Superfund Record of Decision New Hampshire Plating Co Merrimack NH


                                    EPA/ROD/R01-98/134
                                    1998
EPA Superfund
     Record of Decision:
     NEW HAMPSHIRE PLATING CO.
     EPA ID: NHD001091453
     OU01
     MERRIMACK, NH
     09/28/1998

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EPA 541-R98-134

                       RECORD OF DECISION
             US Environmental Protection Agency
                            Region I

            New Hampshire Plating Superfund Site
                   CERCLIS No. NHD001091453

                   Merrimack, New Hampshire

                        September 1998

                      TABLE OF CONTENTS

Contents                                                            Page Number

I.    SITE NAME, LOCATION AND DESCRIPTION 	1

II.   SITE HISTORY & ENFORCEMENT ACTIVITIES 	2

      A. Land Use & Response History
      B. Enforcement History

III.  COMMUNITY PARTICIPATION 	4

IV.   SCOPE & ROLE OF RESPONSE ACTION 	5

V.    SUMMARY OF SITE CHARACTERISTICS 	5

VI.   SUMMARY OF SITE RISKS 	12

VII.  DEVELOPMENT AND SCREENING OF ALTERNATIVES 	16

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

VIII. DESCRIPTION OF ALTERNATIVES 	17

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

IX.   SUMMARY OF THE COMPARATIVE ANALYSIS 	24

X.    THE SELECTED REMEDY 	28

      A. Soil Cleanup Levels
      B. Interim Ground Water Cleanup Levels
      C. Description of Remedial Components

XI.   STATUTORY DETERMINATIONS 	35

      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 	39

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XIII. STATE ROLE 	40

      FIGURE 1 - Site Locus Map
      FIGURE 2 - Study Area Location Map
      FIGURE 3 - Key Site Features
      FIGURE 4 - MCL Exceedances in Overburden Groundwater
      FIGURE 5 - Conceptual Groundwater Management Zone Boundary

      TABLE 1 - Summary of Soil Analytical Results
      TABLE 2 - Summary of Groundwater Analytical Results
      TABLE 3 - Soil Contaminants of Concern
      TABLE 4 - Groundwater Contaminants of Concern
      TABLE 5 - Summary of Risk Assessment Results for Soil
      TABLE 6 - Summary of Risk Assessment Results for Groundwater
      TABLE 7A - Summary of Source Control Alternatives
      TABLE 7B - Summary of Management of Migration Alternatives
      TABLE 8 - Comparative Analysis of Source Control Alternatives
      TABLE 9 - Comparative Analysis of Management of Migration Alternatives
      TABLE 10 - Soil Clean-up Levels
      TABLE 11 - Interim Groundwater Clean-up Levels
      TABLE 12A - Chemical Specific ARARs for Source Control
      TABLE 12B - Location Specific ARARs for Source Control
      TABLE 12C - Action Specific ARARs for Source Control
      TABLE 13A - Chemical Specific ARARs for Management of Migration
      TABLE 13B - Action Specific ARARs for Management of Migration

      APPENDIX A - DES Letter of Concurrence
      APPENDIX B - Responsiveness Summary
      APPENDIX C - Administrative Record Index
      APPENDIX D - Groundwater Use and Value Determination
      APPENDIX E - Letter to Merrimack Village District (June 6, 1998)  with Attached
                   "Evaluation of Potential Supply Well Siting Locations" (May 1998)

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DECLARATION FOR THE RECORD OF DECISION

New Hampshire Plating Company Superfund Site
Merrimack, New Hampshire
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for the New Hampshire Plating Company
Superfund Site (Site) located in Merrimack, 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 concurred on the selected remedy.

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 Merrimack Public Library in Merrimack,
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 SELECTED REMEDY

This ROD sets forth the selected remedy for the New Hampshire Plating Company Site, which involves
in-place treatment of metal-contaminated soil by chemical fixation, natural attenuation of contaminated
groundwater in the overburden aguifers, and institutional controls to allow for acceptable re-development
and prevent future ingestion of contaminated groundwater. The selected remedy is a comprehensive approach
which addresses all current and potential future risks caused by soil and groundwater contamination at
the Site. The remedial measures will prevent leaching of metal-contaminants to groundwater, eliminate
unacceptable exposure to sensitive ecosystems, prevent the ingestion and direct contact with contaminated
groundwater, and allow for restoration of the Site to beneficial uses.

The selected remedy includes these major components:

1. treatment of approximately 40,000 yd 3 of metal-contaminated soil by in-place chemical fixation;

2. consolidation and backfilling of all treated soil in former lagoons 1 and 2;

3. crushing, testing and treating the storage-cell material, as necessary, on-site using the chemical
fixation process and placing treated material in former lagoons 1 and 2;

4. placing two feet of clean soil over the treated materials in the lagoons 1 and 2 area;

5. re-grading and vegetation of the Site using appropriate wetland-type plants and grasses and assuring
adequate flood-storage capacity;

6. restoration of contaminated groundwater in the shallow and deep overburden aquifers by natural
attenuation;

7. establishing a groundwater monitoring, network consistent with New Hampshire's Groundwater
Protection Strategy (GMZ);

8. installing two well clusters in the Town of Litchfield for long-term monitoring;

9. establishing institutional controls including both land-use and groundwater use restrictions;

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10. mitigation of unavoidable impacts to on-site wetlands through the preservation of the Grassy Pond
area in Litchfield and an additional wetland area to be determined in the Town of Merrimack.

DECLARATION

The selected remedy is protective of human health and the environment, attains 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.

The selected remedy is a comprehensive approach which include both source control and management of
migration components. The source control portion of the remedy includes on-site treatment of
metals-contaminated soil by chemical fixation and removal, testing and on-site placement of solidified
material presently contained in a temporary storage-cell. Land-use restrictions or other appropriate
institutional controls will be employed to limit future use of the property to commercial or industrial
development and prevent excavation of treated material. Off-site wetland preservation will be employed to
compensate for unavoidable impacts to the on-site wetlands. 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 at the Site. Active groundwater restoration
does 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 $9,905,400.

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.

I. SITE NAME, LOCATION AND DESCRIPTION

Location and Description

The New Hampshire Plating Company Superfund Site (NHP Site or Site) is located in the Town of Merrimack
(Hillsborough County) in south central New Hampshire. Figure 1 depicts the general location of the Site.
The Site encompasses approximately 13 acres, of which 3.5 acres comprise the Operations Area where the
former New Hampshire Plating Company conducted its operations. The Site is bounded to the east by the
Boston and Maine Railroad right-of-way and the Jones Chemical, Inc.; to the south by Wright Avenue; to
the west by the F. & S. Transit Mix Company; and to the north by the National School Bus Service Company,
and the New England Telephone and Telegraph Company. South of Wright Avenue is an undeveloped lot owned
by the City of Manchester YMCA.

Geographical and Topographical Overview

Three major surface water bodies exist in the vicinity of the Site. The Merrimack River, located
approximately 500 feet east of the NHP Site, flows from north to south along the eastern boundary of the
study area. Horseshoe Pond, an oxbow lake located in a former channel of the Merrimack River, is a
recreational water body located on the southern boundary of the study area, approximately 600 feet south
of the Site. The east-flowing Souhegan River joins the Merrimack River approximately 1200 feet north of
the Site.

The Site is situated in an area with mixed land use, including light industries, commercial businesses,
and a few private residential dwellings. Most of the commercial and industrial facilities are situated
far from each other, and the properties are generally only moderately developed. Figure 2 depicts the
Site and some of the adjoining properties.

Several features located within the NHPC property include: the Operations Area, which encompasses the
former NHPC building (demolished in 1994); a parking lot; the solidified material storage cell (the
monolith); the pugmill area; and the lagoon system, which encompasses Lagoons 1, 2, 3, and 4, and the

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Northern and Southern Wetland and adjacent embankments and uplands. The lagoon system was a former
wetland of approximately three acres. A majority of the site (approximately 10.3 acres) is located within
the 100-year floodplain. These key Site features are depicted in Figure 3.

The land surface generally slopes downward from the Site to the southeast. The lowest topographic
features on the Site property are the former lagoons and wetland areas (at approximately 110 feet mean
sea level (MSL)). The Merrimack River is the lowest feature of the study area at approximately 90 feet
MSL.

The study area lies within the drainage basin of the Merrimack River and its tributaries. Surface water
from Horseshoe Pond flows into the Merrimack River through an outlet stream at the southeastern end of
the pond. Surface drainage within the study area is controlled primarily by topographic features. Because
the study area is predominantly unpaved, much of the surface water infiltrates directly into the
subsurface soils during light and moderate precipitation periods.

The subsurface soils encountered during the Remedial Investigation (RI), in order from ground surface to
bedrock, generally consist of alluvial sand deposits over glacio-lacustrine, glacial outwash, and glacial
till deposits. The lower permeability glacio-lacustrine deposits were observed in the subsurface soils
across much, but not all, of the study area. A bedrock trough, between the former NHP building and
Horseshoe Pond, oriented in an approximate north-south direction, extends across the southern portion of
the study area. The bedrock surface rises steeply in all directions away from the central bedrock low
area. Bedrock cores collected during the RI indicated that the dominant rock types encountered in the
study area were granite and granitic gneiss with some schist.

During the Remedial Investigation, three water bearing formations were identified in the study area:

• an unconfined shallow overburden aguifer that is generally situated between 5 and 40 feet below
ground surface, and is bounded at depth by lower permeability glacio-lacustrine soils;

• a deep overburden aguifer that is generally below the glacio-lacustrine soil unit within the
glacial outwash sand deposits. This aguifer is semi-confined by upper (glacio-lacustrine) and lower
(bedrock) hydraulic boundaries of less permeable formations over most of the study area, except
where the glacio-lacustrine soils are absent. It ranges between 10 and 75 feet thick across the
study area, showing a general trend of thinning toward downgradient locations adjacent to the
Merrimack River; and

• a bedrock aguifer that generally includes the entire bedrock section beneath the study area.

Groundwater within the shallow and deep overburden aguifers predominantly flows in a southeasterly and
easterly direction toward the Merrimack River. Horizontal flow within the bedrock aguifer appears to be
in an easterly direction toward the Merrimack River.

Upward vertical gradients were generally observed between these aguifers in the southern and eastern
portions of the study area. Downward vertical gradients occur in the northern and western portions of the
study area between the shallow and deep overburden aguifers.

A more complete description of the Site can be found in Section 3.0 of the Draft Final Remedial
Investigation Report for the New Hampshire Plating Company, Volume 1.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

NHPC operated an electroplating facility on the site from 1962 to 1985. The metals used in the
electroplating process included cadmium, zinc, chromium, copper, lead, nickel, tin, gold, silver,
aluminum, iron, and manganese. NHPC also used chlorinated organic solvents for de-greasing including:
trichloroethylene (TCE); 1,1,1-trichloroethane (TCA) ; and tetrachloroethylene (PCE) . Cyanide was also
used as part of the electroplating process. Chlorinated solvent use was reportedly discontinued during
the latter part of the 1970s.

Treated and untreated wastes and wastewater were discharged through a gravity-drained underground
discharge pipe into unlined waste lagoons located approximately 325 feet north of the building, These
lagoons occupy wetlands that developed naturally in a series of meander scars formed by the Merrimack
River. Wastes were discharged directly into a primary infiltration lagoon (Lagoon 1). The lagoon system
was constructed to allow the discharged wastes to overflow from the primary lagoon into a secondary
infiltration lagoon (Lagoon 2) and into subseguent overflow lagoons (Lagoons 3 and 4) during periods of

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high discharge from the facility. Approximately 35,000 to 60,000 gallons of wastewater were generated and
discharged to the lagoons each day.

