.      02.02.6                      Document No.  000245
-------
       Title:      Indoor Dust Survey Sampling Quality Assurance/Quality Control Plan.
       Addressee:  U.S. EPA REGION I/BSD
       Authors:     ROY F. WESTON, INC.
       Date:       October 1994
       Format:      REPORT, STUDY                No. Pgs:   32
       AR No.      02.02.7                      Document No.  000030
       Title:      Chronological Summary for the Fletcher's Paint  (Mill Street) Site, July 28,
                   through September 11, 1995.
       Authors:     ROY F. WESTON, INC.
       Date:       October 1995
       Format:      REPORT, STUDY                No. Pgs:  132
       AR No.      02.02.8                      Document No.  000244
1995
02.03  REMOVAL RESPONSE - SAMPLING & ANALYSIS DATA

       Title:      Letter Report from Charles Berube, NHDES, to Rosario Ricciardi, Milford Board of
                   Selectmen,  (June 21, 1996) .  Sampling results.
       Addressee:  ROSARIO RICCIARDI - MILFORD BOARD OF SELECTMEN
       Authors:    CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:       June 21,  1996
       Format:     REPORT, STUDY                No. Pgs:  2
       AR No.      02.03.1                      Document No.  000241

02.04  REMOVAL RESPONSE - POLLUTION REPORTS

       Title:      POLREP 1,  Fletcher Paint-Elm Street
       Authors:    AMYJEAN STRUNK - U.S. EPA REGION I/ESD
       Date:       November 18,  1991
       Format:     REPORT, STUDY                No. Pgs:  2
       AR No.      02.04.1                      Document No. 000083

       Title:      POLREP 2 and Final, Fletcher Paint-Elm Street.
       Authors:    AMYJEAN LUSSIER - U.S. EPA REGION I/ESD
       Date:       January 28,  1992
       Format:     REPORT, STUDY                No. Pgs:  2
       AR No.      02.04.2                      Document No. 000084

       Title:      POLREP #1 - Removal Action, Elm Street and Mill Street.
       Authors:    JANIS K.  TSANG - U.S. EPA REGION I/ESD
       Date:       August 2,  1993
       Format:     REPORT, STUDY                No. Pgs:  5
       AR No.      02.04.3                      Document No.  000011

       Title:      POLREP #2 - Removal Action, Elm Street and Mill Street.
       Authors:    JANIS K.  TSANG - U.S. EPA REGION I/ESD
       Date:       August 17, 1993
       Format:     REPORT, STUDY                No. Pgs:  3
       AR No.      02.04.4                      Document No.  000012

       Title:      POLREP #3 - Removal Action, Elm Street and Mill Street.
       Authors:    JANIS K.  TSANG - U.S. EPA REGION I/ESD
       Date:       September 27,  1993
       Format:     REPORT, STUDY                No. Pgs:  3
       AR No.      02.04.5                      Document No.  000013

       Title:      POLREP #4 - Removal Action, Elm Street and Mill Street.
       Authors:    JANIS K.  TSANG - U.S. EPA REGION I/ESD
       Date:       November 11,  1993
       Format:     REPORT, STUDY                No. Pgs:  3
       AR No.      02.04.6                      Document No.  000014
       Title:      POLREP #5 - Removal Action, Elm Street.
       Authors:     JANIS K. TSANG - U.S. EPA REGION I/ESD
       Date:       January 4, 1994
       Format:      REPORT, STUDY                No. Pgs:  2
       AR No.      02.04.7                      Document No.  000015
-------
       Title:      POLREP #7 - Removal Action, Elm Street.
       Authors:     JANIS K. TSANG - U.S. EPA REGION I/ESD
       Date:       June 25, 1994
       Format:      REPORT,  STUDY                No. Pgs:   2
       AR No.      02.04.8                       Document No.  000016

02.05  REMOVAL RESPONSE - ON-SCENE COORDINATOR REPORTS

       Title:      Draft Completion of Work Report Korean War Memorial Removal Action Fletcher's Paint
                   Works Superfund Site.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:       September 1996
       Format:      REPORT,  STUDY                No. Pgs:  11
       AR No.      02.05.1                       Document No.  000232
         *Attached to Document No. 000231 In 02.01

02.06  REMOVAL RESPONSE - WORK PLANS AND PROGRESS REPORTS

       Title:      Letter Report from A. Lee Gustafson, Environmental Science & Engineering, Inc., to
                   Janis Tsang, US EPA RI,  (August 28, 1995).  Progress Report.
       Addressee:  JANIS K. TSANG - U.S. EPA REGION I
       Authors:     A. LEE GUSTAFSON
       Date:       August 28,  1995
       Format:      REPORT,  STUDY                No. Pgs:   1
       AR No.      02.06.1                       Document NO.  000243

       Title:      Letter from Jill Siebels, General Electric, to Cheryl Sprague, Charles Berube, Lee
                   Mayhew,   (July 25, 1996). Encloses War Memorial Removal Action Work
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Date:       July 25, 1996
       Format:      LETTER                       No. Pgs:   2
       AR No.      02.06.2                       Document No.  000249
       Title:

       Addressee:
       Date:
       Format:
       AR No.
War Memorial Removal Action Work Plan,
25, 1996).
CHERYL L. SPRAGUE - U.S. EPA REGION I
July 25, 1996
WORK PLAN                    No. Pgs:
Fletcher's Paint Works Superfund Site, (July
10
                   02.06.3
         *Attached to Document No.
                                                Document No.
                                   000249 In 02.06
                                                              000250
       Title:      Facsimile from Charles Berube, NHDES, to Cheryl Sprague, US EPA RI, (August 7, 1996)
                   Encloses comments on War Memorial Removal.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL
                   SERVICES
       Date:       August 7, 1996
       Format:      CORRESPONDENCE               No. Pgs:  1
       AR No.      02.06.4                      Document No.  000239
       Title:      Response to EPA Comments regarding Korean War Memorial Voluntary Soil Removal Work
                   Plan,  prepared by ESE
                                                              000235
Addressee:
Authors :
Date:
Format :
AR No.
*Attached
Title:
Addressee:
Authors :
Date:
Format :
AR No.
CHERYL L. SPRAGUE - U.S. EPA
A. LEE GUSTAFSON
August 9, 1996
REPORT, STUDY
02.06.5
to Document No. 000234 In 02.
REGION I


No. Pgs:
Document
,01



53
No.

War Memorial Removal Action Work Plan.
CHERYL L. SPRAGUE - U.S. EPA
A. LEE GUSTAFSON
August 12, 1996
WORK PLAN
02.06.6
REGION I


No. Pgs:
Document



12
No.
                                                              000238
         *Attached to Document No. 000237 In 02.01
-------
02.09  REMOVAL RESPONSE - ACTION MEMORANDA

       Title:      Fletcher's Paint Works (Elm St.), Removal Site Administrative Record: Index
       Authors:    U.S. EPA REGION I
       Date:        May 9, 1989
       Format:     MISCELLANEOUS                No. Pgs:  6
       AR No.      02.09.1                      Document No. 000019
       Title:      Fletcher's Paint Works
       Authors:     U.S. EPA REGION I
       Date:        May 9,  1989
       Format:      MISCELLANEOUS
       AR No.      02.09.2
                        (Mill St.) Removal Site Administrative Record: Index.
                             No. Pgs:  6
                             Document No.
                                                              000020
       Title:      Fletcher's Paint Works Elm Street Site Administrative Record:
       Addressee:   U.S. EPA REGION I
       Authors:     ROY F. WESTON, INC.
       Date:        November 19,  1991
       Format:      MISCELLANEOUS                No. Pgs:  4
       AR No.      02.09.3                      Document No.  000022
                                                              Index.
       Title:      Fletcher Paint Superfund Site, Removal Action III, Administrative Record File and
                   Index.
       Addressee:   U.S. EPA REGION I/BSD
       Authors:     ROY F. WESTON, INC.
       Date:        July 27, 1993
       Format:      MISCELLANEOUS                No. Pgs:  174
       AR No.      02.09.4                      Document No.  000033

       Title:      Fletcher's Paint Works and Storage Facility Superfund Site Removal Action IV
                   Administrative Record File.
       Addressee:   U.S. EPA REGION I/BSD
       Authors:     ROY F. WESTON, INC.
       Date:        September 1995
       Format:      MISCELLANEOUS                No. Pgs:  402
       AR No.      02.09.5                      Document No.  000032

02.15  REMOVAL RESPONSE - REMOVAL RESPONSE SUBCONTRACTOR DOCUMENTS

       Title:      HASP Approval form from Environmental Science & Engineering, Inc., signed November 17
                   and November 18, 1994.
       Date:        November 17, 1994
       Format:      REPORT, STUDY                No. Pgs:  19
       AR No.      02.15.1                      Document No.  000248

03.01  REMEDIAL INVESTIGATION - CORRESPONDENCE

       Title:      Reguest for Review of Wood Coring Sampling  Results.
       Addressee:   AMYJEAN LUSSIER - U.S. EPA REGION I/ESD
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        August 6, 1992
       Format:      MEMORANDUM                   No. Pgs:  3
       AR No.      03.01.1                      Document No.  000034
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Letter from Cheryl Sprague, US EPA RI, to Robert Courage, Milford Town Dept. of Public
Works, (November 18, 1993). Concerned water line-Keyes Well.
ROBERT COURAGE - TOWN OF MILFORD
CHERYL L. SPRAGUE - U.S. EPA REGION I
November 18, 1993
                                       2
LETTER
03.01.2
No. Pgs:
Document No.  000227
-------
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Notification of Evidence of Groundwater Contamination Apparently Emanating from the
Citgo Station Area.
KENYON OIL COMPANY
DANIEL COUGHLIN - U.S. EPA REGION I
January 25, 1994
LETTER
                   03.01.3
                             No. Pgs:  2
                             Document No.  000040
       Title:       Letter from Kenneth Finkelstein, NOAA, to Cheryl Sprague, US EPA RI,
                   Concerning ecological risk assessment NOAA; PCB impact on fish
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     KENNETH FINKELSTEIN
       Date:        May 24, 1994
       Format:      LETTER                       No. Pgs:  3
       AR No.       03.01.4                      Document No.  000230
                                                                      (May 24, 1994) .
       Title:       Transmittal of the Preliminary Ecological Assessment and the Phase IB, Remedial
                   Investigation Workplan.
       Addressee:   THERESA BURKE - BINGHAM, DANA AND GOULD
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        June 6,  1994
       Format:      LETTER                       No. Pgs:  1
       AR No.       03.01.5                       Document No.  000036
       Title:       Letter from William J. Miller, ERM-Northeast, to Cheryl Sprague, US EPA RI,
                   14,  1994)  Review of Remedial Investigation for GE.
       Addressee:   CHERYL L.  SPRAGUE - U.S. EPA REGION I
       Authors:     WILLIAM J MILLER
       Date:        September 14,  1994
       Format:      LETTER                       No. Pgs:  7
       AR No.       03.01.6                      Document No.  000210
                                                                             (September
       Title:       Letter from Lee Mayhew,  Milford Town Administrator, to Cheryl Sprague, US EPA RI,  (May
                   1,  1995). Risk Assessment exposure scenario.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
       Date:        May 1, 1995
       Format:      LETTER                       No. Pgs:  2
       AR No.       03.01.7                      Document No.  000211

03.02  REMEDIAL INVESTIGATION - SAMPLING & ANALYSIS DATA

       Title:       Sampling & Analysis Data: Availability for Review
       Format:                                   No. Pgs:  1
       AR No.       03.02.1                      Document No.  000261

       Title:       Polychlorinated Biphenyl Analysis in Transformer Fluid and Waste Oils - Fletcher's
                   Paint Works.
       Addressee:   MARY ELLEN STANTON - U.S. EPA REGION I/BSD
       Authors:     ELAYNE LEE, DEBORAH THIEM, RICHARD SISCANAW - U.S. EPA REGION I/ESD
       Date:        August 2, 1991
       Format:      SAMPLING AND ANALYSIS DAT    No. Pgs:  2
       AR No.       03.02.2                      Document No.  000088
         *Attached to Document No. 000086 In 03.02
       Title:       Analysis of Sample Numbers 85504 and 85506.
       Addressee:   MARY ELLEN STANTON - U.S. EPA REGION I/ESD
       Authors:     STEVEN HELLER - U.S. EPA REGION I/ESD
       Date:        August 16, 1991
       Format:      SAMPLING AND ANALYSIS DAT    No. Pgs:  8
       AR No.       03.02.3                      Document No.  000087
         *Attached to Document No. 000086 In 03.02
-------
Title:      Transmittal of Analytical Results for Samples Collected on July 30, 1991.
Addressee:  MARY FLETCHER
Authors:    AMYJEAN STRUNK - U.S. EPA REGION I/ESD
Date:       September 10, 1991
Format:     LETTER                       No. Pgs:  1
AR No.      03.02.4                      Document No.  000086

Title:      Field Sampling Plan for Remedial Planning Activities at the Fletcher's Paint Site
            Milford, NH, Phase IA, Revision No.  1.
Addressee:  U.S. EPA REGION I
Authors:    ARTHUR D. LITTLE, INC.
Date:       October 25, 1991
Format:     REPORT, STUDY                No. Pgs:  246
AR No.      03.02.5                      Document No.  000017

Title:      Report to Residents on Soil Samples  Taken from Drainage Ditch Adjacent to Their
            Property.
Addressee:
Authors :
Date:
Format :
AR No.
Title:
Addressee:
Authors :
Date:
Format :
AR No.
*Attached
Title:
Addressee:
Authors :
Date:
Format :
AR No.
ORSON H BRAGDON
CHERYL L. S PRAGUE - U.S
September 1, 1992

. EPA REGION I

SAMPLING AND ANALYSIS DAT No. Pgs:
03.02.6
Indoor Air and Soil Gas
U.S. EPA REGION I
U.S. EPA REGION I/ESD
October 1992
REPORT, STUDY
03.02.7
to Document No. 000090
Transmittal of report:
CHERYL L. S PRAGUE - U.S
PETER R KAHN - U.S. EPA
October 27, 1992
MEMORANDUM
03.02.8
Document



3
No. 000089
Survey - Results, Jacgues Elementary School.



No. Pgs:
Document
In 03.02
"Indoor Air and
. EPA REGION I
REGION I/ESD

No. Pgs:
Document



31
No. 000091

Soil Gas Survey - Results."