In 1980, NHPC notified the EPA that it was a hazardous waste disposal facility in accordance with the
Resource and Conservation Recovery Act (RCRA) Section 3001 regulations and continued to operate under an
interim permit. As the result of inspections conducted by EPA and the New Hampshire Department of
Environmental Services (NHDES) between 1982 and 1985, NHPC received several Notices of Violation/Orders
of Abatement for failure to comply with RCRA transportation, storage, and disposal reguirements, and for
inadeguate treatment of its cyanide wastewater prior to discharge. Operations at NHPC ceased in November
1985.

In June 1987, the NHDES initiated interim remedial measures at the site. Wastes including plating
solutions, cyanide salts, and other materials were removed from the NHPC building. Sludge and sediment
were also removed from the building floors and disposed of at an approved off-site facility. The NHDES
also treated sludge and process wastewater in Lagoon 1 with approximately 127 tons of lime and 800
gallons of a sodium hypochlorite solution.

EPA initiated an emergency, removal action in October of 1989. After a preliminary study in the fall of
1990 and spring of 1991, EPA performed a limited on-site removal action. Approximately 13,600 tons of
sludges and soils were excavated, solidified on-site in an ash/mortar mixture, and encapsulated in a high
density polyethylene (HOPE) solidified material storage cell at a location immediately north of the
former NHPC building. Currently, this solidified monolith mass remains on site. An additional 5,000 tons
of soil were disposed off site at a secured landfill. As the last step of the removal action,
approximately 5,600 cubic yards of untreated soils excavated from the overflow lagoon areas were placed
in Lagoon 1. The soils were covered with an HOPE cap and approximately 2 feet of clean fill. The other
excavated lagoons were covered with between 1 to 2 feet of clean fill.

EPA also conducted a Non-Time-Critical Removal Action (NTCRA) at the NHPC building site in November and
December of 1994. Laboratory wastes left in the NHPC building were packed in drums and shipped off site
for disposal; asbestos-containing materials were removed; process eguipment and the building were
decontaminated; the building, floor slab, and foundation were demolished; an underground storage tank was
removed; the exposed soils were characterized; and the building footprint was graded and covered with a
geomembrane. Both non-hazardous and hazardous materials generated during the building removal were
disposed of off site.

A more complete description of the Site history can be found in Section 2.0 of the Draft Final Remedial
Investigation Report for the New Hampshire Plating Company, Volume 1.

B. Enforcement History

EPA initiated cost recovery activities during initial removal actions. On August 30, 1989, EPA sent
General Notice letters to the following persons who were identified as owners or operators at the Site:
1) Mr. Aldo Bracci and Mrs. Ida D. Bracci; 2) NHPC; and, 3) Mr. Jack 0. Labovitz (through his attorney)
to notify them of their potential liability as owners and or operators, and invited them to perform
proposed activities. On May 31, 1996, EPA notified Mr. Randall Bracci, son of Aldo Bracci, of his
potential liability as an operator at the Site. Mr. Aldo and Mrs. Ida Bracci and Mr. Randall Bracci
responded that they would like to help with the removal but were financially unable. Mr. Labovitz was
unresponsive. NHPC is no longer in operation and has no known assets. In 1985, the last tax return for
NHPC was filed and all on-site operations ceased. In 1991, NHPC was dissolved.

Adjacent businesses were also investigated to determine if they generated wastes which contributed to the
extent of groundwater contamination. It was subseguently determined that the only PRPs are the former
owner/operators. Their liability is clear and has been well documented. However, a cost-recovery case was
determined to not be viable because the PRPs were insolvent and did not have the financial ability to
contribute significantly to past or future expenditures. The Bracci's sued their insurance company for
coverage but lost the case. There are no transporters or generators associated with the Site.

A decision not to pursue costs was documented in a Cost-Recovery Closeout Memorandum approved by the
Office of Site Remediation and Restoration Division Director on December 30, 1996. The Cost-Recovery
Closeout Memorandum contains extensive detail on the PRP search efforts completed by OSRR and financial
ability-to-pay analysis conducted by OES. This decision applies to all past and future costs.

III. COMMUNITY PARTICIPATION

Throughout the Site's history, community concern has been present in varying degrees of involvement. EPA
has kept the community and other interested parties apprised of the Site activities through informational

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meetings, fact sheets, press releases and public meetings.

On February 26, 1993, EPA released a community relations plan which outlined a program to address
community concerns and keep citizens informed about and involved in activities during remedial
activities. On June 13, 1990, EPA held an informational meeting at the Merrimack Court House to describe
plans for completing emergency removal activities and placing the Site on the National Priorities List to
perform a Remedial Investigation and Feasibility Study. On June 9, 1993, EPA held an informational
meeting at the Merrimack Court House to discuss ongoing Remedial Investigation activities and present a
schedule for completion.

On January 15, 1998, EPA made the Administrative Record, including the Remedial Investigation Report,
Feasibility Study Report and Proposed Plan, available for public review at EPA' s offices in Boston and at
the Merrimack Public Library. The Administrative Record Index is attached in Appendix C and contains a
complete listing of all documents used to support this ROD. EPA published a notice and brief analysis of
the Proposed Plan in four local newspapers; the Village Crier, the Nashua Telegraph, the Manchester Union
Leader and the Broadcaster between January 5 and 7, 1998, and made the plan available to the public at
the Merrimack Public Library.

On January 15, 1998, 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. Also during this meeting, the Agency answered guestions from the public. From January 16
to February 14, 1998, the Agency held a thirty (30) day public comment period to accept community
feedback on the alternatives presented in the Feasibility Study and the Proposed Plan and on any other
documents previously released to the public. On January 28, 1998, the Agency held a formal public hearing
to discuss the Proposed Plan and to accept any oral comments. A transcript of this hearing and the
comments and the Agency's written response to comments are included in the attached Responsiveness
Summary  (Appendix B).

IV. SCOPE AND ROIiE OF RESPONSE ACTION

As discussed in Section II.A above, several removal actions have been performed at the Site to stabilize
conditions. The remedial action authorized by this ROD addresses the remaining contaminated soil and
groundwater and is the final response action anticipated for the NHP Site.

The selected remedy was developed by combining components of different source control and management of
migration alternatives to obtain a comprehensive approach for Site remediation, In summary, the remedy
provides for the on-site treatment of about 40,000 cubic yards of metal contaminated soils by chemical
fixation. Treated soils will be consolidated and deposited into former Lagoons 1 and 2. The temporary
storage unit  (monolith) materials will be crushed, mixed with the treated soils and placed in former
Lagoons 1 and 2. The backfilled areas will be covered with 18 inches of off-site fill and six inches of
top soil. Excavated areas will be regraded using existing remaining materials. All disturbed areas will
be re-vegetated with wetland-type vegetation. Former lagoon areas were previously functioning wetlands.

Since the entire lagoon system will reguire significant excavation and grading and treated materials will
remain on-site, restoration of on-site wetlands is not possible. Therefore, off-site mitigation will be
performed to compensate for unavoidable impacts to the 2.8 acre wetland.

With the source area remediated, metal and volatile organic compound (VOC) contamination in groundwater
will attenuate. A New Hampshire Groundwater Management Zone will be established to define a monitoring
program and ensure public awareness of the contamination. Institutional controls will include groundwater
and land use restrictions.

This approach will eliminate leaching to groundwater, address unacceptable risks to burrowing animal
species, and restore the groundwater guality to acceptable levels.

V. SUMMARY OF SITE CHARACTERISTICS

Section 1.0 of the Feasibility Study (FS) contains an overview of the Remedial Investigation. The
significant findings of the Remedial Investigation are summarized below.

The contaminants detected within the NHP Site study area correspond to the known plating effluent
constituents. These contaminants include metals (cadmium, zinc, chromium, lead, nickel, copper, and tin),
chlorinated solvents,  (PCE, TCE and its degradation products), and cyanide. Low levels of semivolatile
organic compounds (SVOCs) were also infreguently detected, but are not believed to be associated with
facility operations.

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A. Sources of Contamination

The historic sources of metals, cyanide, and VOCs at the Site are:

• effluent from the discharge trenches within the building;

• effluent from the overflow pipes along the north wall of the building;

• discharge of effluent to Lagoon 1;

• overflow of effluent from Lagoon 1 into Lagoons 2, 3, and 4; and

• overflow of effluent from the lagoons to adjacent wetlands and soils.

The results of the Remedial Investigation conclude that the current residual sources of metal and cyanide
contamination are:

• surface and subsurface soils in the Lagoon 1 area;

• surface and subsurface soils in the embankments and basins of Lagoons 2, 3, and 4; the
Southern Wetland; the Northern Wetland; and the Lagoon 4 overflow areas; and

• to a lesser extent, subsurface soils in the building area.

Lagoon 1 soils contain the highest levels of metal contamination in the study area and are the largest
residual source of groundwater contamination.

Several VOCs, semi-VOCs and pesticides were sporadically detected throughout the study area but were
determined to be at concentrations well below a level of concern and are not contributing sources of
groundwater contamination. No residual source of VOC contamination was found in on-site soils except
that, subsurface soils below the water table in the Lagoon 1 area are likely desorbing chlorinated VOC
contamination to the groundwater. Cadmium and other metals and chlorinated VOCs in groundwater are
migrating east and southeast in the shallow overburden aguifer and are likely discharging to the
Merrimack River.

A more detailed discussion of the Remedial Investigation results by media follows.

B. Soils

To provide a better understanding of metal contamination remaining in on-site soils, the 13.9 acre study
area was subdivided into specific known or suspected source areas as presented below. These areas are
generally described as the former operations area, the former lagoon areas and wetland areas. Refer to
attached Figure 3 to locate the specific areas presented below. The metals detected above background
concentrations were cadmium, chromium, copper, lead, nickel, tin, and zinc. Cyanide was also detected.
Arsenic, beryllium, cadmium, chromium, cyanide, lead, manganese and nickel were subseguently concluded to
be the contaminants of concern for soils.

Cadmium was generally detected more freguently and at higher concentrations than any of the other metals
and was subseguently determined to be the most toxic contaminant. Therefore, the discussion below focuses
primarily on cadmium. Estimates of contaminated soil volumes are based on cadmium. The remedial action
implemented for cadmium-based volumes of soil will adeguately address the risks presented by other
contaminants. The entire site lies within the 100 year floodplain. Refer to attached Table 1 for a
summary of soil analytical results.

Former Operations Area

This area refers to parcel 1 and includes the former building and related parking area and the area
currently covered by the solidified material storage cell or monolith.

Residual levels of metals in soils were found along the northern side of the former building, where the
overflow pipes discharged through the building wall. Contamination was generally higher in the surface
soil (0 - 1'), and decreased with depth. The highest level of cadmium detected was 172 mg/kg from a
location beneath the former discharge trench, where plating effluent exited the building.

Detectable levels of cyanide were found in 21 soils samples taken from the building area. The highest
level of cyanide detected was 87.7 mg/kg.

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In total, an estimated 5,926 cubic yards of contaminated soils are present in the former building area to
an average depth of 10 feet.

VOC field screening results indicated the presence of TCE; trans-1,2-dichloroethene (T-DCE); TCA, PCE;
and benzene around the building; and TCE in the vicinity of the former septic system. No appreciable
levels of VOCs in soil samples were detected by laboratory analysis.

The extent of contamination present underneath the solidified material storage cell, if any, could not be
evaluated during the RI. The former discharge pipe passed through this area and as a result, could have
released contamination. Therefore, these soils will be tested for contaminants of concern as part of the
selected remedy and may result in an increase soil volume requiring remediation from this area.

Former Lagoon Areas

This area refers to the four former discharge lagoons (1, 2, 3, and 4) on parcel 2, which were the
subject of a major EPA emergency removal action in 1990 to 1991 (see attached Figure 3). That action
included the removal of contaminated soils and sludges from the lagoon areas. An average of two feet of
clean fill was regraded over the entire lagoon area following the removal. Prior to their use for
effluent discharge by NHPC, these lagoons constituted a significant portion of a much larger wetland area
which joined the northern and southern wetland areas remaining on-site. The northern and southern wetland
areas were not part of the original lagoon system and were not remediated during the EPA removal action.

Each of the four lagoons were separated by berms and would sequentially receive discharge from Lagoon 1
to Lagoon 4 as the system reached capacity. The contaminated soil volume estimates below include the
affected bermed areas and adjacent embankments.

Lagoon 1

High concentrations of cadmium and zinc were detected in Lagoon 1 soils, with generally the highest
levels of cadmium (623 mg/kg) in subsurface soils from the embankments and from the backfilled soils.
Their presence in the lagoon embankments suggests that plating effluent may have infiltrated these areas
in a lateral pattern. Their presence in the surface soils suggests that plating effluent from the lagoon
periodically overflowed to perimeter areas. Metal contamination, detected in both surface and subsurface
soils in the southwest corner of the Lagoon 1 area, indicates that plating effluent overflowed and/or
infiltrated laterally southwest of the former lagoon to the topographically lower Southern Wetland area.

Metals present in the formerly remediated and filled portion of the Lagoon 1 area indicates that their
concentrations in the contaminated soil fill are generally homogeneous. The concentrations decrease with
depth below the contaminated fill in soil samples that entirely penetrate the undisturbed soils beneath
the fill.

Cyanide was detected in 11 of 13 soil samples; 10 were collected within the contaminated fill soils. The
highest level of cyanide detected was 59.9 mg/kg.

In total, an estimated 8,416 cubic yards of contaminated soils are present in the former Lagoon 1 area to
an average depth of 10 feet.

Although some VOCs were detected during field screening of Lagoon 1 soils, no appreciable site-related
chlorinated VOCs were detected in laboratory samples from any of the lagoons.

Lagoon 2

The lateral distribution of cadmium and zinc reveals that both surface and subsurface soils in the former
lagoon 2 and its embankments have been contaminated. Cadmium concentrations ranged from 8 to 733 mg/kg,
with the highest levels detected in the southeastern and northwestern corners of the former lagoon.

High concentrations of cadmium and zinc were found within 0 to 6 feet below ground surface in the
embankment area soils. Within the formerly remediated and filled portion of the Lagoon 2 area,
concentrations generally decreased with depth below the fill. High concentrations of metals were
encountered in the shallow subsurface soil beneath the fill. In general, metal concentrations decreased
to non-detection within 0 to 2-feet depth below the fill, although high target metal concentrations were
found at several sampling locations, in subsurface soils up to 8 feet below the fill.

Detectable concentrations of cyanide were found in eight of eleven soil samples, with 74.6 mg/kg the
highest level detected.

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In total, an estimated 10,271 cubic yards of contaminated soils are present in the former Lagoon 2 area
to an average depth of 6 feet.

Lagoons 3 and 4 and Lagoon 4 Overflow Area

The characteristics of Lagoons 3 and 4 were determined to be sufficiently similar; therefore they are
jointly discussed. The Lagoon 4 overflow area is located in a low lying area on the eastern side of the
former lagoon system near the site boundary with Jones Chemical, Inc. Surface soils in the southwest
corner and along the western side of the overflow area have been affected by metals from NHPC waste
disposal operations. In the overflow area, metal concentrations decrease to non-detectable concentrations
below the 1 foot depth.

Cadmium concentrations detected ranged from 6 to 1,277 mg/kg, with the highest concentration detected in
shallow subsurface soils located beneath the clean fill near the embankment that separates Lagoon 2 from
Lagoons 3 and 4. This concentration is the highest level of cadmium found anywhere within the NHPC
property.

High concentrations of the metal contaminants of concern were also detected in the embankment surface
soils. High concentrations of target metals in the soil berm that separates Lagoons 3 and 4 from the
Northern Wetland reveals that overflow of lagoon effluent occurred between Lagoons 3 and 4, and the
topographically lower Northern Wetland.

Metals are present at shallow depths in both the embankment and interior of the Lagoon 3 and 4 area.

Cyanide was found in 11 of the 20 soil samples. The highest level of cyanide detected in Lagoons 3 and 4
was 247 mg/kg.

In total, an estimated 10,361 cubic yards of contaminated soils are present in the former Lagoon 3 and 4
and Lagoon 4 overflow areas. The average depth of contaminated soils is 5.5 feet in Lagoons 3 and 4 and 1
foot in the Lagoon 4 overflow area.

Wetland Areas

The two remaining wetland areas on site, the northern and southern wetlands, were not part of the
original lagoon system. However, these wetland areas were affected by effluent discharge when the storage
capacity of the lagoon system was periodically exceeded, resulting in overflow to the topographically
lower northern and southern wetlands.

Southern Wetland Area

Overflow from the former lagoon system has contaminated the surface and shallow subsurface soils
throughout the southern wetland area. High metal concentrations in the surface soils along the western
edge of the wetland also indicate that past vehicle decontamination activities performed during the EPA
removal action may have contributed to the area's metal contamination.

High concentrations of cadmium and zinc were found in surface soils within the southern wetland area,
with cadmium concentrations ranging from 12 to 728 mg/kg. The highest cadmium concentrations were
detected in surface soils in the eastern and northern portions of the wetland. Sample locations along the
northern side of the wetland and within the roadway area also indicated high concentrations of cadmium
and zinc in the soils beneath the crushed stone road base fill.

Other target metals detected were not widespread except for chromium and tin. Cadmium and zinc decreased
to lower concentrations at depths greater than 4 feet below ground surface for most of the soil boring
locations in the wetland area.

Cyanide was detected in seven of ten soil samples collected, with the highest level of 509 mg/kg. This
surface soil sample contained the highest detected level of cyanide on-site.

In total, an estimated 3,715 cubic yards of contaminated soils are present in the southern wetland area
to an average depth of 8.5 feet.

Northern Wetland Area

Overflow effluent from the former lagoon system delivered metals to shallow soils throughout the area.
Cadmium concentrations ranged from 7 to 286 mg/kg, all in surface soil.

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SVOCs were sporadically detected in the Northern Wetland. These contaminants were found at low levels and
are believed to have originated in storm water runoff west of the site.

Cyanide was detected in nine of twelve soil samples. The highest level of cyanide detected was 21.5
mg/kg.

In total, an estimated 2,621 cubic yards of contaminated soils are present in the northern wetland area
to an average depth of 2 feet.

C. Groundwater

Contaminated groundwater has migrated under adjacent properties and is generally bound by the NHPC
property boundary to the north and west, Horseshoe Pond to the south and the Merrimack River to the east.
Known off-site properties effected by contaminated groundwater are the YMCA, Jones Chemical, New England
Pole, Techwood Systems, Inc. and Lot 22. Groundwater in this area exceeds Maximum Contaminant Levels
(MCLs).

In summary, eight VOCs were detected in groundwater at concentrations which exceed MCLs. These include:
TCE; 1,1-dichloroethene (DCE) ; PCE; vinyl chloride (VC); TCA; cis- and trans-1,2-dichloroethene (C&T
DCE); 1,2-dichloroethane (1,2-DCA); and chloroform. Five metals were also detected in the groundwater
above the established MCLs, including cadmium, nickel, chromium, arsenic, and lead. TCE and cadmium were
the contaminants that most freguently exceeded their respective MCLs of 5 ug/L.

Groundwater contamination was detected in all three aguifers. However, the levels of contamination in the
deep overburden were significantly less than in the shallow overburden, while the bedrock aguifer was
relatively unaffected. Metal contamination is present only in the shallow overburden aguifer.

To provide a better understanding of groundwater contamination which has originated from the site, the
discussion below is by aguifer: shallow overburden, deep overburden and bedrock. Figure 4 presents the
portions of the overburden aguifer where contaminants were detected in excess of MCLs. Attached Table 2
contains a summary of groundwater analytical results.

Shallow Overburden Aquifer

Two VOCs (TCE and DCE) were detected above their MCLs within the northern half of the YMCA property
situated to the south of the former operations area; six VOCs (TCE, DCE, PCE, TCA, C&T DCE, and VC) were
detected above their MCLs within the former operations area; and five VOCs (TCE, DCE, PCE, TCA, and VC)
were detected above their MCLs downgradient of the former operations area. The highest level of VOC
contamination (7500 ug/L of TCE) was found at well MW-217S, within the former operations area,
immediately adjacent to Lagoon 1. VOC levels decrease with distance from the Lagoon 1 area.

One well located on the western side of the YMCA property had a cadmium level exceeding MCLs. Twelve
wells in the former operations area had elevated concentrations of cadmium, nickel, arsenic, lead, and
chromium. Samples from seven monitoring wells located in the downgradient portions of the NHPC study area
indicated cadmium, nickel, and chromium at elevated concentrations. The highest level of metal
contamination (1,290 ug/L of cadmium) was found at well OHM-3, on the Jones Chemical, Inc. property,
immediately downgradient of Lagoon 1.

In total, there is an estimated 3,343,620 cubic feet of contaminated groundwater in the shallow
overburden aguifer.

Deep Overburden Aquifer

Only TCE was detected in excess of its MCL in two deep overburden monitoring wells within the YMCA
property south of the former operations area. Monitoring well MW-106, located adjacent to Horseshoe Pond
on the southern portion of the YMCA property, had the highest concentration of TCE (220 ug/L) observed in
the deep overburden aguifer within the NHPC study area. Four deep overburden monitoring wells in the
former operations area indicated VOC concentrations exceeding MCLs. TCE and chloroform were the only VOCs
detected at elevated concentrations from these wells. Five of six wells downgradient of the former
operations area revealed TCE and C&T-DCE at levels above MCLs.

None of the deep overburden aguifer wells yielded groundwater samples with metals exceeding MCLs.

In total, there is an estimated 14,074,930 cubic feet of contaminated groundwater in the deep overburden
aguifer.

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Bedrock Aquifer

One VOC (TCE at 180 ug/L) was detected above its MCL in well MW-106R, adjacent to Horseshoe Pond on the
southern side of the YMCA property. TCE was also detected at elevated concentrations in bedrock wells,
within the former operations area. The results of the chemical analyses for three wells downgradient of
the former operations area indicated the presence of TCE above its MCL in only one of them.

None of the bedrock aguifer wells yielded groundwater samples with metal levels in excess MCLs.

D. Surface Water and Sediments

Surface water and sediment samples were collected and analyzed for VOCs, SVOCs, metals and cyanide from
Horseshoe Pond and the Merrimack River. Based on results, it does not appear that detectable
concentrations of site contaminants are discharging to Horseshoe Pond or the Merrimack River. No
contaminants were detected in either surface water body. Several sediment samples contained detectable
concentrations of VOCs, SVOCs and metals; however, the risk assessment concluded that these levels were
below a level of human health or ecological concern.