1
No. 000090
Title:      Letter Report from Charles Berube, NHDES, to Cheryl Sprague, US EPA RI,
            1992) Sampling Rounds October 20 through 21, 1992.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       November 9, 1992
Format:     REPORT, STUDY                No. Pgs:  44
AR No.      03.02.9                      Document No.  000224
(November  9,
Title:      Letter Report from Charles Berube, NHDES, to Cheryl Sprague, US EPA RI,  (July 21,
            1993). Results of October 20 through 21, 1992 sampling rounds.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       July 21, 1993
Format:     REPORT, STUDY                No. Pgs:  7
AR No.      03.02.10                     Document No.  000225
Title:      Letter Report from Charles Berube, NHDES, to Cheryl Sprague, US EPA RI,(August 30,
            1993) Results from August 3, 1993 sampling.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       August 30, 1993
Format:     SAMPLING AND ANALYSIS DAT    No. Pgs:  8
AR No.      03.02.11                     Document No.  000209
-------
       Title:       Field Sampling Plan for Remedial Planning Activities at the Fletcher's Paint Site
                   Milford,  NH,  Phase IB, Addendum No. 1.
       Addressee:   U.S.  EPA REGION I
       Authors:     ARTHUR D. LITTLE, INC.
       Date:        September 1,  1993
       Format:      REPORT,  STUDY                No. Pgs:   23
       AR No.       03.02.12                      Document No.  000018
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Field Sampling Plan for Remedial Planning Activities at the Fletcher's Paint Site,
Milford,  NH, Addendum No. 2.
U.S. EPA REGION I
ARTHUR D. LITTLE, INC.
October 21, 1994
REPORT, STUDY
03.02.13
No. Pgs:  17
Document No.
                                                              000229
       Title:       ChemServe Quality Assurance Quality Control Manual, Revision Date March 1996,
       Date:        March 1996
       Format:      REPORT,  STUDY                No. Pgs:  42
       AR No.       03.02.14                     Document No.  000246

03.04  REMEDIAL INVESTIGATION - INTERIM DELIVERABLES

       Title:       Site Management Plan for Remedial Planning at the Fletcher's Paint Site, Milford, NH.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:        August 20, 1991
       Format:      REPORT,  STUDY                No. Pgs:  17
       AR No.       03.04.1                      Document No.  000021

       Title:       Health and Safety Project Plan for RI/FS Phase IA Activities at the Fletcher's Paint
                   Site, Milford,  NH.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:        August 23, 1991
       Format:      REPORT,  STUDY                No. Pgs:  50
       AR No.       03.04.2                      Document No.  000023

       Title:       Quality Assurance Project Plan, RI/FS Phase IA for the Fletcher's Paint Site in
                   Milford, New Hampshire, Revision No. 1.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:        October 23,  1991
       Format:      REPORT,  STUDY                No. Pgs:  64
       AR No.       03.04.3                      Document No.  000027

       Title:       Health and Safety Project Plan, Addendum No. 1 for RI/FS Activities at the Fletcher's
                   Paint Site,  Milford, New Hampshire.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:        September 3, 1993
       Format:      REPORT,  STUDY                No. Pgs:  23
       AR No.       03.04.4                      Document No.  000024
       Title:

       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Quality Assurance Project Plan, RI/FS for the Fletcher's Paint Site in Milford, New
Hampshire, Addendum No. 1.
U.S. EPA REGION I
ARTHUR D. LITTLE, INC.
September 9, 1993
REPORT,
03.04.5
        STUDY
No. Pgs:  25
Document No.
                                                              000028
-------
03.06  REMEDIAL INVESTIGATION - REMEDIAL INVESTIGATION REPORTS

       Title:      Technical Memorandum for Fletcher's Paint Site,  Milford, NH, Phase 1A, Remedial
                   Investigation Rev. No. 1, Vol. 1, Sect. 1-3
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       August 1993
       Format:      REPORT, STUDY                No. Pgs:   184
       AR No.      03.06.1                      Document No.  000141

       Title:      Technical Memorandum for Fletcher's Paint Site, Milford, NH, Phase 1A, Remedial
                   Investigation, Rev. No. 1, Vol. II, Sect. 4 & 5.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       August 1993
       Format:      REPORT, STUDY                No. Pgs:   164
       AR No.      03.06.2                      Document No.  000142

       Title:      Technical Memorandum for Fletcher's Paint Site, Milford, NH, Phase 1A, Remedial
                   Investigation, Rev. No. 1, Vol. Ill, Appendices A-E.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       August 1993
       Format:      REPORT, STUDY                No. Pgs:   297
       AR No.      03.06.3                      Document No.  000143

       Title:      Technical Memorandum for Fletcher's Paint Site, Milford, NH, Phase 1A, Remedial
                   Investigation, Rev. No. 1, Vol. IV, Appendices F-J.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       August 1993
       Format:      REPORT, STUDY                No. Pgs:   349
       AR No.      03.06.4                      Document No.  000144

       Title:      Technical Memorandum for Fletcher's Paint Site, Milford, NH, Phase 1A, Remedial
                   Investigation, Rev. No. 1, Vol. V, Appendices K-P.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       August 1993
       Format:      REPORT, STUDY                No. Pgs:   162
       AR No.      03.06.5                      Document No.  000145

       Title:      Final Report for Preliminary Ecological Assessment at the Fletcher's Paint Site,
                   Milford,  NH, Phase IA, Technical Memorandum Supplement.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       March 15, 1994
       Format:      REPORT, STUDY                No. Pgs:   156
       AR No.      03.06.6                      Document No.  000031

       Title:      Final Remedial Investigation for Fletcher's Paint Site, Milford, NH, Revision No. 1,
                   Volume I, Sections 1-3.
       Addressee:   U.S. EPA REGION I
       Authors:    ARTHUR D. LITTLE, INC.
       Date:       July 1, 1994
       Format:      REPORT, STUDY                No. Pgs:   186
       AR No.      03.06.7                      Document No.  000079
       Title:      Final Remedial Investigation for Fletcher's Paint Site, Revision No. 1, Volume II,
                   Sections 4-7.
       Addressee:  U.S. EPA REGION I
       Authors:     ARTHUR D. LITTLE, INC.
       Date:       July 1, 1994
       Format:      REPORT, STUDY                                No. Pgs:  409
       AR No.      03.06.8                                      Document No.  000080
-------
        Title:       Final Remedial Investigation for Fletcher's Paint Site, Revision No. 1, Volume III
                    Appendices A-J.
        Addressee:  U.S. EPA REGION I
        Authors:     ARTHUR D. LITTLE, INC.
        Date:       July 1, 1994
        Format:      REPORT, STUDY                                No. Pgs:     865
        AR No.       03.06.9                                      Document No.  000081
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Final Remedial Investigation for Fletcher's Paint Site, Revision No. 1. Volume  IV,
Appendices K-0.
U.S. EPA REGION I
ARTHUR D. LITTLE, INC.
July 1, 1994
REPORT, STUDY                                No. Pgs:    294
                    03.06.10
                                                                 Document No.  000082
03.07
         REMEDIAL INVESTIGATION - WORK PLANS AND PROGRESS REPORTS
        Title:
        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Work Plan for RI/FS Activities at the Fletcher's Paint Site, Revision No. 1.
U.S. EPA REGION I
ARTHUR D. LITTLE, INC.
July 19, 1991
WORK PLAN
03.07.1
No. Pgs:
Document No.
184
000035
        Title:       Work Plan Amendment No. 2, Remedial Investigation/Feasibility Study Activities at the
                    Fletcher's Paint Site, Revision No. 1.
        Addressee:  U.S. EPA REGION I
        Authors:     ARTHUR D. LITTLE, INC.
        Date:       August 4, 1993
        Format:      REPORT, STUDY                                No. Pgs:      36
        AR No.       03.07.2                                      Document No.  000037
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Work Plan Amendment No. 4, Remedial Investigation/Feasibility Study Activities at the
Fletcher's Paint Site, Phase IB, Revision No. 1.
U.S. EPA REGION I
ARTHUR D. LITTLE, INC.
February 3, 1994
REPORT, STUDY
03.07.3
No. Pgs:
Document No.
39
000039
03.09
         REMEDIAL INVESTIGATION - HEALTH ASSESSMENTS
        Title:
        Authors:
        Date:
        Format:
        AR No.
ATSDR Report to Congress 1993, 1994, 1995
U.S. A.T.S.D.R.

REPORT, STUDY
03.09.1
No. Pgs:      2
Document No.  000259
        Title:       Preliminary Health Assessment for Fletcher's Paint Works and Storage Facility
                    Hazardous Waste Site.
        Addressee:  U.S. A.T.S.D.R.
        Authors:     N.H. BUREAU OF HEALTH RISK ASSESSMENT
        Date:       June 11, 1990
        Format:      REPORT, STUDY                                No. Pgs:      15
        AR No.       03.09.2                                      Document No.  000085
        Title:       Health Consultation: Fletcher's Paint Site  (CR# 10A2).
        Addressee:  TED BAZENAS - U.S. A.T.S.D.R.
        Authors:     KENNETH G. ORLOFF - U.S. A.T.S.D.R.
        Date:       July 10, 1992
        Format:      REPORT, STUDY                                No. Pgs:      5
        AR No.       03.09.3                                      Document No.  000092
-------
        Title:       ATSDR Record of Activity.
        Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
        Authors:     KENNETH G.  ORLOFF - U.S. A.T.S.D.R.
        Date:        August 28,  1992
        Format:      REPORT, STUDY
        AR No.       03.09.4
No. Pgs:      2
Document No.  000038
        Title:       Health Consultation: Evaluation of Chemical Contamination of Fish from the Souhegan
                    River Area of the Fletcher's Paint Storage Facility.
        Authors:     U.S.  A.T.S.D.R.
        Date:        December 10,  1997
        Format:      REPORT,  STUDY                                No. Pgs:      14
        AR No.       03.09.5                                       Document No.  000267

03.10   REMEDIAL INVESTIGATION - ENDANGERMENT/BASELINE RISK ASSESSMENTS

        Title:       Final Baseline Human Health Risk Assessment for Fletcher's Paint Site, Section 6 of
                    Remedial Investigation, Revision No. 1.
        Addressee:   U.S.  EPA REGION I
        Authors:     ARTHUR D. LITTLE, INC.
        Date:        July 1,  1994
        Format:      REPORT,  STUDY                                No. Pgs:      217
        AR No.       03.10.1                                       Document No.  000041

        Title:       Focused Feasibility Report.
        Addressee:   GENERAL ELECTRIC COMPANY
        Authors:     ENVIRONMENTAL SCIENCE & ENGINEERING, INC
        Date:        June 2,  1995
        Format:      REPORT,  STUDY
        AR No.       03.10.2
No. Pgs:      121
Document No.  000094
           *Attached to Document No. 000093 In 03.10
        Title:       Comments on the Baseline Risk Assessment.
        Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
        Authors:     COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
        Date:        June 6, 1995
        Format:      LETTER
        AR No.       03.10.3
No. Pgs:      1
Document No.  000093
04.01   FEASIBILITY STUDY - CORRESPONDENCE

        Title:       "ERACE--Electrical Remediation at Contaminated  Environments" by Pacific Northwest
                    Laboratory/Battelle Memorial Institute.
        Format:      MISCELLANEOUS                                No. Pgs:      3
        AR No.       04.01.1                                      Document No.  000132
           *Attached to Document No. 000129 In 04.01

        Title:       Environmental Remediation Services by Maxymillian Technologies
        Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
        Format:      MISCELLANEOUS                                No. Pgs:      15
        AR No.       04.01.2                                      Document No.  000139
           *Attached to Document No. 000173 In 04.01

        Title:       Off-Site Incineration, State of the Market, Presentation to the EPA by Rollins
                    Environmental Services, Date unknown.
        Format:      NOTES-MEETING                                No. Pgs:      32
        AR No.       04.01.3                                      Document No.  000156
        Title:       "Facts about In Situ Thermal Desorption Technology," Meeting Handout from Shell
                    Technologies.
        Format:      FACT SHEET,  PRESS RELEASE                    No. Pgs:      4
        AR No.       04.01.4                                      Document No.  000172
-------
Title:      "Cost Effective Solutions - Former Manufactured Gas Plant Remediation Services"
            Maxymillian Technologies brochure.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Format:     MISCELLANEOUS                                No. Pgs:       4
AR No.      04.01.5                                      Document No.  000222
    *Attached to Document No. 000221 In 04.01
Title:
Addressee:
Authors:
Date:
Format:
AR No.
General Electric's Work Plan for Gasmer Road Thermal Well Field Test, Houston, TX
CHERYL L. SPRAGUE - U.S. EPA REGION I
GENERAL ELECTRIC COMPANY
REPORT,  STUDY
04.01.6
No. Pgs:
Document No.
10
000199
    *Attached to Document No. 000198 In 04.01
Title:      U.S. PATENT No. 5,190,405, Vacuum Method for Removing Soil Contaminants Utilizing
            Thermal Conduction Heating
Date:       March 2, 1993
Format:     MISCELLANEOUS                                No. Pgs:      13
AR No.      04.01.7                                      Document No.  000201

Title:      Letter Report from David Major, Beak Consultants, "Soil Treatment Strategy for the
            Fletcher's Paint Site in Milford, NH."  (February 18, 1995).
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    DAVID W. MAJOR - BEAK CONSULTANTS LIMITED
Date:       February 28, 1994
Format:     REPORT, STUDY                                No. Pgs:      16
AR No.      04.01.8                                      Document No.  000161
    *Attached to Document No. 000160 In 04.01

Title:      Six-Phase Soil Heating Accelerates VOC Extraction from Clay Soil, Proceedings of
            Spectrum '94: International Nuclear and Hazardous Waste Management.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    J GAUGLITZ
Date:       August 14,  1994
Format:     MISCELLANEOUS                                No. Pgs:      9
AR No.      04.01.9                                      Document No.  000130
    *Attached to Document No. 000129 In 04.01

Title:      "Six-Phase Soil Heating for Enhanced Removal of Contaminants: Volatile Organic
            Compounds in Non-Arid Soils Integrated Demonstration, Savannah River"
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    J GAUGLITZ
Date:       October 1994
Format:     MISCELLANEOUS                                 No. Pgs:      65
AR No.      04.01.10                                      Document No.  000131
    *Attached to Document No. 000129 In 04.01
Title:      In Situ Vitrification Fact Sheet.
Authors:    GEOSAFE CORPORATION
Date:       November 1994
Format:     MISCELLANEOUS
AR No.      04.01.11
                                              No. Pgs:      4
                                              Document No.  000099
    *Attached to Document No. 000098 In 04.01
Title:      SITE Technology Capsule: Geosafe Corporation In Situ Vitrification Technology.
Authors:    U.S. ENVIRONMENTAL PROTECTION AGENCY
Date:       November 1994
Format:     MISCELLANEOUS                                 No. Pgs:      9
AR No.      04.01.12                                      Document No.  000101
    *Attached to Document No. 000098 In 04.01
-------
Title:      Large-Scale Commercial Applications of the In Situ Vitrification Remediation
            Technology.
Authors:    GEOSAFE CORPORATION
Date:       November 1994
Format:     MISCELLANEOUS                                 No. Pgs:      11
AR No.      04.01.13                                      Document No.  000102
    *Attached to Document No. 000098 In 04.01

Title:      Facsimile from Coleen Fuerst, General Electric, to Cheryl Sprague, U.S. EPA RI,
            (November 9, 1994). Outline of treatability plan, shipping sample.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       November 9, 1994
Format:     CORRESPONDENCE                                No. Pgs:      7
AR No.      04.01.14                                      Document No.  000157

Title:      State of New Hampshire Groundwater Sampling.
Addressee:  CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       November 16, 1994
Format:     LETTER                                       No. Pgs:      2
AR No.      04.01.15                                     Document No.  000095

Title:      Letter from Donald J. Coughlin, NH Superfund Section, to Coleen Fuerst, General
            Electric,  (November 29, 1994). Concerned FS alternatives.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    DANIEL COUGHLIN - U.S. EPA NEW ENGLAND
Date:       November 29, 1994
Format:     LETTER                                       No. Pgs:      3
AR No.      04.01.16                                     Document No.  000158
Title:      "Development of an Indirectly Heated Thermal Desorption System for PCB Contaminated
            Soil," Presented at the 1995 Superfund XVI Conference.
            CHERYL L. SPRAGUE - U.S. EPA REGION I
            ANTHONY PISANELLI, NEAL A. MAXYMILLIAN
            1995
            REPORT, STUDY                               No. Pgs:      16
            04.01.17                                    Document No.  000137
Addressee
Authors:
Date:
Format:
AR No.
   *Attached to Document No. 000173 In 04.01
Title:      "Indirect System Progress Photos" by Maxymillian Technologies
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       1995
Format:     PHOTO, MICROFORM, VIDEO                     No. Pgs:      18
AR No.      04.01.18                                    Document No.  000138
    *Attached to Document No. 000173 In 04.01

Title:      Letter from Mario Leclerc, Milford Wastewater Treatment Facility, to Michael Marando,
            ADL,  (not dated). Concerning groundwater.
Addressee:  MICHAEL A MARANDO - ARTHUR D. LITTLE, INC.
Authors:    MARIO LECLERK - MILFORD WASTEWATER TREATMENT
            FACILITY
Date:       1995
Format:     LETTER                                      No. Pgs:      1
AR No.      04.01.19                                    Document No.  000166
   *Attached to Document No. 000164 In 04.01
Title:      Letter from Michael A. Marando, ADL, to Mario Leclerk,
            Facility,  (January 17, 1995). Concerning groundwater.
Addressee:  MARIO LECLERK - MILFORD WASTEWATER TREATMENT FACILITY
Authors:    MICHAEL A MARANDO - ARTHUR D. LITTLE, INC.
Date:       January 17, 1995
Format:     LETTER                                  No. Pgs:
AR No.      04.01.20                                Document No.
    *Attached to Document No. 000164 In 04.01
                                                                   Milford Wastewater Treatment
                                                                  1
                                                                  000165
-------
Title:      Letter from Coleen Fuerst, General Electric, to Cheryl  Sprague, US EPA RI,  (February
            13, 1995). Concerning Feasibility Study alternatives.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       February 13, 1995
Format:     LETTER                                  No. Pgs:      3
AR No.      04.01.21                                Document No.  000159

Title:      Soil Treatment Strategy for the Fletcher's Paint Site in Milford, New  Hampshire.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    DAVID W. MAJOR - BEAK CONSULTANTS LIMITED
Date:       February 28, 1995
Format:     REPORT, STUDY                           No. Pgs:      16
AR No.      04.01.22                                Document No.  000097
   *Attached to Document No. 000096 In 04.01
Title:      Limited Soil Excavation and/or Treatment Approach.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       March 2, 1995
Format:     LETTER                                  No. Pgs:
AR No.      04.01.23                                Document No.
1
000096
Title:      Letter from Coleen Fuerst, General Electric, to Cheryl  Sprague, US EPA RI,  (March 2,
            1995).  Concerning limited soil excavation.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       March 2, 1995
Format:     LETTER                                  No. Pgs:      1
AR No.      04.01.24                                Document No.  000160

Title:      Memorandum from David Major, Beak Consultants, Ltd., to Coleen  Fuerst,  General
            Electric, (March 3, 1995). Concerning transport of PCB  in groundwater.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    DAVID W. MAJOR - BEAK CONSULTANTS LIMITED
Date:       March 3, 1995
Format:     CORRESPONDENCE                          No. Pgs:      3
AR No.      04.01.25                                Document No.  000163
    *Attached to, Document No. 000162 In 04.01

Title:      Letter from Coleen Fuerst, General Electric, to Cheryl  Sprague, US EPA RI,  (March 6,
            1995). Concerning transport of PCB in groundwater.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       March 6, 1995
Format:     LETTER                                  No. Pgs:      1
AR No.      04.01.26                                Document No.  000162

Title:      Facsimile from Ken Cahill, Arthur D. Little, Inc., to Cheryl  Sprague,  US  EPA RI,
            (March 10, 1995). Concerning Milford POTW groundwater assessment.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    KEN CAHILL - ARTHUR D. LITTLE, INC.
Date:       March 10, 1995
Format:     CORRESPONDENCE                         No. Pgs:      1
AR No.      04.01.27                               Document No.  000164
Title:      Letter from George Kingsley, CF Systems, to Cheryl Sprague, US EPA RI,
            1995). Concerns treatability study.  (Study is Confidential.)
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION  I
Authors:    GEORGE KINGSLEY
Date:       March 16, 1995
Format:     LETTER                                 No. Pgs:       1
AR No.      04.01.28                               Document No.   000168
                 (March 16,
-------
Title:      Letter from Lee F. Mayhew, Town of Milford Administrator, to Cheryl Sprague, US  EPA
            RI,  (March 20, 1995). Concerning Feasibility Study.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Date:       March 20, 1995
Format:     LETTER                                 No. Pgs:      1
AR No.      04.01.29                               Document No.  000167

Title:      Letter from Lee F. Mayhew, to Cheryl Sprague, US EPA RI,  (March 28, 1995). Concerning
            Feasibility Study.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Date:       March 28, 1995
Format:     LETTER                                 No. Pgs:      1
AR No.      04.01.30                               Document No.  000170
Title:      Letter from Cheryl Sprague, US EPA RI, to Coleen Fuerst, General Electric,
            1995). Concerning proposed technology update meeting.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       April 2, 1995
Format:     LETTER                                 No. Pgs:      1
AR No.      04.01.31                               Document No.  000171
                                       (April 2,
Title:      Letter Commenting on the Remedial Approach Outlined in April  12, 1995 Letter  to
            Cheryl Sprague.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    JOHN REGAN - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       May 3, 1995
Format:     LETTER                                No. Pgs:      5
AR No.      04.01.32                              Document No.  000263

Title:      Letter from James H. Maxymillian, Maxymillian Technologies, to Cheryl Sprague, US EPA
            RI, (August 22, 1995). Concerns thermal systems.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    JAMES H. MAXYMILLIAN
Date:       August 22, 1995
Format:     LETTER                                No. Pgs:      1
AR No.      04.01.33                              Document No.  000173

Title:      "Thermal Blanket For In-Situ Remediation of Surficial Contamination: A  Pilot  Test,"
            Pre-print of article submitted to Environ. Science & Tech. 8/30/95
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    I.E.T. IBEN - GENERAL ELECTRIC COMPANY
Date:       August 30, 1995
Format:     REPORT, STUDY                        No. Pgs:      27
AR No.      04.01.34                             Document No.  000200

Title:      In Situ Vitrification Technology Update.
Authors:    GEOSAFE CORPORATION
Date:       November 1995
Format:     MISCELLANEOUS                        No. Pgs:      6
AR No.      04.01.35                             Document No.  000100
    *Attached to Document No. 000098 In 04.01
Title:      Follow-up on Meeting of 10/30/95.
Addressee:  RUTH BLEYLER - U.S. EPA REGION I
Authors:    DALE M. TIMMONS - GEOSAFE CORPORATION
Date:       November 6, 1995
Format:      LETTER
AR No.      04.01.36
No. Pgs:      1
Document No.  000098
-------
Title:      Letter from A. Lee Gustafson & Dennis R. Sasseville, Environmental Science & Engr.,
            Inc. to  John M. Regan, NHDES,  (November 9, 1995).
Addressee:  N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       November 9, 1995
Format:     LETTER                              No. Pgs:      5
AR No.      04.01.37                            Document No.  000174

Title:      "Soil-Heating Technology Shown to Accelerate the Removal of Volatile Organic
            Compounds from Clay Soils," Bergsman et al.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    THERESA BERGSMAN
Date:       December 1995
Format:     MISCELLANEOUS                       No. Pgs:      11
AR No.      04.01.38                            Document No.  000133
    *Attached to Document No. 000129 In 04.01

Title:      Letter Concerning the Information Reguired  in the Focused Feasibility Study Being
            Prepared by Beak on Behalf of GE.
Addressee:  MICHAEL IANNIELLO - GENERAL ELECTRIC COMPANY
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       December 5, 1995
Format:     LETTER                              No. Pgs:      4
AR No.      04.01.39                            Document No.  000266