Horseshoe Pond

VOCs were not detected in any of the surface water samples; however, VOCs were detected in five of the
seven sediment samples. Four VOCs detected in these samples include: 2-butanone (methyl ethyl ketone
(MEK)); acetone; TCA; and carbon disulfide. Based on the absence of these compounds in groundwater which
would act as the migration pathway between the site and the pond, it does not appear that these sediment
VOCs are related to the former site operations.

The only sediment sample analyzed for SVOCs was collected on the eastern shore; it contained several
polynuclear aromatic hydrocarbons (PAHs) typically associated with fuels, oils, and other
petroleum-related compounds and is not a site-related contaminant. One phthalate was also detected in the
sample.

Sediment samples containing arsenic, chromium, copper, nickel, and zinc were detected at concentrations
approximately 25 to 40% above background levels in two samples. Based on the absence of these metals in
groundwater between the site and Horseshoe Pond, it does not appear that sediment metals are related to
the former site operations.

Merrimack River

VOCs were not detected in any of the surface water or sediment samples. Chromium was detected in one
sediment sample, however, no other metals were present.

A complete discussion of site characteristics can be found in Sections 3.0 and 4.0 of the Draft Final
Remedial Investigation Report.

VI. SUMMARY OF SITE RISKS

A Baseline Human Health and Ecological Risk Assessment (RA) was performed to estimate the probability and
magnitude of potential adverse human health and environmental effects from exposure to contaminants
associated with the Site. The human health risk assessment followed a four step process: 1) contaminant
identification, which identified those hazardous substances which, given the specifics of the Site, were
of significant concern; 2) exposure assessment, which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined the extent of possible exposure; 3)
toxicity assessment, which considered the types and magnitude of adverse health effects associated with
exposure to hazardous substances, and 4) risk characterization, which integrated the three earlier steps
to summarize the potential and actual health risks posed by hazardous substances at the Site, including
carcinogenic and non-carcinogenic risks. The results of the human health risk assessment for the New
Hampshire Plating Superfund Site are discussed below, followed by the conclusions of the ecological risk
assessment.

Human Health Risk Assessment

Forty-five (45) contaminants of concern (COCs) , listed in Tables 3 and 4 of this Record of Decision for
soil and groundwater respectively, were selected for evaluation in the human health risk assessment.
These contaminants constitute a representative subset of the more than one-hundred (100) contaminants
identified in soil, groundwater and/or sediments at the Site during the Remedial Investigation. The
forty-five (45) contaminants of concern were selected to represent potential site related hazards based

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on toxicity, concentration, frequency of detection, and mobility and persistence in the environment. A
summary of the health effects of each of the contaminants of concern can be found in Section 6.2.2 of the
human health risk assessment contained in the Draft Final Remedial Investigation Report.

Potential human health effects associated with exposure to the contaminants of concern were estimated
quantitatively or qualitatively through the development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to hazardous substances by media based on
the present uses, potential future uses, and location of the Site.

The New Hampshire Plating Site is located in a predominately industrial area. Although commercial uses
are most common, some residential and undeveloped lots do exist in the immediate area. This mixed
land-use required the risk assessment to consider residential, trespasser and industrial scenarios to
fully evaluate exposure pathways for various media. The following is a brief summary of the exposure
pathways evaluated. A more thorough description can be found in Section 6.43 of the human health risk
assessment.

Soil Exposure Pathways

Potential current and future trespassing, future residential and future worker scenarios were evaluated
for exposure to contaminated soils. Potential exposures evaluated were incidental ingestion of soil and
dermal absorption of contaminants. Ingestion was evaluated for a 15 kg child (1-6 years) who may ingest
200 mg/day of soil over 150 days/year for 6 years. Trespasser, residential and industrial ingestion was
evaluated for a 70 kg adult who may ingest 100 mg/day of soil over 52 to 150 days/year for 10 to 25
years. Absorption was also evaluated for the above pathways. The hazard indices in the baseline risk
assessment and FS were re-calculated as shown in Table 5 using the revised dermal adherence factor of
0.23. The dermal factor used in the baseline risk assessment was 1.0. This resulted in slightly lower
hazard indices. This change does not effect cleanup goals.

Groundwater Exposure Pathways

The potential risks from future residential use of contaminated groundwater were evaluated. Ingestion of
groundwater for 350 days/year over 30 years was assumed. Small children (15 kg) were assumed to ingest 1
liter/day and adults (70 kg) were assumed to ingest 2 liters/day.

Sediment Exposure Pathway

Potential risks under current and future trespassing and future recreational land use were evaluated.
Potential exposures evaluated were incidental ingestion of soil and dermal absorption of contaminants. It
was assumed that older children (40 kg body weight and 6-12 years old) and adults (70 kg body weight) may
incidentally ingest lOOmg/day of contaminated sediment for 24 days/year.

There are no exposure pathways for surface water or air since these media were not impacted by the
release. For each pathway evaluated, a central tendency (CT) or average and a reasonable maximum exposure
(RUE) estimate were generated corresponding to exposure to the average and the maximum concentration
detected in that particular medium.

Human Health Risk Assessment Conclusions

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level
with the chemical specific cancer factor. Cancer slope 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 than a one in a million chance of developing cancer over 70 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,
such as are present at the Site.

The hazard index was also calculated for each pathway as EPA's measure of the potential for
non-carcinogenic health effects. A hazard quotient 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 quotient is
often expressed as a single value (e.g., 0.3) indicating the ratio of the stated exposure as defined to

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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 quotient 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 quotient for a compound known to produce liver damaqe should not be added
to a second whose toxic endpoint is kidney damaqe).

Table 5 depicts the carcinoqenic and non-carcinoqenic risk summary results for present and potential
future exposure to soil contaminants correspondinq to the central tendency (CT) and the reasonable
maximum exposure (RME) scenarios. The results are presented for each of the tarqet areas of the Site
identified in Section V above. Tables 6-10A throuqh 6-19B in Volume 2 of the Draft Final Remedial
Investiqation Report depict the CT and RME results for each contaminant of concern.

Attached Table 6 depicts the carcinoqenic and non-carcinoqenic risk summary results for present and
potential future exposure to qroundwater contaminants correspondinq to the central tendency (CT) and the
reasonable maximum exposure (RME) scenarios. Tables 6-20A throuqh 6-23D in Volume 2 of the Draft Final
Remedial Investiqation Report depict the CT and RNE results for each contaminant of concern.

The followinq bullets best summarize the results of the baseline human health risk assessment for the
Site:

• For soils, carcinoqenic risk estimates are within or less than EPA's acceptable risk ranqe of 1 x
10 -4 to 1 x 10 -6. Non-carcinoqenic risk estimates for cadmium exceed EPA's hazard index benchmark
(acceptable threshold) of 1.0 for an RME receptor assuminq industrial or trespasser land-use
scenarios at Laqoons 3 and 4.

• For qroundwater, several volatile orqanic compounds (VOCs) and inorqanics (metals) exceed
Federal maximum contaminant levels (MCLs), primarily in the shallow overburden aquifer. Under
potential future use, if qroundwater were inqested, the carcinoqenic risk estimates ranqe from 1.4
x 10 -2 to 1. 7 x 10 -3. Hazard indices for non-carcinoqenic risks ranqe from 140 for the RME
scenario to 99 for the CT scenario.

• For Horseshoe Pond and Merrimack River sediments, the RME carcinoqenic risk estimate for
a recreational user was 2 x 10 -6. The hazard index for all non-carcinoqenic risk estimates is less
than the benchmark of 1.0. These results indicate that no adverse effects are present from dermal
contact with or inadvertent inqestion of sediments.

Baseline Ecological Risk Assessment

Cadmium was selected as the contaminant of concern based on its toxicity and hiqh bioaccumulation
potential. Cadmium also had a hiqh frequency of detection and was qenerally co-located with other
contaminants. Potential ecoloqical risks associated with exposure to cadmium in laqoon soils were
evaluated for several tarqet species. No exposure pathways were evaluated for other media based on the
limited presence of either habitat or contaminants as explained in Section 7.0 of the Draft Final
Remedial Investiqation Report.

Five indicator species were selected for the ecoloqical risk assessment, and a conceptual food web model
was prepared to represent the bioaccumulation pathway at the site. The food web model was the basis for
the calculation of cadmium soil concentrations above which adverse effects on the indicator species are
expected to occur.

Of the five indicator species, the short-tailed shrew was found to be at the qreatest risk of adverse
effects from cadmium concentrations, in the soil. For this indicator species, cadmium concentrations
above 5.6 mq/kq in 0'- 2' deep soils would be expected to have a detrimental impact.

The ecoloqical risk assessment concluded that site soils throuqhout the wetlands-laqoons system pose
probable adverse ecoloqical effects due to cadmium contamination.

Overall Risk Assessment Conclusion

Actual or threatened releases of hazardous substances from this site, if not addressed by implementinq
the response action selected in this ROD, may present an imminent and substantial endanqerment to public
health, welfare, or the environment. Soil and qroundwater both require remediation to address public
health or ecoloqical risk concerns. The basis for soil remediation is to address existinq unacceptable
ecoloqical threats to local species and eliminate onqoinq contribution to qroundwater contamination
throuqh leachinq of metal contaminants to soil. The basis for qroundwater remediation is unacceptable
human health risks and exceedances of MCLs.

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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 of 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 formed to aid in the development and
screening of alternatives to mitigate existing and future potential threats to public health and the
environment.

The remedial action objectives for soil are:

    •  minimize contaminant leaching from soils that would result in groundwater contamination
      exceeding MCLs, state ambient groundwater quality standards  (AGQS),  or acceptable
      human-health based levels; and

    •  prevent contact by ecological receptors with soils having contaminant concentrations
      exceeding the ecological risk-based performance remedial goals (PRGs).

The remedial action objectives for groundwater are:

    •  prevent ingestion of groundwater containing contaminants at concentrations exceeding
      drinking water criteria;

    •  minimize off-site migration of contaminants in the groundwater; and

    •  minimize discharge of contaminated groundwater to the Merrimack River.

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 were developed for the site.

With respect to source control, the 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 Section 2.5 of the Feasibility Study Report, several soil and groundwater treatment
technologies were identified, assessed and screened based on implementability, effectiveness, and cost.
These technologies were combined into source control (SC)  and management of migration (MOM) alternatives.
Section 3.0 of the Feasibility Study Report presents the development of SC and MOM alternatives through
the combination of technologies identified in the previous screening process and consistent with Section
300.430(e)(3) of the NCP. Generally, the purpose of the initial screening process is to narrow the number
of potential remedial actions for further detailed analysis while preserving a range of options. Each
formulated alternative is then evaluated and screened again to assemble the final alternatives for
detailed analysis. As discussed in Section 3.4 of the Feasibility Study Report, this tiered alternative
screening approach was not necessary since, in an effort to streamline the FS, only a limited number of

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alternatives were initially developed based on acceptable technologies. Refer to attached Table 7A for a
summary of the five source control alternatives and Table 7B for a summary of the three management of
migration alternatives which were presented for detailed analysis.

VIII. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each alternative evaluated.

A. Source Control (SC) Alternatives Analyzed

The source control alternatives analyzed for the Site include: No-Action (SC-1); Excavation,
Consolidation and Capping  (SC-2); Excavation, Solidification and Off-site Disposal (SC-3); Excavation and
Off-site Disposal (SC-4); and Chemical Fixation and On-site Backfilling (SC-5).