Title:      "Facts about In Situ Thermal Desorption Technology" from Shell Technology Ventures
            Inc.
Addressee:  MILFORD BOARD OF SELECTMEN
Date:       January 1996
Format:     FACT SHEET, PRESS RELEASE          No. Pgs:      4
AR No.      04.01.40                           Document No.  000184
    *Attached to Document No. 000183 In 04.01
Title:      Letter from Coleen Fuerst, General Electric, to Cheryl Sprague, US EPA RI,
            20, 1996) .  Concerning Maxymillian and Shell thermal technology.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST GENERAL ELECTRIC COMPANY
Date:       February 20, 1996
Format:     LETTER                             No. Pgs:      1
AR No.      04.01.41                           Document No.  000175
(February
Title:      Letter from Stephen D. Ramsey, General Electric,  to John DeVillars, US EPA RI,
            (February 28, 1996). Concerning feasibility study.
Addressee:  JOHN DEVILLARS - U.S. EPA REGION I
Authors:    GENERAL ELECTRIC COMPANY
Date:       February 28, 1996
Format:     LETTER                              No. Pgs:      2
AR No.      04.01.42                            Document No.  000176

Title:      Letter from Coleen Fuerst, General Electric, to Cheryl Sprague, US EPA RI,  (March 11,
            1996).  Concerning thermal desorption technologies.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       March 11, 1996
Format:     LETTER                              No. Pgs:      1
AR No.      04.01.43                            Document No.  000177
Title:      A Citizen's Guide to Thermal Desorption, Technology Fact Sheet,  (April 1996).
Addressee:  LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Authors:    U.S. ENVIRONMENTAL PROTECTION AGENCY
Date:       April 1996
Format:     FACT SHEET, PRESS RELEASE           No. Pgs:      4
AR No.      04.01.44                            Document No.  000192
   *Attached to Document No. 000189 In 04.01
-------
Title:      "Cotton Bugs Eat Wastes" ENR,  (April 22, 1996), p. 18.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       April 22, 1996
Format:     NEWS CLIPPING                       No. Pgs:      1
AR No.      04.01.45                            Document No.  000179
    *Attached to Document No. 000178 In 04.01

Title:      Letter from Lisa Hogen, Maxymillian Technologies, to Cheryl Sprague, US EPA RI,
            (April 24, 1996) . Enclosed literature on indirect system.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LISA HOGEN
Date:       April 24, 1996
Format:     LETTER                              No. Pgs:
AR No.      04.01.46                            Document No.
1
000221
    *Attached to Document No. 000139 In 04.01
Title:      Entretech "1" Informational description from internet.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       May 1, 1996
Format:     FACT SHEET, PRESS RELEASE          No. Pgs:      3
AR No.      04.01.47                           Document No.  000180
    *Attached to Document No. 000178 In 04.01

Title:      Letter from Lee F. Mayhew, Town of Milford Administrator, to Cheryl Sprague, US EPA
            RI, (May 2, 1996). Concerning cotton fiber discovery.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Date:       May 2, 1996
Format:     LETTER                             No. Pgs:      1
AR No.      04.01.48                           Document No.  000178

Title:      Letter from John DeVillars, US EPA RI, to Stephen D. Ramsey, General Electric,  (May
            7, 1996). Concerning meeting schedules and feasibility study.
Addressee:  STEPHEN D RAMSEY - GENERAL ELECTRIC COMPANY
Authors:    JOHN DEVILLARS - U.S. EPA REGION I
Date:       May 7, 1996
Format:     LETTER                             No. Pgs:      1
AR No.      04.01.49                           Document No.  000181

Title:      "Demonstration Test Report PCB Disposal by Non-Thermal Alternative Methods, South
            Glens Falls Drag Strip, Saratoga Cty., NY, vols. 1  & 2.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       May 9, 1996
Format:     REPORT, STUDY                      No. Pgs:      272
AR No.      04.01.50                           Document No.  000135

Title:      Letter from John H. Guswa, GeoTrans, Inc., to Coleen Fuerst, General Electric,  (May
            22, 1996) .  Comments on Final Feasibility Study.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    JOHN H. GUSWA
Date:       May 22, 1996
Format:     LETTER                             No. Pgs:      5
AR No.      04.01.51                           Document No.  000187
    *Attached to Document No. 000185 In 04.01
Title:      Letter from Coleen Fuerst, General Electric, to Marilyn Kenison, Town of Milford,
            dated 5/23/96, concerning public meeting on thermal technologies.
Addressee:  MILFORD BOARD OF SELECTMEN
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       May 23, 1996
Format:     LETTER                             No. Pgs:      1
AR No.      04.01.52                           Document No.  000183
    *Attached to Document No. 000182 In 04.01
-------
Title:      Letter from Julie A. Stickney & Russell E. Keenan, ChemRisk, to Coleen  Fuerst,  GE,
             (May 23, 1996) . Comments on Final Feasibility Study.
Addressee:  COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Authors:    JULIE A. STICKNEY, RUSSELL E. KEENAN
Date:       May 23, 1996
Format:     LETTER                             No. Pgs:       19
AR No.      04.01.53                           Document No.   000186
    *Attached to Document No. 000185 In 04.01

Title:      Comments (May 24, 1996) from Coleen Fuerst, General Electric, on the  Final
            Feasibility Study.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
Date:       May 24, 1996
Format:     MISCELLANEOUS                      No. Pgs:       13
AR No.      04.01.54                           Document No.   000185

Title:      Facsimile from Lee F. Mayhew, Town of Milford Administrator, to Cheryl  Sprague, US
            EPA RI,  (May 30, 1996). Encloses letter from Coleen Fuerst, GE.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Date:       May 30, 1996
Format:     CORRESPONDENCE                     No. Pgs:       1
AR No.      04.01.55                           Document No.   000182

Title:      Memorandum from Eva L. Davis, EPA Research Hydrologist, to Cheryl Sprague,  (June  19,
            1996). Concerning thermal remediation technigues.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    EVA L. DAVIS - U.S. ENVIRONMENTAL PROTECTION AGENCY
Date:       June 19, 1996
Format:     MEMORANDUM                         No. Pgs:       4
AR No.      04.01.56                           Document No.   000190
    *Attached to Document No. 000189 In 04.01

Title:      Memorandum from Bryan Olson, EPA RI, to Cheryl Sprague, EPA RI,  (June 19, 1996).
            Concerning information on comparable site for thermal wells demo.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    BRYAN OLSON - U.S. EPA REGION I
Date:       June 19, 1996
Format:     MEMORANDUM                         No. Pgs:       1
AR No.      04.01.57                           Document No.   000191
    *Attached to Document No. 000189 In 04.01

Title:      Letter from Cheryl Sprague, US EPA RI, to Lee Mayhew, Town of Milford Administrator,
             (June 28, 1996). Concerning Feasibility Study alternatives.
Addressee:  LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       June 28, 1996
Format:     LETTER                             No. Pgs:       3
AR No.      04.01.58                           Document No.   000189

Title:      Letter from Cheryl Sprague, US EPA RI, to Lee Mayhew, Town of Milford Administrator,
             (July 3, 1996) . Clarification of June 28, 1996 letter.
Addressee:  LEE F. MAYHEW - MILFORD BOARD OF SELECTMEN
Authors:    CHERYL L. SPRAGUE U.S. EPA REGION I
Date:       July 3, 1996
Format:     LETTER                             No. Pgs:       1
AR No.      04.01.59                           Document No.   000193
Title:      Letter from Jill Siebels, General Electric, to Lee Mayhew, Town  of Milford
            Administrator,  (July 3, 1996). Answers guestions posed on thermal wells.
Addressee:  LEE F. MAYHEW MILFORD BOARD OF SELECTMEN
Authors:    JILL SIEBELS GENERAL ELECTRIC COMPANY
Date:       July 3, 1996
Format:     LETTER                              No. Pgs:      6
AR No.      04.01.60                            Document No.  000194
-------
Title:      Letter from Jill Siebels, General Electric, to Philip O'Brien,
            1996). Concerning site tour and meeting July 5, 1996.
Addressee:  PHILIP J. O'BRIEN - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Authors:    JILL SIEBELS - GENERAL ELECTRIC COMPANY
Date:       July 10, 1996
Format:     LETTER                              No. Pgs:      1
AR No.      04.01.61                            Document No.  000195
 NHDES,  (July 10,
Title:      Letter from Larry Brill, US EPA RI, to Philip O'Brien, NHDES,
            Concerning meeting to discuss goals of clean-up.
Addressee:  PHILIP J. O'BRIEN - N.H. DEPT. OF ENVIRONMENTAL
            SERVICES
Authors:    LARRY BRILL - U.S. EPA NEW ENGLAND
Date:       July 17, 1996
Format:     LETTER                              No. Pgs:      5
AR No.      04.01.62                            Document No.  000197
(July  17,  1996) .
Title:      Letter from David E. Ott, Terra Vac to Cheryl Sprague, EPA Region  I
            Concerning Six. Phase Soil Heating  (SPSH) technology.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    DAVID OTT
Date:       July 18, 1996
Format:     LETTER                              No. Pgs:      1
AR No.      04.01.63                            Document No.  000129
      (July 18,  1996)
Title:      Letter from Philip O'Brien, NHDES, to Larry Brill, US EPA NE,
            Concerning revised clean up goals and performance standards.
Addressee:  LARRY BRILL - U.S. EPA NEW ENGLAND
Authors:    PHILIP J. O'BRIEN - N.H. DEPT. OF ENVIRONMENTAL
            SERVICES
Date:       July 22, 1996
Format:     LETTER                              No. Pgs:      1
AR No.      04.01.64                            Document No.  000196
(July  22,1996).
Title:      Letter from Jill Siebels, General  Electric, to Cheryl Sprague, Charles Berube, Lee
            Mayhew (July 25, 1996) . Enclosing work plan for Gasmer Road.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    JILL SIEBELS - GENERAL ELECTRIC COMPANY
Date:       July 25,  1996
Format:     LETTER                              No. Pgs:      1
AR No.      04.01.65                            Document No.  000198

Title:      Letter Concerning Attached Work Plan for the Use of Is-Situ Thermal Desorption  at  a
            Texas Site.
Addressee:  EVA L. DAVIS - U.S. ENVIRONMENTAL PROTECTION AGENCY
Authors:    J. M. HIRSCH - SHELL TECHNOLOGY VENTURES, INC.
Date:       July 30,  1996
Format:     LETTER                              No. Pgs:      20
AR No.      04.01.66                            Document No.  000292

Title:      Letter from Julie Stickney, ChemRisk, to Jill Siebels, General Electric,  (August 1,
            1996). Concerning predicted residual risks to utility workers.
Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
Authors:    JULIE A.  STICKNEY
Date:       August 1, 1996
Format:     LETTER                              No. Pgs:      19
AR No.      04.01.67                            Document No.  000203
    *Attached to Document No. 000202 In 04.01
Title:      Letter from Jill Siebels, General Electric, from Cheryl Sprague, US EPA RI,  (August
            6, 1996). Concerning technical justification for remedies.
Addressee:  CHERYL L.      SPRAGUE  -  U.S.  EPA REGION I
Authors:    JILL SIEBELS - GENERAL ELECTRIC  COMPANY
Date:       August 6, 1996
Format:     LETTER                              No.  Pgs:      2
AR No.      04.01.68                            Document No.  000202
-------
 Title:      Letter from Thomas A. Krug, Beak Consultants Ltd., to Jill Siebels, General Electric,
              (August 6, 1996). Concerning potential PCB transport.
 Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
 Authors:    THOMAS A. KRUG - BEAK CONSULTANTS LIMITED
 Date:       August 6, 1996
 Format:     LETTER                              No. Pgs:      10
 AR No.      04.01.69                            Document No.  000204
     *Attached to, Document No. 000202 In 04.01

 Title:      Letter from John Regan, NHDES, to Cheryl Sprague, US EPA RI,  (August  6,  1996).
             Concerning groundwater protection rules and GE's comments on  FS.
 Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
 Authors:    JOHN REGAN - N.H. DEPT. OF ENVIRONMENTAL SERVICES
 Date:       August 6, 1996
 Format:     LETTER                              No. Pgs:      2
 AR No.      04.01.70                            Document No.  000205

 Title:      Letter Concerning Topics to be Discussed at August 8, 1996 Meeting.
 Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
 Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
 Date:       August 6, 1996
 Format:     LETTER                              No. Pgs:      1
 AR No.      04.01.71                            Document No.  000283

 Title:      Letter from Marilyn Kenison, Milford Board of Selectmen, to Jill Siebels, General
             Electric, (August 12, 1996). Supports GE's demonstration.
 Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
 Authors:    MARILYN KENISON - MILFORD BOARD OF SELECTMEN
 Date:       August 12, 1996
 Format:     LETTER                              No. Pgs:      2
 AR No.      04.01.72                            Document No.  000206

 Title:      Memorandum Concerning January 16, 1997 Visit to TerraTherm to Tour Thermal Wells
             Demonstration.
 Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
 Authors:    EVA L. DAVIS - U.S. ENVIRONMENTAL PROTECTION
             AGENCY
 Date:       January 23,  1997
 Format:     MEMORANDUM                          No. Pgs:      7
 AR No.      04.01.73                            Document No.  000293

 Title:      Letter with Comments and Questions on the Demonstration Test  Plan Prepared for the
             Missouri Electric Works Superfund Site.
 Addressee:  J. M. HIRSCH - TERRATHERM ENVIRONMENTAL SERVICES,
             INC.
 Authors:    EVA L. DAVIS - U.S. ENVIRONMENTAL PROTECTION
             AGENCY
 Date:       January 31,  1997
 Format:     LETTER                              No. Pgs:      2
 AR No.      04.01.74                            Document No.  000294

 Title:      Memorandum Concerning Thermal Blankets and Thermal Wells, with Enclosed  Summary of
             Notes on Visit to Missouri Electric Works Superfund Site.
 Addressee:  ROGER DUWART - U.S. EPA REGION I
 Authors:    EVA L. DAVIS - U.S. EPA NEW ENGLAND
 Date:       May 30, 1997
 Format:     MEMORANDUM                          No. Pgs:      6
 AR No.      04.01.75                            Document No.  000295
Title:      Letter Concerning Attached Updated Cost Estimates for the December 1997 Proposed Plan.
Addressee:  MICHAEL IANNIELLO - GENERAL ELECTRIC COMPANY
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       March 6, 1998
Format:     LETTER                       No. Pgs: 31
AR No.      04.01.76                     Document No. 000270
-------
       Title:       Letter Urging EPA to Adopt a Remediation Plan Providing the Most Cleanup for the Least
                   Cost.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     LEE F. MAYHEW - TOWN OF MILFORD
       Date:        March 23, 1998
       Format:      LETTER                       No. Pgs: 5
       AR No.       04.01.77                     Document No. 000271

       Title:       Letter Clarifying Future Land Use Expectations and Town's Cleanup Position.
       Addressee:   LEE F. MAYHEW - TOWN OF MILFORD
       Authors:     CHERYL L. SPRAGUE - U.S. REGION I
       Date:        May 13, 1998
       Format:      LETTER                       No. Pgs: 2
       AR No.       04.01.78                     Document No. 000272

       Title:       Letter Report on Application of In Situ Thermal Desorption Technology.
       Addressee:   THOMAS E. ROY - ARIES ENGINEERING INC.
       Authors:     THOMAS A. KRUG - BEAK CONSULTANTS LIMITED
       Date:        May 15, 1998
       Format:      REPORT, STUDY
       AR No.       04.01.79                     Document No. 000298
       Title:
       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Response to EPA Letter Concerning Future Use of Elm St. and Mill St. Properties.
CHERYL L. SPRAGUE - U.S. EPA REGION I
LEE F. MAYHEW - TOWN OF MILFORD
June 1, 1998
LETTER
04.01.80
No. Pgs: 2
Document No. 000276
       Title:       Letter Commenting on the Memorandum from Dr. Eva Davis Concerning the Application of
                   TerraTherm's ISTD Process.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     HAROLD J. VINEGAR, GEORGE L. STEGEMEIER - SHELL E
                   & P TECHNOLOGY COMPANY
       Date:        June 19,  1998
       Format:      LETTER                       No. Pgs: 29
       AR No.       04.01.81                     Document No. 000277

       Title:       Letter Concerning Additional Questions Regarding In Situ Thermal Desorption.
       Addressee:   THOMAS E. ROY - ARIES ENGINEERING INC.
       Authors:     RICHARD B. SHELDON - GENERAL ELECTRIC COMPANY
       Date:        July 9, 1998
       Format:      LETTER                       No. Pgs: 9
       AR No.       04-01.82                     Document No. 000279

       Title:       Letter Requesting Meeting of All Parties and Encourages a Demonstrations of the
                   Full-Scale Application of ISTD on PCBs.
       Addressee:   ANTOINETTE POWELL - U.S. EPA REGION I
       Authors:     JOHN E. PELTONEN - SHEEHAN,  PHINNEY, BASS & GREEN
       Date:        July 10,  1998
       Format:      LETTER                       No. Pgs: 2
       AR No.       04.01.83                     Document No. 000280

04.02  FEASIBILITY STUDY - SAMPLING & ANALYSIS DATA

       Title:       Sampling & Analysis Data: Availability for Review
       Format:                                   No. Pgs: 1
       AR No.       04.02.1                      Document No. 000262
       Title:       Water Quality Analysis - Sample #242698 & 242702.
       Addressee:   SUSAN LEVESQUE
       Authors:     CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        August 31,  1993
       Format:      SAMPLING AND ANALYSIS DAT    No. Pgs: 3
       AR No.       04.02.2                      Document No. 000106
-------
       Title:      Analytical Results for Three Samples Taken in March 1994.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        April 29, 1994
       Format:      SAMPLING AND ANALYSIS DAT    No. Pgs: 16
       AR No.      04.02.3                      Document No. 000105

       Title:      Ten Locations for Residential PCB Surface Soil Sampling.
       Addressee:   CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        September 14, 1994
       Format:      LETTER                       No. Pgs: 3
       AR No.      04.02.4                      Document No. 000104

       Title:      Analytical Results from the PCB Soil Sampling on September 19, 1994.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     CHARLES BERUBE - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        October 14,  1994
       Format:      SAMPLING AND ANALYSIS DAT    No. Pgs: 12
       AR No:      04.02.5                      Document No. 000103

       Title:      Results of November 1997 Sampling at the Mill Street Property.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     THOMAS A. KRUG - BEAK CONSULTANTS LIMITED
       Date:        May 25, 1998
       Format:      SAMPLING AND ANALYSIS DAT
       AR No.      04.02.6                      Document No. 000275

04.04  FEASIBILITY STUDY - INTERIM DELIVERABLES

       Title:      Thermal Desorption Remedy Selection Level Treatability Study Report for the Fletcher's
                   Paint Site.
       Addressee:   U.S. ENVIRONMENTAL PROTECTION AGENCY
       Authors:     IT CORPORATION
       Date:        January 1995
       Format:      REPORT, STUDY                No. Pgs: 88
       AR No.      04.04.1                      Document No. 000107

       Title:      Recalculation of risks associated with soil cleanup levels for the Fletcher's Paint
                   Superfund Site
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     ANN-MARIE BURKE - U.S. ENVIRONMENTAL PROTECTION
                   AGENCY
       Date:        October 8, 1996
       Format:      LETTER                       No. Pgs: 3
       AR No.      04.04.2                      Document No. 000260

04.06  FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS

       Title:      Focused Feasibility Report.
       Authors:     ENVIRONMENTAL SCIENCE & ENGINEERING, INC
       Date:        June 2, 1995
       Format:      REPORT, STUDY
       AR No.      04.06.1                      Document No. 000264
       Title:      Comments on the Focused Feasibility Report Dated June 1995.
       Addressee:   COLEEN M. FUERST - GENERAL ELECTRIC COMPANY
       Authors:     JOHN REGAN - N.H. DEPT. OF ENVIRONMENTAL SERVICES
       Date:        June 27, 1995
       Format:      LETTER                       No. Pgs: 4
       AR No.      04.06.2                      Document No. 000265
-------
       Title:       Final Feasibility Study for the Fletcher's Paint Site Milford,  NH.
       Addressee:   U.S.  EPA REGION I
       Authors:     ARTHUR D. LITTLE, INC.
       Date:        April 26, 1996
       Format:      REPORT,  STUDY                No.  Pgs:  762
       AR No.       04.06.3                      Document No. 000140

       Title:       Focused Feasibility Study Report.
       Addressee:   GENERAL ELECTRIC COMPANY
       Authors:     BEAK CONSULTANTS LIMITED
       Date:        December 15,  1997
       Format:      REPORT,  STUDY
       AR No.       04.06.4                      Document No. 000268

       Title:       Letter Commenting on the Proposed Focused Feasibility Study Alternatives Contained in
                   the Focused Feasibility Study Report Submitted by Beak Consultants.
       Addressee:   MICHAEL IANNIELLO - GENERAL ELECTRIC COMPANY
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        February 27,  1998
       Format:      LETTER                       No.  Pgs:  14
       AR No.       04.06.5                      Document No. 000269

       Title:       Memorandum from EPA Hydrologist Evaluating TerraTherm's In Situ Thermal Desorption
                   Processes.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     EVA L. DAVIS  - U.S. ENVIRONMENTAL PROTECTION AGENCY
       Date:        April 21, 1998
       Format:      MEMORANDUM                   No.  Pgs:  9
       AR No.       04.06.6                      Document No. 000274
         *Attached to Document No. 000273  In 04.06

       Title:       Memorandum: Review of Additional  Investigation Activities at Mill Street Property ....
                   Workplan & Sampling and Analysis  Plan Prepared by BEAK, 7/97.
       Addressee:   CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     A. F. BELIVEAU - U.S. EPA REGION I/ESD
       Date:        April 27, 1998
       Format:      MEMORANDUM                   No.  Pgs:  4
       AR No.       04.06.7                      Document No. 000297
         *Attached to Document No. 000296  In 04.06

       Title:       Letter Concerning the Proposed DNAPL Investigation.
       Addressee:   MICHAEL IANNIELLO - GENERAL ELECTRIC COMPANY
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        May 8, 1998
       Format:      LETTER                       No.  Pgs:  7
       AR No.       04.06.8                      Document No. 000296

       Title:       Third and Final Comment Letter to the Focused Feasibility Study,  Evaluating
                   TerraTherm's  ISTD  (Thermal Well)  Technology.
       Addressee:   MICHAEL IANNIELLO - GENERAL ELECTRIC COMPANY
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        May 22,  1998
       Format:      LETTER                       No.  Pgs:  11
       AR No.       04.06.9                      Document No. 000273

04.09  FEASIBILITY STUDY - PROPOSED PLANS  FOR SELECTED REMEDIAL ACTION
       Title:       Proposed Plan,  Fletcher's Paint Superfund Site,  Milford New Hampshire (December,
       Authors:     CHERYL L.  SPRAGUE - U.S.  ENVIRONMENTAL PROTECTION AGENCY
       Date:        December 1996
       Format:      FACT SHEET,  PRESS RELEASE    No.  Pgs:  23
       AR No.       04.09.1                      Document No. 000251
1996)
-------
05.01  RECORDS OF DECISION - CORRESPONDENCE

       Title:      National Remedy Review Board Recommendation on the Fletcher Paint Superfund Site
       Addressee:  LINDA M. MURPHY - U.S. EPA NEW ENGLAND
       Authors:    BRUCE K. MEANS
       Date:        December 5,  1996
       Format:     MEMORANDUM                   No. Pgs:  3
       AR No.      05.01.1                      Document No. 000257

05.02  RECORDS OF DECISION - APPLICABLE OR RELEVANT & APPROPRIATE REQUIREMENTS

       Title:      Applicable or Relevant and Appropriate Requirements  (ARARs) ,  Location-Specific.
       Date:        June 28, 1993
       Format:     MISCELLANEOUS                No. Pgs:  3
       AR No.      05.02.1                      Document No. 000109

       Title:      Applicable or Relevant and Appropriate Requirements  (ARARs),  General Action-Specific.
       Date:        June 28, 1993
       Format:     MISCELLANEOUS                No. Pgs:  6
       AR No.      05.02.2                      Document No. 000110

       Title:      Action-Specific ARARS, Alternatives 2 through 10.
       Date:        June 28, 1993
       Format:     MISCELLANEOUS                No. Pgs:  25
       AR No.      05.02.3                      Document No. 000111

       Title:      Applicable or Relevant and Appropriate Requirements  (ARARs),  Chemical-Specific.
       Date:        December 3,  1993
       Format:     MISCELLANEOUS                No. Pgs:  2
       AR No.      05.02.4                      Document No. 000108

05.04  RECORDS OF DECISION - RECORD OF DECISION

       Title:      Record of Decision
       Authors:    U.S. EPA REGION I
       Date:        September 30, 1998
       Format:     REPORT, STUDY
       AR No.      05.04.1                      Document No. 000299

06.01  REMEDIAL DESIGN CORRESPONDENCE

       Title:      Handwritten Notes on Meeting with GE,  Shell, EPA, NHDES & Town Selectmen,
       Format:     NOTES-MEETING                No. Pgs:  6
       AR No.      06.01.1                      Document No. 000284

       Title:      The Advantages of In-Situ Thermal Technology.
       Authors:    GENERAL ELECTRIC COMPANY
       Format:     LIST                         No. Pgs:  5
       AR No.      06.01.2                      Document No. 000286

       Title:      In Situ Thermal Desorption for the Remediation of PCBs and other Hydrocarbons.
       Authors:    RICHARD B. SHELDON - GENERAL ELECTRIC COMPANY
       Date:        May 17, 1996
       Format:     REPORT , STUDY               No. Pgs:  18
       AR No.      06.01.3                      Document No. 000285

09.10  STATE COORDINATION - STATE TECHNICAL AND HISTORICAL RECORDS

       Title:      Complaint - Suspected Illegal Industrial Discharges, Milford, New Hampshire.
       Addressee:  LORRAINE CARSON - MILFORD CONSERVATION COMMISSION
       Authors:    LYNN A. WOODARD - N.H. WATER SUPPLY AND POLL. CONTROL COM.
       Date:        March 5, 1981
       Format:     LETTER                       No. Pgs:  1
       AR No.      09.10.1                      Document No. 000077
-------
       Title:      N.H. Municipal Records Board Rules, 1985, Mur 300.
       Authors:     N.H. MUNICIPAL RECORDS BOARD
       Date:        1985
       Format:      MISCELLANEOUS                No. Pgs:  14
       AR No.      09.10.2                      Document No. 000074