SC-1 No-Action

The No Action Alternative is developed as a baseline case. The only activities that would be conducted
under this alternative are minimal long-term monitoring of groundwater to evaluate potential soil
contaminant leaching and migration. The purpose of the alternative is to evaluate the overall ecological
receptor and environmental protection provided by the NHPC Site in its present state. Under this
alternative, no remedial actions would be taken to reduce or minimize contaminant leaching or protect
ecological receptors. No measures would be implemented to prevent potential exposures of biota to
contaminated lagoon soils. The solidified monolith would remain on site and would not be addressed.
Because the monolith would remain in place, approximately half of the NHPC property would not be suitable
for future reuse.

    •  Contaminants would remain in place and continue to migrate to groundwater.
    •  Minimal groundwater monitoring would be performed.
    •  No institutional controls would be established.

ESTIMATED NET-PRESENT WORTH COST IS:            $714,100

    •  This alternative is a baseline against which other cleanup alternatives are compared. It is not
      protective and does not meet applicable or relevant and appropriate requirements  (ARARs).

SC-2 Consolidation and Capping

Soils which exceed PRGs for groundwater leaching and ecological risk and which fail TCLP, or other
suitable leaching test, would be excavated from the former building area,  Lagoons 1,  2, 3 and 4, and the
Northern and Southern wetlands. Closure and post-closure plans would be prepared to comply with RCRA
hazardous waste surface impoundment closure requirements in case not all contaminated subsurface soils
can be practicably excavated. Excavated soils would be consolidated into lagoons 1 and 2, which would be
lined in compliance with RCRA hazardous waste regulations. The temporary storage area would be crushed
and added to the consolidated soil. Consolidated areas would be lined and capped and a leachate detection
system established to meet RCRA closure requirements.

Since the lagoon system represents a 2.8 acre wetland area and remediation impacts are unavoidable,
mitigation would be performed through the preservation of off-site wetlands. Institutional controls would
be established to restrict excavation through the cap and limit land-uses to industrial applications.

    •  41,300 yds 3 of soil would be excavated and capped in the former lagoons 1 and 2 area.
    •  The temporary holding cell storage material (7,875 yds 3) would be crushed, consolidated
      with the treated soil and capped.
    •  The finer and cap would conform with RCRA Subtitle C requirements.
    •  The former building and holding cell excavated areas would be backfilled with clean material
      and vegetated to prevent erosion.
    •  The former lagoons 3 and 4 and the northern and southern wetland areas would be backfilled
      with a minimal amount of clean material (
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ESTIMATED TIME FOR REQUIRED CONSTRUCTION IS:    24 to 30 months
ESTIMATED TIME REQUIRED TO ACHIEVE PRGs IS:     24 to 30 months
ESTIMATED NET-PRESENT WORTH COST IS:            $7,267,800

SC-3 Excavation. Solidification and Off-Site Disposal

Alternative SC-3 features excavation of contaminated soils, on-site solidification of soils to stabilize
metals, and off-site disposal in a solid waste landfill. Alternative SC-3 would reduce contaminant
leaching to groundwater  (thus protecting human health),  and prevent potential ecological receptor
exposures. The soils containing contaminants in excess of PRGs for groundwater leaching and ecological
risks and which fail TCLP, or other suitable leaching test, would be excavated from the former building
area, the lagoons, and wetlands, and staged on site for treatment. Closure and post-closure plans would
be prepared to comply with RCRA hazardous waste surface impoundment closure reguirements in case not all
contaminated subsurface soils can be practicably excavated. Cadmium and other metals would be solidified
in a soil-cement matrix to immobilize the metals and minimize the leaching of these contaminants.
After solidification, the treated soils would be sent off site for disposal. The solidified soil-cement
matrix would be cured as a soil-like material rather than as a monolithic mass to facilitate subseguent
handling and backfilling. Materials resistant to treatment would be sent off-site for disposal. The
existing monolith would be demolished,  crushed and sent off-site.

The area encompassed by the existing Northern and Southern Wetlands, and Lagoons 1, 2, 3,  and 4 would be
restored on-site as wetlands. Institutional controls would be established to limit land- uses to
industrial applications and preserve the restored wetland.

    •  41,300 yds 3 of soil would be excavated and solidified.
    •  The treated soil would be disposed off-site at a Subtitle D solid waste facility. Some
       materials may  reguire  disposal at  a  Subtitle C facility.
    •  The temporary holding cell storage material (7,875 yds 3) would be crushed and disposed
       at  a  Subtitle  C  or D facility, as  appropriate.
    •  The former building and holding cell excavated areas would be backfilled with clean
       material  and vegetated to prevent  erosion.
    •  The former lagoons 1,  2, 3 and 4 and the northern and southern wetland areas would be
       backfilled, graded and vegetated to  restore to a  natural wetland  condition.
    •  The Site lies within the 100 year floodplain.  Flood storage capacity would be maintained
       through re-creation of the wetland area.
    •  Institutional controls would be established to restrict activities to commercial/industrial on
      Parcel 1 and preserve the wetland area on Parcel 2.

ESTIMATED TIME FOR REQUIRED CONSTRUCTION IS:    29 to 35 months
ESTIMATED TIME REQUIRED TO ACHIEVE PRGs IS:     29 to 35 months
ESTIMATED NET-PRESENT WORTH COST IS:            $23,693,000  (assumes all disposal is at a Subtitle D
                                                facility)

SC-4 Excavation and Off-Site Treatment and Disposal

Alternative SC-4 features the excavation and off-site disposal of contaminated soils in a suitable
treatment, storage and disposal (TSD)  facility. Alternative SC-4 is similar to SC-3; the primary
difference is that under SC-4, treatment would be conducted at the TSD facility rather than on site.
Based on the leachability of metals from the site soils, solidification at the TSD facility would be
reguired prior to land disposal. Alternative SC-4 would reduce or minimize contaminant leaching to
groundwater, thus protecting human health,  and prevent potential ecological receptor exposures to
contaminants. The soils containing contaminants in excess of PRGs for groundwater leaching and ecological
risk and which fail TCLP, or other suitable leaching test, would be excavated from the former building
area, the lagoons, and wetlands and staged on site,  loaded into trucks,  and shipped off site for
treatment and disposal. Closure and post-closure plans would be prepared to comply with RCRA hazardous
waste surface impoundment closure reguirements in case not all contaminated subsurface soils can be
practicably excavated.

The monolith would be demolished and sent off-site for disposal at a Subtitle C or D facility, as
appropriate. Treatment should not be necessary since solidification has already been performed. The
excavated areas would be backfilled with clean fill and regraded. The area encompassed by the existing
Northern and Southern Wetlands and the lagoon system would be restored as wetlands. Institutional
controls would be established to limit land-uses to industrial applications and preserve the restored
wetland.
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    •  41,300 yds 3 of soil would be excavated and treated and disposed off-site.
    •  The excavated soil would be transported to an off-site TSD facility. The TSD would treat
       and/or dispose  the  soil  as  appropriate.
    •  The temporary holding cell storage material (7,875 yds 3)  would be crushed and
       transported  to  a  Subtitle D  facility  for  solid waste  disposal.  Some material may  reguire
       shipment  to  the TSD facility for  off-site treatment.
    •  The former building and holding cell excavated areas would be backfilled with clean
       material  and vegetated to prevent erosion.
    •  The former lagoons 1, 2,  3 and 4 and the northern and southern wetland areas would be
       backfilled,  graded  and vegetated  to restore to a  natural wetland  condition.
    •  The Site lies within the 100 year floodplain.  Flood storage capacity would be maintained
       through re-creation of the wetland area.
    •  Institutional controls would be established to restrict activities to commercial/
      industrial on Parcel 1 and preserve the wetland area on Parcel 2.

ESTIMATED TIME FOR REQUIRED CONSTRUCTION IS:    29 to 35 months
ESTIMATED TIME REQUIRED TO ACHIEVE PRGs IS:      29 to 35 months
ESTIMATED NET-PRESENT WORTH COST IS:            $37,323,400

SC-5 Chemical Fixation and On-site Backfilling

Alternative SC-5, selected source control remedy for the Site,  features in-place chemical fixation,
on-site backfilling of treated soils, and off-site compensatory wetlands restoration. Under Alternative
SC-5, metal contaminants leaching to groundwater would be reduced or minimized through chemically
altering the soluble metals into stable and much less soluble mineral forms, thus rendering the metals
unleachable and protecting human health and the environment. Treated soils from all excavated areas of
the Site would be used to backfill the Lagoons 1 and 2 areas. They would be covered with a two-foot
permeable soil cover and revegetated to prevent erosion and potential exposure of biological receptors to
the treated soils  (if bioavailability of metals in the treated soil is not reduced).  Lagoons 3 and 4 and
the Northern and Southern Wetlands would be backfilled with a minimal amount of clean soil and used as
storm water retention basins that would have adeguate capacity to address runoff from a 100-year storm
event.

The soils containing contaminants in excess of PRGs for groundwater leaching and ecological risk and
which fail TCLP, or other suitable leaching test, would be treated in place with reagents in
approximately 12-inch lifts, mixed, allowed to cure for approximately 24 hours, and would then be
excavated and stockpiled on-site temporarily. Soils from the former building area, the lagoons,  and the
Northern and Southern Wetlands would be treated. The monolith would be demolished, tested for RCRA
leaching characteristics,  treated if needed, and used as on-site backfill. Additional treatment of the
monolithic materials is not anticipated because contaminated soils were previously solidified.

After confirmation of treatment effectiveness (through leaching tests including TCLP, SPLP, or MEP), all
treated materials would be backfilled into Lagoon 1 (and a portion of Lagoon 2, as needed) and covered.
Closure and post-closure plans would be prepared to comply with RCRA hazardous waste surface impoundment
closure reguirements in case not all contaminated subsurface soils can be practicably excavated. An
on-site treatability study would be necessary to determine the appropriate reagent mixture and confirm
the effective reduction in leaching and bioavailability of metals from treated soils.

Since the lagoon system represents a 2.8 acre wetland area and remediation impacts are unavoidable,
mitigation would be performed through the preservation of off-site wetlands. Institutional controls would
be established to restrict excavation through the cap and limit land- use to industrial applications.

    •  41,300 yds 3 of soil would be treated in-place,  excavated and placed in the former Lagoons 1 and 2
       areas. The treated  material  will  be covered with  a permeable  two-foot  soil  cover  to establish
      vegetation.
    •  The temporary holding cell storage material (7,875 yds 3)  would be crushed,  treated as necessary
      and placed with the treated soil in former Lagoons 1 and 2.
    •  The former building and holding cell excavated areas would be backfilled with clean material and
      vegetated to prevent erosion.
    •  The former Lagoons 3 and 4 and the Northern and Southern Wetland areas would be backfilled with a
      minimal amount of clean material  (
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ESTIMATED TIME FOR REQUIRED CONSTRUCTION IS:    23 to 29 months
ESTIMATED TIME REQUIRED TO ACHIEVE PRGs IS:     23 to 29 months
ESTIMATED NET-PRESENT WORTH COST IS:            $9,134,000

B. Management of Migration (MOM) Alternatives Analyzed

Management of Migration (MOM) alternatives address contaminants that have migrated in groundwater from
the original source of contamination. At the New Hampshire Plating Site, contaminants have migrated from
the on-site lagoons and building source areas, under adjacent properties and to the Merrimack River east
of the Site. The contaminants have also spread south to Horseshoe Pond. The contaminants are present
primarily in the shallow overburden aguifer. The MOM alternatives evaluated for the Site include a
no-action alternative  (GW-1), a limited action alternative (GW-2) and a treatment and containment
alternative (GW-3).