10.01  ENFORCEMENT/NEGOTIATION - CORRESPONDENCE

       Title:      EPA Activities at the Fletcher's Paint Site Milford, NH.
       Addressee:   ED FRANKOVITZ - MILFORD CONSIGNMENT SHOP
       Authors:     DANIEL COUGHLIN U.S. EPA REGION I
       Date:        July 1, 1993
       Format:      LETTER                       No. Pgs:  2
       AR No.      10.01.1                      Document No. 000043

10.08  ENFORCEMENT/NEGOTIATION - EPA CONSENT DECREES

       Title:      Consent Decree, United States of America v. General Electric Company and
                   Windsor-Embassy  Corporation, Civil No. 91-467-M.
       Addressee:   U.S. DISTRICT COURT, NEW HAMPSHIRE
       Authors:     U.S. DEPARTMENT OF JUSTICE
       Date:        March 23,  1994
       Format:      LITIGATION                   No. Pgs:  46
       AR No.      10.08.1                      Document No. 000044

11.05  POTENTIALLY RESPONSIBLE PARTIES - MULTIPLE PRP DOCUMENTS

       Title:      Notice of Potential Liability at the Fletcher Paint Superfund Site, Milford, NH
       Addressee:   MARILYN KENISON - MILFORD BOARD OF SELECTMEN
       Authors:     LINDA M. MURPHY - U.S. ENVIRONMENTAL PROTECTION AGENCY
       Date:        October 11, 1996
       Format:      LETTER                       No. Pgs:  29
       AR No.      11.05.1                      Document No. 000255

11.09  POTENTIALLY RESPONSIBLE PARTIES - PRP-SPECIFIC DOCUMENTS

       Title:      Letter regarding issuance of additional General Notice Letters
       Addressee:   JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Authors:     CHERYL L.  SPRAGUE - U.S. ENVIRONMENTAL PROTECTION AGENCY
       Date:        October 17, 1996
       Format:      CORRESPONDENCE               No. Pgs:  2
       AR No.      11.09.1                      Document No. 000254

13.01  COMMUNITY RELATIONS - CORRESPONDENCE

       Title:      Feasibility Study Public Comments
       Addressee:   CHERYL L.  SPRAGUE - U.S. ENVIRONMENTAL PROTECTION AGENCY
       Format:                                   No. Pgs:  19
       AR No.      13.01.1                      Document No. 000253

       Title:      Open Letter to Citizens of Milford, New Hampshire.
       Authors:     VICTORIA FLETCHER
       Date:        September 25, 1991
       Format:      LETTER                       No. Pgs:  1
       AR No.      13.01.2                      Document No. 000052

       Title:      Milford N.H. Concerns and Interests Regarding Savage Well and Fletcher Paint
                   Situations.
       Addressee:   SUSAN FRANK - U.S. EPA REGION I
       Authors:     WILLIAM B. ROTCH - MILFORD CABINET AND WILTON JOURNAL
       Date:        December 13, 1991
       Format:      LETTER                       No. Pgs:  2
       AR No.      13.01.3                      Document No. 000053
-------
Title:      EPA Cleanup of Fletcher Paint Works - Convening  Meeting.
Addressee:  AD HOC CITIZENS' ADVISORY COMMITTEE
Authors:    ARNIE WIGHT - PRINCIPLED NEGOTIATIONS, INC.
Date:       December 14, 1991
Format:     MEMORANDUM                   No. Pgs: 1
AR No.      13.01.4                      Document No. 000054

Title:      Reguest for Meeting About Drainage Under the Fletcher Site.
Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
Authors:    LEE F. MAYHEW - TOWN OF MILFORD
Date:       February 12, 1992
Format:     LETTER                       No. Pgs: 1
AR No.      13.01.5                      Document No. 000050

Title:      Public Participation in Clean Up of Fletcher Paint Site.
Addressee:  AD HOC CITIZENS' ADVISORY COMMITTEE
Authors:    ARNIE WIGHT - PRINCIPLED NEGOTIATIONS, INC.
Date:       May 2, 1992
Format:     LETTER                       No. Pgs: 1
AR No.      13.01.6                      Document No. 000048

Title:      EPA/Fletcher Paint Site Clean Up, Goals and Objectives of Citizen Advisory Group.
Addressee:  AD HOC CITIZENS' ADVISORY COMMITTEE
Authors:    ARNIE WIGHT - AD HOC CITIZENS' ADVISORY COMMITTEE
Date:       June 2, 1992
Format:     MEMORANDUM                   No. Pgs: 4
AR No.      13.01.7                      Document No. 000049
  *Attached to Document No. 000048 In 13.01

Title:      Questions and Suggestions Related to Well Testing and the School Site Investigation.
Addressee:  DANIEL COUGHLIN - U.S. EPA REGION I
Authors:    ARNIE WIGHT - PRINCIPLED NEGOTIATIONS, INC.
Date:       July 24, 1992
Format:     LETTER                       No. Pgs: 1
AR No.      13.01.8                      Document No. 000047

Title:      EPA Response to Questions Pertaining to the Investigations at the Site.
Addressee:  ARNIE WIGHT - PRINCIPLED NEGOTIATIONS, INC.
Authors:    DANIEL COUGHLIN - U.S. EPA REGION I
Date:       August 24, 1992
Format:     LETTER                       No. Pgs: 2
AR No.      13.01.9                      Document No. 000046

Title:      Chemical Contamination and Drainage System Problems at the Site.
Addressee:  LEE F. MAYHEW - TOWN OF MILFORD
Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
Date:       October 19, 1992
Format:     LETTER                       No. Pgs: 4
AR No.      13.01.10                     Document No. 000045

Title:      Officials Seek Public input on Superfund Site.
Authors:    N.H. DEPT. OF HEALTH & HUMAN SERVICES
Date:       May 10, 1994
Format:     FACT SHEET, PRESS RELEASE    No.Pgs: 1
AR No.      13.01.11                     Document No. 000112
Title:      Fletcher's Paint Site, Milford, NH 2/16/95 Meeting with Milford Selectmen: Agenda.
Authors:    U.S. EPA REGION I
Date:       February 16, 1995
Format:     MISCELLANEOUS                No. Pgs: 20
AR No.      13.01.12                     Document No. 000065
-------
       Title:      Letter from Milford Board of Selectmen, to Cheryl Sprague, US EPA RI,  (February 27,
                   1995). Official position on site, goals of clean-up.
       Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
       Authors:     JOHN E RUONALA, RICHARD H MACE, ROSARIO
                   RICCIARDI, MARILYN KENISON - MILFORD BOARD OF
                   SELECTMEN
       Date:        February 27, 1995
       Format:      LETTER                       No. Pgs: 3
       AR No.      13.01.13                     Document No. 000188
       Title:      Meeting Notes, EPA Region I, NHDES, GE, Town of Milford  (August
                   Discussion.
       Authors:     CHERYL L. SPRAGUE - U.S. EPA REGION I
       Date:        August 8, 1995
       Format:      NOTES-MEETING                No. Pgs: 4
       AR No.      13.01.14                     Document No. 000153
1996).  FS
       Title:      Public Comments Received from May 1996 Public  Meeting  (Names redacted).
       Addressee:  U.S. EPA REGION I
       Date:        May 1996
       Format:      PUBLIC MEETING RECORDS       No. Pgs: 8
       AR No.      13.01.15                     Document No. 000149
       Title:      Letter from Cheryl Sprague, US EPA RI, to Jill Siebels, General Electric Co.,
                   6,  1996).
       Addressee:  JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Authors:     CHERYL L.  SPRAGUE - U.S. EPA REGION I
       Date:        August 6,  1996
       Format:      LETTER                       No. Pgs: 1
       AR No.      13.01.16                     Document No. 000151
           (August
       Title:      Summary of FS Remedies vs GE's Proposed Remedy, Handout from General Electric at
                   meeting held August 8, 1996.
       Addressee:  CHERYL, L. SPRAGUE - U.S. EPA REGION I
       Authors:     GENERAL ELECTRIC COMPANY
       Date:        August 8,  1996
       Format:      NOTES-MEETING                No. Pgs: 2
       AR No.      13.01.17                     Document No. 000154
         *Attached to Document No. 000153 In 13.01

13.02  COMMUNITY RELATIONS - COMMUNITY RELATIONS PLANS

       Title:      One Paragraph; Summary of Community Relations Actions for a Removal by EPA.
       Format:      NOTES-GENERAL                No. Pgs: 1
       AR No.      13.02.1                      Document No. 000072

       Title:      Community Relations Plan for Remedial Planning Activities at the Fletcher's Paint
                   Site,  Milford, NH.
       Addressee:  U.S. EPA REGION I
       Authors:     ARTHUR D.  LITTLE, INC.
       Date:        February 11, 1993
       Format:      REPORT, STUDY                No. Pgs: 18
       AR No.      13.02.2                      Document No. 000071

13.03  COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES

       Title:      News Release, Initiation of Local Committee Supported by Technical Assistance Grant
                   Program.
       Authors:     AD HOC CITIZENS' ADVISORY COMMITTEE
       Format:      FACT SHEET, PRESS RELEASE    No. Pgs: 1
       AR No.      13.03.1                      Document No. 000055
       Title:      "EPA Cleans Up Files."
       Authors:     JANET PHELPS - MILFORD CABINET AND WILTON JOURNAL
       Format:      NEWS CLIPPING                No. Pgs: 1
       AR No.      13.03.2                      Document No. 000126
-------
Title:      "Milford's Stone Bridge."
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       August 26, 1992
Format:     NEWS CLIPPING                No. Pgs: 1
AR No.      13.03.3                      Document No. 000113

Title:      Photograph of a Milford Tannery on the Editorial Page.
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       October 14, 1992
Format:     NEWS CLIPPING                No. Pgs: 1
AR No.      13.03.4                      Document No. 000114
Title:      EPA Awards Initial $15,000 Grant to CUPS! To Monitor Fletcher's Paint Works  &
            Superfund Site Cleanup.
Authors:    U.S. EPA REGION I
Date:       June 10, 1993
Format:     FACT SHEET, PRESS RELEASE    No. Pgs: 2
AR No.      13.03.5                      Document No. 000056
Storage
Title:      "Fletcher's Clean-Up," The Milford Cabinet and Wilton Journal - Milford, NH  (July 28,
            1993)
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       July 28, 1993
Format:     NEWS CLIPPING                No. Pgs: 1
AR No.      13.03.6                      Document No. 000219

Title:      Photograph of "The Blacksmith Shop" on Elm Street on the Editorial Page.
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       March 30, 1994
Format:     NEWS CLIPPING                No. Pgs: 1
AR No.      13.03.7                      Document No. 000115

Title:      "EPA Concludes Keyes Field Safe for Recreation," EPA Environmental News. EPA Region  I
            (July 27, 1994).
Authors:    U.S. EPA REGION I
Date:       July 27, 1994
Format:     FACT SHEET, PRESS RELEASE    No. Pgs: 2
AR No.      13.03.8                      Document No. 000223

Title:      "Keyes Field OK, River Off Limits."
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       August 3, 1994
Format:     NEWS CLIPPING                No. Pgs: 2
AR No.      13.03.9                      Document No. 000116

Title:      Public Workshop to Discuss Potential Impacts of the Clean Up of Fletcher's Paint
            Superfund Site.
Authors:    U.S. EPA NEW ENGLAND
Date:       January 12, 1995
Format:     FACT SHEET, PRESS RELEASE    No. Pgs: 1
AR No.      13.03.10                     Document No. 000064

Title:      "EPA Finds Few Friends in Milford."
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       January 18, 1995
Format:     NEWS CLIPPING                No. Pgs: 2
AR No.      13.03.11                     Document No. 000117
Title:      Letter to the Editor: "Leave Well Enough Alone."
Addressee:  MILFORD CABINET AND WILTON JOURNAL
Authors:    KIM B LABELLE
Date:       February 1, 1995
Format:     NEWS CLIPPING                No. Pgs: 1
AR No.      13.03.12                     Document No. 000118
-------
Title:      "General Electric's Role Comes to Light."
Authors:    MILFORD CABINET AND WILTON JOURNAL
Date:       February 22, 1995
Format:     NEWS CLIPPING                No. Pgs: 2
AR No.      13.03.13                     Document No. 000119

Title:       Letter to the Editor, "It's time to decide for life or death," Milford  Cabinet  and
             Wilton Journal  (March 1, 1995).
Authors:     MICHELLE KUNKEL
Date:        March 1, 1995
Format:      NEWS CLIPPING                No. Pgs: 1
AR No.       13.03.14                     Document No. 000213

Title:       "Selectmen complain about EPA, open bids, form fireworks group," The Milford  Cabinet
             and Wilton Journal - Milford, NH  (July 19, 1995). Mill St.  site.
Authors:     BOB MACKINTOSH - MILFORD CABINET AND WILTON
             JOURNAL
Date:        July 19, 1995
Format:      NEWS CLIPPING                No. Pgs: 1
AR No.       13.03.15                     Document No. 000220