Consistent with EPA's Groundwater Use and Value Determination Guidance  (April 3, 1996), NHDES determined
that groundwater in the vicinity of the Site is of medium to high value. A copy of the Groundwater Use
and Value Determination for this Site is attached in Appendix D. The Site and surrounding area are served
by the Merrimack Village District public water supply  distribution system. There are no drinking water
wells in the vicinity of the Site. This use and value determination replaces the former groundwater
classification system.

Based on information contained in the NHDES' Groundwater Use and Value Determination Report  (January 12,
1998) and the results of modeling performed in the Feasibility Study, EPA concluded that, for the
development of remedial alternatives, extraction and treatment for the purpose of containment (GW-3)  was
adeguate and that full aguifer restoration through extraction and treatment was unwarranted.

GW-1 No-Action

The No Action Alternative was developed as a baseline case. Under this alternative, no source control
action would be taken at the NHPC Site to reduce or mitigate soil contaminant leaching to groundwater.
Without source control, the groundwater guality would not be expected to return to acceptable levels
through dilution and natural geochemical attenuation in a reasonable amount  of time since soil
contaminants would continually contribute to groundwater contamination. No institutional controls for the
protection of human health would be provided. The only activities conducted would be minimal long-term
monitoring of groundwater to evaluate contaminant migration.

    •  Only minimal groundwater monitoring performed.
    •  No institutional controls established.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION IS:         n/a
ESTIMATED TIME REQUIRED TO ATTAIN PRGs IS:             700+ years
ESTIMATED NET-PRESENT WORTH COST IS:                   $751,400

    *  This alternative is a baseline against which other cleanup alternatives are compared. It
       is not protective and does not meet ARARs.

GW-2 Limited Action

GW-2 Limited Action, the selected management of migration alternative for the Site, involves little or no
treatment, but provides protection of human health by preventing or controlling potential exposures to
contaminated groundwater through institutional controls. Limited Action would only be implemented in
conjunction with one of the Source Control alternatives (SC-2, 3, 4 or 5).  With source control in place,
the groundwater guality would gradually return to acceptable levels  (groundwater guality that would meet
federal and state standards)  through dilution and natural geochemical attenuation. A comprehensive
long-term surface and groundwater monitoring program would be implemented to evaluate contaminant status
and migration. Surface water bodies to be monitored include the Merrimack River and Horseshoe Pond.

    •  Implemented in conjunction with Source Control.
    •  Contaminant levels would be reduced through natural attenuation mechanisms.
    •  A comprehensive surface and groundwater monitoring program would be established.
    •  Institutional Controls (i.e., deed restrictions, zoning regulations)  would be established to
      prevent consumption of groundwater containing unacceptable levels of contaminants.
    •  A Groundwater Management Zone would be established in compliance with the State's Groundwater
      Protection Rules (Env-Ws 410).
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ESTIMATED TIME FOR DESIGN AND CONSTRUCTION IS:         n/a
ESTIMATED TIME REQUIRED TO ATTAIN PRGs IS:             26 to 58 years
ESTIMATED NET-PRESENT WORTH COST IS:                   $771,400

GW-3 Containment by Extraction

Under this treatment alternative, a groundwater extraction system would be installed: to hydraulically
contain groundwater leaving the NHPC source areas; to limit further contaminant migration in the shallow
overburden, the deep overburden, and bedrock aguifers; and to limit the continued discharge of
contaminated groundwater into the Merrimack River. It is anticipated that groundwater containment would
be implemented in conjunction with one of the Source Control alternatives (SC-2, 3, 4 or 5).

Groundwater containment would be accomplished using four shallow overburden and two deep overburden
extraction wells, situated on the NHPC eastern property boundary, to capture contaminated overburden
groundwater at an estimated combined average of 50 gallons per minute  (gpm)  pumping rate. The results of
aguifer tests performed as part of a pre-design investigation would be used to design and install the
extraction system.

Groundwater collected by the extraction wells would be transferred to a treatment system for removal of
metals and volatile organic compounds. Groundwater would be treated to attain the more stringent of
federal maximum contaminant levels or state ambient groundwater guality standards. Based on available
space at the Site, the western section of the site (the former pug mill area) is a viable location for
the treatment system. A surface and groundwater monitoring program would be implemented to evaluate
contaminant status and migration. Surface water bodies to be monitored include the Merrimack River and
Horseshoe Pond. Institutional controls (i.e., deed restrictions, zoning regulations) would be established
to prevent consumption of groundwater containing, unacceptable levels of contaminants. Because extraction
and containment will retard groundwater flow and impede dilution, GW-3 will reguire more time to achieve
acceptable standards in the off-site portions of the plume than full natural attenuation (GW-2).

    •  Assumes implementation in conjunction with Source Control.
    •  Groundwater contaminant levels on-site would be reduced through treatment. Contaminant levels
      off-site would be reduced through natural attenuation mechanisms
    •  Groundwater monitoring would be performed.
    •  Institutional Controls would be established.
    •  A Groundwater Management Zone would be established in compliance with the State's Groundwater
      Protection Rules (Env-Ws 410).

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION IS:         12 to 18 months
ESTIMATED TIME REQUIRED TO ATTAIN PRGs IS:             40 to 112 years
ESTIMATED NET-PRESENT WORTH COST IS:                   $5,644,200

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 National Contingency
Plan (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 remedy for the New Hampshire Plating Site. The following is a summary of the comparison of each
source control's and management of migration alternative's strengths and weaknesses with respect to 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
    adeguate 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 reguirements (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.
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Primary Balancing Criteria

The following five criteria are utilized to compare and evaluate the elements of one alternative to
another for those 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 and 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.

A detailed assessment of each Source Control and Management of Migration alternative relative to the nine
criteria can be found in Sections 4.1 and 4.3 of the Feasibility Study.

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. The full comparative
analysis can be found in Table 8 for Source Control alternatives and Table 9 for Management of Migration
alternatives, which are attached.

The section below presents the nine criteria and a brief narrative summary of each alternative's
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.  Alternatives which best satisfy each of the five balancing criteria are shown in bold print.

Source Control Alternatives

1. Overall protection of human health and the environment - Alternatives SC-2, 3, 4 and 5 all meet this
   threshold criteria through a combination of physical treatment and institutional controls. Alternative
   SC-1 was eliminated from further consideration.

2. Compliance with applicable or relevant and appropriate requirements  (ARARS)- Alternatives SC-2, 3, 4
   and 5 all meet this threshold criteria and do not require waivers.

3. Long-term effectiveness and permanence - Alternative SC-2 would be effective in reducing leaching of
   contaminants and, with proper maintenance, is a reliable technology. Alternative SC-3 would also be
   effective in reducing leaching of contaminants, is a reliable technology and would require less
   maintenance than SC-1. Alternative SC-4 would enjoy the highest level of effectiveness and permanence
   since contaminated soils would be removed from the Site. Alternative SC-5 would also be effective in
   reducing leaching of contaminants and is expected to require no maintenance. SC-5 is an innovative
   technology which is expected to be reliable based on performance at similar sites.

4. Reduction of toxicity, mobility, or volume through treatment - Alternative SC-2 does not involve
   treatment, therefore there would be no reduction of toxicity or volume. However, reduction of mobility
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   is expected since a RCRA cap would be used to eliminate water infiltration. Alternative SC-3 would
   result in a reduction of contaminant mobility, but not toxicity. Some increase in volume would occur.
   Alternative SC-4 involves off-site disposal. Reduction of toxicity,  mobility or volume would be
   similar to alternative SC-2 if the material were sent to a RCRA Subtitle C facility without further
   treatment. Reduction of toxicity, mobility or volume would be similar to alternative SC-3 if the
   material were sent to a TSDF for treatment  (most likely by solidification) and then disposed in a
   solid waste landfill. Alternative SC-5, would enjoy the highest level of reduction in toxicity,
   mobility or volume since mobility would be reduced or eliminated; there is no increase, and possibly a
   decrease in volume; and there is evidence to support a reduction in toxicity. Comprehensive testing
   will be performed to verify the reduction in toxicity.

5. Short term effectiveness - Alternative SC-2 would reguire 24-30 months to achieve PRGs. Potential
   exposures to workers and the community during remediation would be minimized through engineering
   controls. Alternative SC-3 would reguire 29-35 months to achieve PRGs. Potential exposures to workers
   and the community during remediation would be greater than SC-2 but would be minimized through
   engineering controls. Alternative SC-4 would reguire 29 to 35 months to achieve PRGs. Damage to
   wetlands would occur during implementation of all source control alternatives and would reguire
   on-site  (SC-3, SC-4) or off-site (SC-2, SC-5) mitigation action. Potential exposures to workers and
   the community during remediation would be similar to SC-3 and would be minimized through engineering
   controls. Alternative SC-5 would enjoy the highest level of short-term effectiveness (by a narrow
   margin over SC-2) since, similar to SC-2, potential exposures to workers and the community during
   remediation would be relatively low and SC-5 would reguire slightly less time to implement, 23 to 29
   months.

6. Implementability - Alternative SC-2 is readily implementable. Deed restrictions would be necessary and
   may be difficult to obtain since ownership of the property is in guestion. Alternatives SC-3 and SC-4
   would enjoy the highest level of implementability since both services are widely available and no deed
   restrictions would be necessary. Alternative SC-5 is an innovative technology and is expected to be
   readily implementable, though only a limited number of vendors are known to provide this service.
   Also, deed restrictions would likely be necessary unless a reduction in  toxicity could be verified.

7. Cost - Alternative SC-2 would be the least expensive at an estimated net-present worth cost of
   $7,267,800. Alternative SC-3 would cost an estimated $23,693,000. Alternative SC-4 would be most
   expensive at an estimated cost of $37,323,400. Alternative SC-5 would be about 20% more expensive than
   SC-2 at an estimated cost of $9,134,000.

8. State Acceptance - The State has expressed support for the proposed alternative SC-5 (Chemical
   Fixation) based on its ability to effectively treat soils in a cost-effective manner. Although
   alternative SC-2 (Landfilling)  would be less expensive, the State expressed concerns with the
   long-term integrity of the landfill, its proximity to the Merrimack River and its location in a
   100-year floodplain. State acceptance will be assured through issuance of a concurrence letter from
   the State prior to approval of this document by EPA.

9. Community Acceptance - During the public comment period, the only concern raised for the proposed
   alternative, SC-5,  was exposure to dust that would be generated during remedial actions. However, any
   of the proposed remedial actions would reguire excavation and may generate dust. Engineering controls
   will be used to minimize dust and air monitoring will be performed to assure no exposure. There were
   no other comments on the proposed source control alternative.

Management of Migration Alternatives

1. Overall protection of human health and the environment - Alternative GW-2 would meet this threshold
   criteria through the use of institutional controls. Alternative GW-3 would meet this threshold
   criteria through a combination of physical treatment and

2. Compliance with applicable or relevant and appropriate reguirements (ARARS)- Alternatives GW-2 and
   GW-3 would meet this threshold criteria without waivers.

3. Long-term effectiveness and permanence - Alternatives GW-2 and GW-3 are egually effective and each
   would reguire a significant amount of time to reduce contaminant concentrations to acceptable levels.
   The primary mechanism for reduction under alternative GW-2 would be natural attenuation processes
   (i.e., flushing). Both alternatives would rely on institutional controls to prevent exposures to
   potential contaminants. Alternative GW-3 would rely on physical treatment processes to contain and
   reduce contamination in the plume area beneath the site. The treatment processes are expected to be
   highly reliable with proper maintenance. Institutional controls may include deed restrictions, zoning
   reguirements, Env-Ws 410 reguirements or a combination of the above, as deemed necessary by EPA and
   the State. Long-term monitoring would be implemented to evaluate the effectiveness of natural
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   attenuation for both alternatives. Since contamination would remain at the site in groundwater at
   unacceptable levels, five-year reviews are necessary for both alternatives.

4.  Reduction of toxicity, mobility, or volume through treatment - Alternative GW-2 does not involve
   treatment and there would be no reduction in mobility or volume. Through natural attenuation,
   reduction in toxicity is expected over time. Alternative GW-3 relies on a combination of treatment and
   natural attenuation and therefore would result in some reduction in toxicity, mobility and volume.

5.  Short term effectiveness - Alternative GW-2 would reguire 26 to 58 years to achieve RAOs.  Alternative
   GW-3 would reguire 40 to 112 years to achieve RAOs. Since alternative GW-2 only involves monitoring,
   there would be no risk to the community or environment. Short term risks to workers would be
   controlled through use protective clothing during monitoring activities. For alternative GW-3,
   engineering controls would be implemented to minimize the potential for unacceptable exposure to the
   community or environment from construction and operation of the treatment plant. Short term risks to
   workers would be controlled through use protective clothing during monitoring activities.  Overall,
   alternative GW-2 provides the best overall short-term effectiveness.

6.  Implementability - Alternative GW-2 would be readily implementable. Institutional controls are
   expected to be readily obtained. Only typical sampling and laboratory eguipment would be necessary to
   implement the monitoring program. In addition to the above components, alternative GW-3 would reguire
   construction and operation of a treatment system. Services to construct, operate and monitor the
   treatment system are expected to be widely available.

7.  Cost - Alternative GW-2 would be the least expensive at an estimated net-present worth cost of
   $771,400. Alternative GW-3 would cost an estimated $5,644,200.

8.  State Acceptance - The State has expressed support for the proposed alternative, GW-2 (Limited
   Action), since it is protective of human health and the environment and is cost-effective. State
   acceptance will be assured through issuance of a concurrence letter from the State prior to approval
   of this document by EPA.

9.  Community Acceptance - During the public comment period, the Merrimack Village District (MVD)
   expressed concern with selection of alternative GW-2. The MVD issued several strong letters reguesting
   that EPA actively remediate groundwater so that it may be used to support installation of a new
   community well for the town. EPA and NHDES met with the MVD to discuss this issue and agreed to
   perform additional hydrologic and remediation evaluations. Based on these evaluations, EPA has
   concluded that the town's goal to install a municipal well in the immediate area of the site cannot be
   satisfied in the reguested time frame (8 years).  EPA has evaluated a potential alternative well site
   that may meet the MVD's reguirements.  EPA's evaluation and conclusions were presented to the Merrimack
   Village District in a letter report from EPA's consultant dated May 28, 1998. The report and
   transmittal letter are attached in Appendix E. The Merrimack Village district has not responded to the
   report. Alternative GW-2 remains EPA's preferred alternative.

X.  THE SEIiECTED REMEDY

The selected remedy for the New Hampshire Plating Superfund Site is a comprehensive approach that
includes both source control and management of migration components.

Alternative SC-5 is the selected source control alternative for remediation of soils. Alternative SC5
features in-place chemical fixation, on-site backfilling of treated soils, and off-site compensatory
wetlands restoration. Under Alternative SC5, metal contaminants leaching to groundwater will be reduced
to acceptable levels through chemically altering the soluble metals into stable and much less soluble
mineral forms, thus protecting human health and the environment. The treated soils will be used to
backfill excavated areas in lagoons 1 and 2. Excavated areas outside lagoons 1 and 2 will be re-graded
using remaining soils to the extent possible. Minimal clean fill will be added as necessary.  The treated
soils backfill area will be covered with a two foot permeable soil cover and revegetated to prevent
erosion and potential exposure of biological receptors to the treated soils  (if bioavailability of metals
in the treated soil is not reduced). The backfilled lagoons and wetlands will be used as storm water
retention basins that will have adeguate capacity to address runoff from a 100-year storm event. Land-use
restrictions will be implemented to limit future development to commercial/industrial uses and assure
that the clean soil cover over the treated material on parcel 2 is not breached.

Alternative GW-2 is the selected management of migration alternative for remediation of groundwater.
Alternative GW2 does not involve treatment, but provides protection of human health by preventing or
controlling potential exposures to contaminated groundwater through institutional controls. With source
control in place, the groundwater guality will gradually return to acceptable levels (i.e., will meet
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federal and state standards) through dilution and natural geochemical attenuation. The activities that
will be conducted under the GW2 alternative are institutional controls, long-term monitoring of
groundwater to evaluate contaminant status and migration, and a review of site conditions and risks every
5 years. GW2 will not in itself minimize off-site contaminant migration or discharge of contaminated
groundwater to the Merrimack River, but in combination with source control, it will address these
objectives. The institutional controls proposed include:

    •  Establishing a Groundwater Management Zone  (GMZ) pursuant to the New Hampshire Code of
      Administrative Rule Env-Ws 410.26; and

    •  Attaching restrictions, or notices as appropriate, to deeds of the NHPC property and the properties
      within the designated GMZ; or

    •  Enacting local ordinances to prohibit the potable use of untreated contaminated groundwater
      underlying the Site and within the GMZ.

The remedial components are more fully described in section D below.

A.   Soil Cleanup Levels

Based upon data developed in the RI and the Baseline Risk Assessment, remedial measures to address human
health risks associated with possible exposure to source soils are not warranted because present and
future potential risks are within EPA's acceptable carcinogenic risk range and generally below a Hazard
Index of one for non-carcinogens. Under the reasonable maximum exposure scenario, the non-carcinogenic
risk would exceed a hazard index of 1 in Lagoons 3 and 4 as a result of potential exposure to cadmium.
The hazard index in Lagoons 3 and 4 is less than three, which does not by itself provide sufficient basis
for remedial action. However, area soils are a source of release of inorganic contaminants to
groundwater. Additionally, the levels of inorganic contaminants in the top two feet of soil present an
unacceptable ecological risk. Therefore, the soil remedial action is based on protection of groundwater
and ecological receptors. In addressing these goals, the incremental risks to human health from exposure
to site soils will also be mitigated.

Protection of Groundwater

On-site soils are a source of release of inorganic contaminants to groundwater. This phenomenon has
resulted in groundwater contaminant levels which exceed MCLs and may result in an unacceptable risk to
those who ingest contaminated groundwater. Therefore, cleanup levels for soils were established to
protect the aguifer from soil leachate. The Excel-Crystal Ball Transport (ECTran) model was used by EPA's
consultant to estimate residual soil levels that are not expected to impair future groundwater guality.
The interim cleanup levels for groundwater (presented below) were used as input into the ECTran model and
are based on MCLs and State AGQS. Table 10 summarizes the soil cleanup levels reguired to protect the
aguifer, and therefore public health, and were developed for the groundwater contaminants of concern
detected above interim groundwater cleanup levels. Cadmium is the most toxic and freguently detected soil
contaminant throughout the Site and will be used as an indicator to determine attainment of clean-up
levels. The clean-up levels for cadmium range from 1.78 to 6.42 mg/kg, depending on the location of
specific source areas as follows: NHPC former building area is 3.30 mg/kg;  Lagoon 1 and the southern
wetland area are 6.42 mg/kg; Lagoon 2 is 2.55 mg/kg; Lagoons 3 and 4 are 2.42 mg/kg; and the northern
wetland area is 1.78 mg/kg. Location specific soil clean-up levels were developed for the contaminants of
concern to account for variation in flow paths, hydrogeologic conditions and contaminant concentrations.

Untreated soils which remain in place  (i.e.,  soils below applicable clean-up levels) will be tested for
RCRA leaching characteristics using the appropriate leaching test; TCLP, SPLP or MEP, to confirm that the
residual soil contaminant levels do not exceed RCRA leaching standards.

Ecological Risk

EPA determined that an active wildlife habitat is present throughout the former lagoon area. An
ecological risk assessment evaluated potential effects to the local wildlife habitat resulting from
exposure to inorganic contaminants present in soils. A conceptual food-web model was prepared to evaluate
the bioaccumulation pathways of five indicator species  (red fox, short-tailed shrew, green-backed heron,
American robin and green frog). Cadmium was chosen as the sole contaminant of concern for all ecological
receptors based on its relative toxicity and bioaccumulation potential. The ecological risk assessment
only evaluated potential exposures within the top two feet of soil. The general assumption was made that
ecological receptors are not likely to be directly exposed to native soil beneath the zero to two foot
depth interval. The ecological risk assessment concluded that exposure to cadmium soil concentrations
above 5.6 mg/kg in the top two feet of soil would result in detrimental impacts to the short-tailed
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shrew.  This clean-up level applies to soil throughout the former lagoon area.

These cleanup levels in soil are consistent with ARARs for groundwater, attain EPA's risk management goal
for remedial actions, and have been determined by EPA to be protective. The cleanup levels must be met at
the completion of the remedial action at the points of compliance which, for protection of groundwater,
include all soil from ground surface to the groundwater table throughout the former lagoon area, the
northern and southern wetland areas and the former building area and, for protection of ecological
receptors, includes the top two feet of soil throughout the former lagoon area and the northern and
southern wetland areas.

B. Interim Groundwater Cleanup Levels

Interim cleanup levels have been established in groundwater for all organic and inorganic 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 Level Goals (MCLGs)  and State Ambient Groundwater Quality Standards  (AGQSs)) as
available, or other suitable criteria described below. Because the aquifer under the Site is a medium to
high value aquifer, which is a potential source of drinking water, MCLs and non-zero MCLGs established
under the Safe Drinking Water Act are ARARs. Periodic assessments of the protection afforded by remedial
activities will be made as the remedy is being implemented and at the completion of the remedial action.
When the Interim Ground Water Cleanup Levels have been achieved and have not been exceeded for a period
of three consecutive years, a risk assessment shall be performed on the residual groundwater
contamination to determine whether the remedial action is protective. This risk assessment of the
residual groundwater contamination shall follow the current EPA procedures in effect at that time and
will assess the cumulative carcinogenic and non-carcinogenic risks posed by ingestion of 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. These protective
 residual levels shall constitute the final cleanup levels for this Record of Decision and shall be
considered performance standards for any remedial action.

Table 11 summarizes the Interim Cleanup Levels for carcinogenic and non-carcinogenic contaminants of
concern identified in groundwater.

All Interim Groundwater Cleanup Levels and final groundwater clean-up levels, if any, must be met at the
completion of the remedial action in all impacted wells. These wells are located within the State defined
conceptual Groundwater Management Zone depicted in Figure 5. EPA has estimated that these levels will be
obtained within 26 to 58 years after completion of the   source control component.