Title:       "Superfund Cleanup Blues."
Authors:     BETH A MARCHESE - MILFORD CABINET AND WILTON
             JOURNAL
Date:        July 23, 1995
Format:      NEWS CLIPPING                No. Pgs: 2
AR No.       13.03.16                     Document No. 000120

Title:       "EPA Bulldozers in Milford Stirring Up Mixed Feelings."
Authors:     BETH A. MARCHESE - MILFORD CABINET AND WILTON JOURNAL
Date:        July 23, 1995
Format:      NEWS CLIPPING                No. Pgs: 2
AR No.       13.03.17                     Document No. 000121
  *Attached to Document No. 000120 In 13.03

Title:       "EPA, General Electric Reach Accord on Work."
Authors:     JANET PHELPS - MILFORD CABINET AND WILTON JOURNAL
Date:        August 2, 1995
Format:      NEWS CLIPPING                No. Pgs: 2
AR No.       13.03.18                     Document No. 000122

Title:       "EPA, General Electric reach accord on work," The Milford Cabinet  and Wilton  Journal
             - Milford, NH  (August 2, 1995).
Authors:     JANET PHELPS - MILFORD CABINET AND WILTON JOURNAL
Date:        August 2, 1995
Format:      NEWS CLIPPING                No. Pgs: 2
AR No.       13.03.19                     Document No. 000214

Title:       "25 Years Ago this Week - 1970."
Authors:     MILFORD CABINET AND WILTON JOURNAL
Date:        August 9, 1995
Format:      NEWS CLIPPING                No. Pgs: 1
AR No.       13.03.20                     Document No. 000123

Title:       "Dustbusters."
Authors:     MILFORD CABINET AND WILTON JOURNAL
Date:        August 9, 1995
Format:      NEWS CLIPPING                No. Pgs: 1
AR No.       13.03.21                     Document No. 000124
Title:       "Milford: Mill Street Cleanup on Schedule."
Authors:     THE TELEGRAPH
Date:        August 10, 1995
Format:      NEWS CLIPPING                No. Pgs: 1
AR No.       13.03.22                     Document No. 000125
-------
       Title:        "EPA releases Fletcher's cleanup choices," The Milford Cabinet and Wilton Journal -
                    Milford,  NH  (May 1,  1996).
       Authors:      JANET PHELPS - MILFORD CABINET AND WILTON JOURNAL
       Date:         May 1,  1996
       Format:       NEWS CLIPPING                No. Pgs:  2
       AR No.        13.03.23                     Document No. 000216

       Title:        "Milford may be liable for part of Fletcher's cleanup costs," The Telegraph - Nashua,
                    NH (May 23, 1996).
       Authors:      DARREN GARNICK
       Date:         May 23, 1996
       Format:       NEWS CLIPPING                No. Pgs:  2
       AR No.        13.03.24                     Document No. 000215

       Title:        GE Public Meeting Notice: "GE has hot new solution for cleanup"
       Authors:      COLEEN M. FUERST,  JILL SIEBELS - GENERAL ELECTRIC COMPANY
       Date:         June 4, 1996
       Format:       MISCELLANEOUS                No. Pgs:  3
       AR No.        13.03.25                     Document No. 000252

       Title:        "Korean War Memorial soil removal to begin in Milford, New Hampshire," EPA Region I,
                    GE, NHDES  (August 9, 1996).
       Authors:      U.S.  EPA REGION I
       Date:         August 9, 1996
       Format:       FACT SHEET, PRESS RELEASE    No. Pgs:  1
       AR No.        13.03.26                     Document No. 000155

       Title:        Draft Press Release from EPA Region I of Settlement with General Electric, (August
                    26, 1994).
       Authors:      U.S.  EPA REGION I
       Date:         August 26, 1996
       Format:       FACT SHEET, PRESS RELEASE    No. Pgs:  1
       AR No.        13.03.27                     Document No. 000212

       Title:        EPA Environmental News: "EPA Proposes Phased Cleanup Approach for Fletcher's Paint
                    Superfund Site"
       Authors:      CHERYL L. SPRAGUE,  KRISTEN CONROY - U.S. EPA NEW
                    ENGLAND
       Date:         December 27, 1996
       Format:       FACT SHEET, PRESS RELEASE    No. Pgs:  2
       AR No.        13.03.28                     Document No. 000256

       Title:        Remediation: Thermal Desorption Technigue Keeps Pollution Under Wraps.
       Authors:      WILLIAM J. ANGELO
       Date:         February 23, 1998
       Format:       NEWS CLIPPING                No. Pgs:  2
       AR No.        13.03.29                     Document No. 000282

       Title:        Hazardous Waste News: EPA Testing New Remediation Process That Could Heat-Vaporize
                    Pollutants.
       Date:         April 20, 1998
       Format:       FACT SHEET, PRESS RELEASE    No. Pgs:  1
       AR No.        13.03.30                     Document No. 000281

13.04  COMMUNITY RELATIONS - PUBLIC MEETINGS/HEARINGS

       Title:        Fletcher's Paint Works and Storage Facility Site Kick-off Meeting Agenda, September
                    25, 1991.
       Authors:      U.S.  EPA REGION I
       Format:       MEMORANDUM                   No. Pgs:  1
       AR No.        13.04.1                      Document No. 000051
       Title:        Meeting Agenda, EPA Region I (May 17, 1994) .  Concerning Feasibility Study.
       Authors:      U.S. EPA REGION I
       Date:         May 17, 1994
       Format:       PUBLIC MEETING RECORDS       No. Pgs: 5
       AR No.        13.04.2                      Document No. 000147
-------
       Title:       Fletcher's Paint Works & Storage Superfund Site; Remedial Investigation Meeting.
       Authors:      U.S. EPA REGION I
       Date:         August 17, 1994
       Format:       PUBLIC MEETING RECORDS       No. Pgs:  46
       AR No.       13.04.3                      Document No. 000134
         *Attached to Document No. 000128 In 13.04

       Title:       Summary of August 17, 1994 Public Meeting Fletcher's Paint Site.
       Addressee:    U.S. EPA REGION I
       Authors:      ARTHUR D. LITTLE, INC.
       Date:         September 12,  1994
       Format:       PUBLIC MEETING RECORDS       No. Pgs:  5
       AR No.       13.04.4                      Document No. 000128

       Title:       Impact Meeting Sign-in Sheets.
       Addressee:    U.S. EPA REGION I
       Date:         January 17, 1995
       Format:       LIST                         No. Pgs:  5
       AR No.       13.04.5                      Document No. 000042

       Title:       Attendance List, EPA Region I, ADL, GE, B&M, NHDES,  (February 16, 1995).
       Date:         February 16,  1995
       Format:       LIST                         No. Pgs:  1
       AR No.       13.04.6                      Document No. 000148

       Title:       Superfund: The Road to Cleanup. U.S. EPA RI Public Meeting Presentation  (May 1996).
       Authors:      U.S. EPA REGION I
       Date:         May 1996
       Format:       PUBLIC MEETING RECORDS       No. Pgs:  15
       AR No.       13.04.7                      Document No. 000136

       Title:       Attendance List, EPA, NHDES,  GE, Town of Milford,  (August 8, 1996).
       Date:         August 8, 1996
       Format:       PUBLIC MEETING RECORDS       No. Pgs:  1
       AR No.       13.04.8                      Document No. 000152
13.5
COMMUNITY RELATIONS - FACT SHEETS/INFORMATION UPDATES
        Title:

        Authors:
        Format:
        AR No.
           Informational Folder from TerraTherm  Environmental Services, Inc.  [Available at EPA
           Region I Records Center, Boston, MA].
           TERRATHERM ENVIRONMENTAL SERVICES, INC.
                   13.05.1
                                                             Document No.  000289
        Title:
        Authors:
        Date:
        Format:
        AR No.
           EPA Begins Remedial Investigation and Feasibility Study at the Fletcher's Paint Site.
           U.S. EPA REGION I
           September 1991
           FACT SHEET, PRESS RELEASE
           13.05.2
No. Pgs:  8
Document No.
                                                                           000062
        Title:      EPA to Remove Contaminated Material.
        Authors:    U.S.  EPA REGION I
        Date:      July 12,  1993
        Format:     FACT SHEET,  PRESS RELEASE
        AR No.      13.05.3
                                                     No. Pgs:  5
                                                     Document No.
                                                                           000060
        Title:      Superfund Fact Sheet, Remedial Studies Results & Shed Removal Update.
        Authors:    U.S.  EPA REGION I
        Date:      September 1993
        Format:     FACT SHEET,  PRESS RELEASE                 No. Pgs:  11
        AR No.      13.05.4                                   Document No.  000059
-------
        Title:      Superfund Program Remedial Investigation Fact Sheet, Fletcher's Paint Site
                   Investigation  Results.
        Authors:    U.S. EPA REGION I
        Date:      August 1994
        Format:     FACT SHEET, PRESS RELEASE                 No. Pgs:  11
        AR No.      13.05.5                                   Document No.  000057

        Title:      "Superfund Fact Sheet, Fletcher's Paint Works Storage Facility Superfund Site,
                   Milford,  NH,  (January 1995).  Informal Workshop announced.
        Authors:    U.S. EPA REGION I
        Date:      January 1995
        Format:     FACT SHEET, PRESS RELEASE                 No. Pgs:  4
        AR No.      13.05.6                                   Document No.  000218

        Title:      "Cleanup Alternatives for the Fletcher's Paint Site, Milford, NH" EPA Region I  (April,
                   1996).  Concerned potential alternative cleanup choices
        Authors:    U.S. EPA REGION I
        Date:      April 1996
        Format:     FACT SHEET, PRESS RELEASE                 No. Pgs:  21
        AR No.      13.05.7                                   Document No.  000217

        Title:      Project Status Fact Sheet: In Situ Thermal Desorption Using Thermal Wells.
        Authors:    GENERAL ELECTRIC COMPANY
        Date:      July 1997
        Format:     FACT SHEET, PRESS RELEASE                 No. Pgs:  2
        AR No.      13.05.8                                   Document No.  000288
        Title:      TerraTherm Update - Spring 1998.
        Authors:    TERRATHERM ENVIRONMENTAL SERVICES, INC.
        Date:      June 17, 1998
        Format:     FACT SHEET,  PRESS RELEASE
        AR No.      13.05.9
No. Pgs:  2
Document No.  000287
13.07
              COMMUNITY RELATIONS - TECHNICAL ASSISTANCE GRANTS
        Title:      Response to Questions from C.U.P.S.! on the Fletcher Paint Superfund Site.
        Addressee: JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
        Date:      November 23, 1992
        Format:     LETTER                                    No. Pgs:  8
        AR No.      13.07.1                                   Document No.  000067

        Title:      Results of the October, 1992 NHDES Sampling,  Milford Transfer Station & Keyes Field.
        Addressee: JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
        Date:      December 3, 1992
        Format:     LETTER                                    No. Pgs:  1
        AR No.      13.07.2                                   Document No.  000068

        Title:      Reguest for Hazardous and Toxic Material Removal, Mill Street Warehouse, Fletcher
                   Paint Site, [December 11, 1991].
        Addressee: MILFORD BOARD OF SELECTMEN
        Authors:    JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Date:      December 11, 1992
        Format:     LETTER                                   No. Pgs:  3
        AR No.      3.07.3                                   Document No.  000070
        Title:      Application for Federal Assistance, Superfund Technical Assistance Grant.
        Addressee: U.S. EPA REGION I
        Authors:    JAMES D. SMITH - CLEAN UP PAINT SITE  (C.U.P.S.!)
        Date:      January 28, 1993
        Format:     FORM                                     No. Pgs:  20
        AR No.      13.07.4                                  Document No.  000066
-------
        Title:      Transmittal of the Preliminary Ecological Assessment and Notification of Preliminary
                   Survey of the Souhegan River.
        Addressee:  JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Authors:    CHERYL L. SPRAGUE - U.S. EPA REGION I
        Date:       June 6,  1994
        Format:     LETTER                                   No. Pgs:   1
        AR No.      3.07.5                                   Document No.  000058

        Title:      CUPS! Clean Up Paint Site! Community Informational Sheet.
        Authors:    JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Date:       January 17, 1995
        Format:     MISCELLANEOUS                             No. Pgs:  2
        AR No.      13.07.6                                   Document No.  000061

        Title:      Letter from Michael McGagh,  TAG Project Manager, US EPA RI, to James D.Smith, Clean Up
                   Paint Site! (C.U.P.S!),  (March 27, 1996).
        Addressee:  JAMES D. SMITH - CLEAN UP PAINT SITE (C.U.P.S.!)
        Authors:    MICHAEL MCGAGH - U.S. EPA REGION I
        Date:       March 27, 1996
        Format:     LETTER                                    No. Pgs:  2
        AR No.      13.07.7                                   Document No.  000146
14.01
        CONGRESSIONAL RELATIONS - CORRESPONDENCE
        Title:      Concern About the Clean up options for the Site, and a Request for Update on Work at
                   the Site.
        Addressee:  JOHN DEVILLARS - U.S. EPA REGION I
        Authors:    JUDD GREGG - U.S. CONGRESS. SENATE
        Date:       July 11, 1995
        Format:     LETTER                                    No. Pgs:  1
        AR No.      14.01.1                                   Document No.  000063

        Title:      Meeting Agenda,  Fletcher Paint Site Visit by U.S. Senator Bob Smith, Milford, NH,
                   (July 5, 1996).
        Addressee:  CHERYL L. SPRAGUE - U.S. EPA REGION I
        Date:       July 5, 1996
        Format:     NOTES-MEETING                             No. Pgs:  1
        AR No.      14.01.2                                   Document No.  000150
        Title:      Letter from U.S. Senator Bob Smith, to John DeVillars, US EPA RI,
                   Concerning support for delay in ROD to test ISTD.
        Addressee:  JOHN DEVILLARS - U.S. EPA REGION I
        Authors:    BOB SMITH - U.S. CONGRESS. SENATE
        Date:       September 9,  1996
        Format:     LETTER                                    No. Pgs:  2
        AR No.      14.01.3                                   Document No.  000208
          *Attached to Document No. 000207 In 14.01
(September  9,  1996)
        Title:      Letter from U.S. Senator Bob Smith, to Elliott Laws, EPA Washington,
                   1996).  Concerning letter to John DeVillars attached.
        Addressee:  ELLIOTT LAWS - U.S. ENVIRONMENTAL PROTECTION AGENCY
        Authors:    BOB SMITH - U.S. CONGRESS. SENATE
        Date:       September 10,  1996
        Format:     LETTER                                    No. Pgs:  1
        AR No.      14-01.4                                   Document No.  000207
   (September  10,
        Title:      Congressional Correspondence regarding Fletcher Paint Superfund Site.
        Addressee:  BOB SMITH - U.S. CONGRESS. SENATE
        Authors:    JOHN DEVILLARS - U.S. EPA REGION I
        Date:       October 8,  1996
        Format:     CORRESPONDENCE                            No. Pgs:  2
        AR No.      14.01.5                                   Document No.  000258
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16.04   NATURAL RESOURCE TRUSTEE - TRUSTEE NOTIFICATION FORM AND SELECTION GU

        Title:      Site Exposure Potential, Fletcher's Paint Works and Storage, Milford, NH, Region I,
                   NHD001079649
        Authors:   U.S. EPA REGION I
        Format:    REPORT, STUDY                             No. Pgs:  3
        AR No.      16.04.1                                   Document No.  000228

17.07.   SITE MANAGEMENT RECORDS - REFERENCE DOCUMENTS

        Title:      Geohydrology of, and Simulation of Ground-Water Flow in, the Milford-Souhegan
                   Glacial-Drift Aguifer, Milford, New Hampshire.
        Authors:   PHILIP T. HARTE, THOMAS J. MACK - U.S. GEOLOGICAL SURVEY
        Date:      1992
        Format:    REPORT, STUDY                             No. Pgs:  109
        AR No.      17.07.1                                   Document No.  000127

17.08   SITE MANAGEMENT RECORDS - FEDERAL AND LOCAL TECHNICAL AND HISTORICAL

        Title:      Minutes of the April 14, 1981 Meeting.
        Authors:   MILFORD CONSERVATION COMMISSION
        Format:    NOTES-MEETING                             No. Pgs:  1
        AR No.      17.08.1                                   Document No.  000075

        Title:      Short Description of Fletcher Paint Works and the Windsor-Embassy Chemical
                   Corporation, Excerpt from Town History.
        Date:       1979
        Format:    MISCELLANEOUS                             No. Pgs:  1
        AR No.      17.08.2                                   Document No.  000076

        Title:      Suspected Pollution of Water Sources in Milford.
        Addressee: LYNN A. WOODARD - N.H. WATER SUPPLY AND POLL. CONTROL COM.
        Authors:   LORRAINE CARSON - MILFORD CONSERVATION COMMISSION
        Date:      February 12, 1981
        Format:    LETTER                                    No. Pgs:  2
        AR No.      17.08.3                                   Document No.  000078

        Title:      Town of Milford, New Hampshire 03055, Rules & Regulations of Sewer Use, Article III,
                   Use of the Public Sewers.
        Authors:   TOWN OF MILFORD
        Date:      May 1987
        Format:    MISCELLANEOUS                             No. Pgs:  7
        AR No.      17.08.4                                   Document No.  000073
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                                        APPENDIX D

Ms. Linda Murphy, Director
Office of Site Remediation and Restoration
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
1 Congress Street
Boston, MA 02203-2211

SUBJECT: MILFORD, Fletcher Paint Site, Groundwater Use and Value Determination

Dear Ms. Murphy:

       The New Hampshire Department of Environmental Services  (Department) has completed the groundwater
use and value determination for the Fletcher Paint Superfund Site in Milford, New Hampshire. The
Department made the determination at the reguest of the U.S. Environmental Protection Agency (EPA) using
EPA's guidance document entitled, "Ground Water Use and Value Determination Guidance, Final Draft, dated
April 3,1996".

       Following the procedures outlined in the guidance document, the Department has determined that the
groundwater in the vicinity of the Fletcher Paint Site is Medium Use and Value, Attached is a worksheet
summarizing the site-specific use and value considerations and a list of the sources of information used
for the determination.

       EPA and DES recognize this determination should not be used mechanically to direct a particular
remedial outcome, but instead should be used as a management tool for remedial action development and
selection. The Department believes that the use and value determination provides the foundation for
selecting a remedy that is resource-based and incorporates several of the features of EPA's guidance
document in that it: 1) recognizes an increased State role for Superfund decision-making in accordance
with the principles of the Comprehensive State Groundwater Protection Program  (CSGWPP); 2) creates the
framework for a cost-effective and practical decision relative to groundwater remediation within a
reasonable time-frame based on the value and expected use of groundwater; 3) reflects the Town of
Milford's intentions with respect to their long term plans for use of the Keyes Well and the groundwater
in the vicinity of the Fletcher Paint Site; and 4) facilitates making a decision that is consistent with
the state and federal corrective action programs. The Department has an increased role since EPA-New
England endorsed New Hampshire's CSGWPP program in 1994.

       The use and value determination is consistent with past discussions between the agencies in which
the Department has emphasized the selection of a remedy that 1) achieves treatment, removal or
containment of the source of groundwater contamination and 2) restores groundwater guality to Ambient
Groundwater Quality Standards (AGQS),  i.e., drinking water standards, through natural attenuation while
managing the plume within a Groundwater Management Zone.

The Department is implementing this approach at nearby sites where releases of petroleum and other
contaminants have impacted groundwater guality. This pragmatic approach is designed so that the combined
remedial actions taken at the Fletcher Paint Site and other sites will restore the guality of groundwater
over time. This is consistent with the Town's long term strategy to reevaluate the use of the groundwater
in this area as an alternative to meet future water supply demand. The Fletcher Paint Site is located in
an area mapped by the U.S. Geological Survey as a stratified drift aguifer, and the nearby Keyes Well had
a demonstrated yield of 350 gallons per minute prior to the discovery of contaminants in 1984.  The
proximity of the Keyes Well to several sites where contaminants have been released, and remedial actions
are ongoing, does not preclude future use of the well as a water supply. However, the following factors
make short term reuse of the Keyes Well unlikely: 1) the Town has taken actions to provide a dependable
and ample source of drinking water through its interconnection to the Pennichuck Water Works system, 2)
the Town and the Department have a greater interest in restoration and reuse of the groundwater in the
much more extensive aguifer located near the Savage Well, 3)) the proximity of the Keyes Well to the
Souhegan River may subject it to the treatment reguirements of the Safe Drinking Water Act as groundwater
under the influence of surface water,  and 4) there are multiple plumes in addition to the Fletcher Paint
Site in the vicinity of the Keyes Well that will take time before groundwater guality is restored.

If you have any guestions on this declaration, please contact Carl Baxter at (603) 271-2909.



cc.    Philip J. O'Brien, Ph.D., Director, WMD         Carl Baxter,  P.E.    Richard Boynton, EPA
       Harry Stewart, P.E.                             Larry Brill,  EPA
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                                FIiETCHER PAINT SITE, MILFORD NEW HAMPSHIRE
                                                APPENDIX A
                   SUMMARY OF GROUNDWATER SITE-SPECIFIC USE AND VALUE CONSIDERATIONS
       FACTORS

1. QUANTITY
HIGH

 X
                              MEDIUM
                                           LOW
2. QUALITY
3. CURRENT PUBLIC WATER
SUPPLY SYSTEMS  (PWSS)
4. CURRENT PRIVATE
DRINKING WATER SUPPLY
WELLS
                    COMMENTS

Transmissivity ranges from 4000-8000 ft#/day. The Keyes Well, an
inactive municipal well, is located within 1100 feet of the site. The
Keyes Well had a capacity of approximately 250,000 gallons
per day  (GPD) before it was closed due to contamination from the
Fletcher Paint site and other sources in the area. Daily production is
estimated based on 12 hours usage daily.

Some occurrence of elevated concentrations of iron and manganese.
The Keyes Well is within 100 feet of surface water and may
reguire treatment or relocation  to meet the Safe Drinking Water Act
(SDWA)  treatment reguirements for groundwater under the
influence of surface water in order to be used in the future,
irrespective of the Fletcher Paint site status.

Keyes Municipal Well inactive since 1984. Town uses other
groundwater sources and installed connection to Pennichuck water
system.

Municipal water available to all properties located in the study area
Groundwater Management Zone will be established to control
future use.
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                                FIiETCHER PAINT SITE, MILFORD NEW HAMPSHIRE
                                                APPENDIX A
                   SUMMARY OF GROUNDWATER SITE-SPECIFIC USE AND VALUE CONSIDERATIONS
5. LIKELIHOOD AND
IDENTIFICATION OF FUTURE
DRINKING WATER USE
                                 X
6. OTHER CURRENT OR
REASONABLE EXPECTED
GROUNDWATER USE(S)  IN
REVIEW AREA

7. ECOLOGICAL VALUE VALUE
 i.  PUBLIC OPINION
The town has other groundwater sources and Pennichuck
Water Works connection to address foreseeable needs.
Current source capacity, including Pennichuck, is 1.8 million
GPD. The average daily demand for water in Milford was
966,000 GPD in 1994 with a daily maximum of 1,460,000
GPD. A long term goal is to make the Keyes Well available
for use. If developed in the future, the Keyes Well may
reguire treatment to meet the Safe Drinking Water Act
reguirements for "groundwater under the influence of
surface water." As a result, the future feasibility and cost
effectiveness of treating or re-siting the Keyes Well is
unknown but may be low relative to the use of other current
(such as Pennichuck Water Works) and/or potential future
sources. For example, the redevelopment of the Savage
Well superfund site after aguifer restoration is likely to be
both more cost-effective and a higher priority due to the
substantially higher well yields available from that aguifer.

Municipal water available to site area and other significant
groundwater withdrawals in the area are unlikely.
Groundwater Management Zone will control future use of
groundwater.

Groundwater discharges to Souhegan River, Class B
surface water  (swimmable, fishable and with treatment can
be used as drinking water source). River is used for
recreational purposes; canoeing, swimming and fishing.

Town does not plan to use the Keyes Well in the
foreseeable future. Long term goal is that Keyes Well has
value as future potential water supply source.
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                                         APPENDIX E

                        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                          REGION 1
                         JFK Federal Building, Boston, MA 02203-2211

DATE:       October, 8, 11996
SUBJ:       Recalculation of risks associated with soil cleanup levels for the Fletcher's
            Paint Superfund Site

FROM:       Ann-Marie Burke, Toxicologist
            Technical Support Section

TO:         Cheryl Sprague, RPM
            NH, RI Superfund Section

The following is a recalculation of the cancer risk associated with the cleanup level for PCBs in soils
at the Fletcher's Paint Superfund Site. This recalculation of risks is the result of a meeting held
between EPA, GE, the State of NH and the Town of Milford, NH on August 8, 1996. At this meeting GE
proposed certain changes to the risk assessment assumptions for PCBs in soils at the Fletcher's site. EPA
agreed to some changes, disagreed with others and introduced additional changes based on new scientific
information about exposure to PCBs released after the amended baseline risk assessment (ABRA) was
completed. This results in a different risk associated with a soil concentration for PCBs than was
calculated in the ABRA. It has been decided that the ABRA will not be amended again but these changes in
exposure and risk assumptions will be conveyed in the ROD for this site. If you have any guestions about
this calculation, do not hesitate to call me at (617)223-5528.

                                      Surface soils 0-1 foot

Cleanup levels for surface soils at the Elm and Mill Street site are protective for an adult or child
visitor who might contact soils in these areas. The Elm Street site is expected to be a future park and
the Mill Street site is expected to remain a commercial area close enough to residents so that young
children could trespass. The cleanup levels for PCBs in surface soils for both areas is Ippm.

The eguation for the risk associated with a particular cleanup level for the oral and dermal routes of
exposures is presented below:






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                                    APPENDIX F





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