C. Description of Remedial Components

1. Source Control

As the selected source control alternative for remediation of soils, alternative SC-5 features in-place
chemical fixation, excavation, on-site backfilling of treated soils, and off-site compensatory wetlands
restoration. In-place chemical fixation is an innovative technology which has been extensively tested and
used to successfully remediate other federal and state sites. However, because this is a relatively new
technology, a field scale pre-design study will be performed to assure the technology is capable of
treating the soil to the necessary remedial clean-up goals, determine if the preferred in-place
application process is effective,  develop the appropriate reagent and application rate, and evaluate the
bioaccumulation potential of treated soils. It is anticipated that the pre-design study will be performed
on a portion of lagoon 1 soils and will require 3 to 6 months to complete. The components of the overall
source control remedial action include:

    •  completion of a field-scale pre-design study;

    •  sequential application of the treatment reagent in 1-foot lifts throughout the building area,
      lagoon area and northern and southern wetland areas down to the water table  (about 41,300 cubic
      yards of soil will be treated);

    •  excavation of the treated soil for temporary on-site storage  (air monitoring to be performed for
      worker and adjacent property owner safety);

    •  backfilling of all treated soil in the lagoons 1 and 2 areas;

    •  grading of all other excavated areas using existing soils to the extent practical;
-------
    •  use of 18 inches of clean fill and 6 inches of loam to cover treated materials with a 2-foot buffer
      to address potential ecological concern and re-vegetate (note that the cover may be reduced to six
      inches if results from the pre-design study demonstrate that the treated material has no
      bioaccumulation potential, and note that clean fill may be used from the on-site pugmill area to
      help retain flood storage capacity); and

    •  revegetation of the building area with grasses and the remaining wetland areas  (northern, southern,
      Lagoon 3 and Lagoon 4)  with appropriate wetland type vegetation.

2. Solidified Material Storage Cell

An EPA emergency removal action was performed on the site from 1990 to 1992. Approximately 13,600 tons of
sludge and contaminated soil were excavated from the four lagoon areas, solidified on-site and
encapsulated in a high-density polyethylene solidified material storage cell (SMSC). The SMSC was
intended as an interim measure and does not meet RCRA or State closure reguirements. It is estimated that
the SMSC contains about 8,000 cubic yards of treated material. The following remedial actions will be
performed on the SMSC as part of source control:

    •  the SMSC will be crushed into small diameter fragments using a procedure such as a bucket-mounted
      jack hammer (air monitoring to be performed for the safety of workers and adjacent property
      owners);

    •  the crushed fragments will be grouped in a pile and tested by TCLP at an established freguency. If
      the fragments pass TCLP, they will be placed in the lagoons 1 and 2 area as backfill to be mixed
      with the treated soil.  If the fragments fail TCLP, they will be placed in a separate pile for later
      treatment using the chemical fixation process.  Following application of the chemical fixation
      process, the fragments will be re-tested using TCLP. If the fragments still fail TCLP,  they will be
      grouped for off-site disposal at an appropriate Subtitle C facility.

    •  The extent of contamination present underneath the SMSC, if any, could not be evaluated during the
      RI.  The former discharge pipe passed through this area and as a result, could have released
      contamination. Therefore, these soils will be tested for contaminants of concern as part of the
      selected remedy and may result in an increase soft volume reguiring remediation from this area.

3. Wetland Mitigation

Because the areas to be treated and excavated under the source control component are wetlands, excavation
and associated activities will be performed to minimize adverse impacts to the wetland areas. All source
control alternatives considered in the FS, except for no action, would reguire excavation of contaminated
soil from wetland areas.

EPA has determined that, for this Site, there are no practicable alternatives to the treatment and
excavation components of the selected remedy that would achieve Site goals but would have less,
short-term adverse impacts to the ecosystem. Therefore, measures will be performed to mitigate these
impacts. Lagoons 3 and 4 and the northern and southern wetlands will be backfilled with minimal clean
soil, revegetated with appropriate wetland-type vegetation,  and used as storm-water retention basins that
would have adeguate capacity to address run-off from a 100-year storm event. Restoration or creation of
new wetlands on-site would reguire that treated soils be sent off-site at a cost of approximately $8
million dollars and are not practical due to limited space and the desire to return the front parcel of
the site to productive light-industrial use consistent with local zoning. As such, EPA has and will
perform the following activities:

    •  Off-site wetland mitigation will be performed in coordination with DES, US Fish & Wildlife, the
      Nature Conservancy and the local conservation commissions. EPA and DES jointly agreed to purchase
      and preserve an ecologically rare and significant wetland in the adjacent Town of Litchfield. Areas
      upland to the wetland,  known as Grassy Pond, were purchased by DES in May 1998 under an agreement
      with EPA which allowed for reimbursement of 90% of the State's costs once this ROD was complete.
      The urgency to purchase the Grassy Pond upland properties resulted from construction by the
      property owner, which would otherwise have caused irreparable damage to the wetland prior to
      completion of this ROD. A wetland delineation for Grassy Pond was completed prior to the
      acguisition. The acguisition cost was $1.39 million;

    •  In addition, a second wetland acguisition will occur in the Town of Merrimack. This wetland
      acguisition is necessary to address concerns raised by the Town of Merrimack that the Grassy Pond
      acguisition would not benefit the local community since it is on the other side of the Merrimack
      River and is not accessible. With respect to off-site wetland mitigation, there is a general
      reguirement that the mitigation property be located in the same watershed as the affected site. In
-------
      this case, the Grassy Pond wetland is in the same watershed as the Site. However, separation by the
      river is a valid concern. Negotiations on the unnamed wetland  (referred to as the Naticook Road
      Wetland) will begin after the ROD is completed. The appraised property value is $110,000. If
      negotiations fail, EPA will work with the Town to identify an alternative wetland of equal
      ecological and monetary value;

    •  EPA will prepare a final wetland mitigation report to demonstrate that the preservation measures
      adequately satisfy the objectives of the Wetland Executive Order and Section 404 of the Clean Water
      Act.

4.Management of Migration

Alternative GW-2 is the selected management of migration alternative for remediation of groundwater.
Alternative GW2 does not involve treatment, but provides protection of human health by preventing or
controlling potential exposures to contaminated groundwater through the use of institutional controls.
With source control in place, the groundwater quality will gradually return to acceptable levels (i.e.,
will meet federal and state standards) through dilution and natural geochemical attenuation. The
activities that will be conducted under the GW2 alternative include:

•   annual monitoring  of selected wells within  the Groundwater Management  Zone  (GMZ). Approximately  40
    existing monitoring  wells will be  selected  by EPA and DES and  sampled  throughout  the plume  for all
    contaminants  of  concern. All monitoring wells will be sampled  using  the  low-flow  field method  (where
    possible)  and applicable  EPA analytical methods.  EPA quality control methods will be followed such  as
    collection of trip blanks,  duplicates,  etc.  and a completeness  check of  all analytical results  (i.e.,
    tier  I validation).  There are no known  existing potable  supply wells within the plume area.  The
    Merrimack  Village  District  requested agency assistance to determine  a  possible location  of  a new
    municipal  well in  the immediate vicinity, but outside the GMZ,  that would not be
   affected by site-related contamination.  If a municipal well is installed in a mutually agreeable area
   outside the GMZ and is later found to be impacted by site-related contamination,  EPA and DES will
   evaluate options to isolate the plume from the well;

    •  installation of two monitoring well  couplets on the opposite side of the Merrimack River in the
      Town of Litchfield. These wells will be installed in the shallow and deep overburden and will be
      used to determine if site-related contamination extends beyond the Merrimack River.  Exact well
      locations will be jointly determined by EPA,  DES and the Town of Litchfield.  These well couplets
      will be sampled initially for all COCs. If the results are non-detect, then annual sampling will
      commence for VOCs only. If VOCs are  later detected,  then inorganic contaminants of concern will
      also be monitored;.

    •  monitoring of up to six residential wells across the Merrimack River in the Town of Litchfield.
      Exact locations are to be determined. These wells will be used to determine if site-related
      contamination extends beyond the Merrimack River.  These wells will be sampled for VOCs only.  If
      VOCs are present,  then inorganic contaminants of concern will be added.  All wells which are
      non-detect will be re-sampled once every five years (prior to the required five-year review).  Wells
      with any site-related contamination will be monitored quarterly;

    •  annual sampling of surface water from three points on the Merrimack River and three points on
      Horseshoe Pond.  The three river monitoring points will represent upgradient,  cross-gradient and
      downgradient locations. The three Horseshoe Pond monitoring points will be taken along the shore
      front adjacent to the YMCA property.  Sample locations will be replicated to the extent practical.
      Samples will be analyzed for all COCs.  After completion of the first two annual events, sample
      frequencies may be reduced to once every five years (prior to the required five year review)  if
      results are non-detect.

The long-term monitoring program may be modified in scope and frequency as deemed necessary by EPA and
DES and consistent with the goals of the management of migration remedial action.

5. Institutional Controls

Alternative GW2 will not in itself minimize off-site contaminant migration or discharge of contaminated
groundwater to the Merrimack River,  but in combination with source control,  it will address these
objectives.  The institutional controls proposed include:

    •  establishing a GMZ pursuant to the New Hampshire Code of Administrative Rule Env-Ws 410.26;
-------
    •  attaching restrictions, or notices as appropriate, to deeds of the NHPC property and the properties
      within the designated GMZ  (at this time, it appears deed notices will be acceptable for all
      impacted properties within the GMZ since an active public water supply is in use) or enacting local
      ordinances to prohibit the potable use of untreated contaminated groundwater underlying the Site
      and within the GMZ;

    •  attaching restrictions to the deed of parcel 1  (the former building area) to assure the future
      property use remains industrial/commercial;

    •  attaching restrictions to the deed of parcel 2  (the former lagoon area) to assure the remaining
      wetlands are undisturbed and to limit any future use of the treated-backfilled portion of parcel 2
      to activities which do not result in excavation below the two foot clean-fill layer.

Consistent with EPA guidance, EPA will review the Site at least once every five years after initiation of
remedial action (Five-Year Review)  at the Site to assure that the remedial action continues to protect
human health and the environment.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the New Hampshire Plating 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 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/or institutional controls; more specifically, active soil treatment will
eliminate ecological risks and reduce contaminant leaching to groundwater such that attenuation
mechanisms will return the groundwater to acceptable drinking water standards. Institutional controls
will eliminate use of the groundwater as a potable source until standards are attained.

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. The selected remedy
is protective of sensitive ecological receptors and will comply with ARARs. When the Interim Ground Water
Cleanup Levels identified in the ROD 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 groundwater
contamination shall follow EPA procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by ingestion of 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
protective levels are achieved and have not been exceeded for a period of three consecutive years, or
until the remedy is otherwise deemed protective. These protective residual levels shall constitute the
final cleanup levels for this Record of Decision and shall be considered performance standards for any
remedial action.

B. The Selected Remedy Attains ARARs

This remedy will attain all applicable or relevant and appropriate federal and state reguirements  (ARARs)
that apply to the Site. Since wastes  (i.e., contaminated soil) are being moved within the same "area of
contamination"  (AOC) and will be treated in-place such that hazardous constituents will not migrate, Land
Disposal Restrictions  (LDRs) do not apply.

A discussion of which reguirements are applicable or relevant and appropriate may be found in the FS
Report at pages 4-53 to 4-55 for the source control alternative and pages 4-82 to 4-83 for the management
of migration alternative. A brief narrative summary of the ARARs follows. Refer to attached Tables 12A,
12B, and 12C for a comprehensive presentation of all Source Control ARARs and other policies, criteria
and guidances to be considered (TBCs) and Tables 13A and 13B for a comprehensive presentation of all
Management of Migration ARARs and other policies, criteria and guidances to be considered  (TBCs).

The selected source control and management of migration remedial actions (SC5-W and GW2) will comply with
all chemical, action and location-specific ARARs.
-------
Chemical-Specific ARARs

Specifically, maximum contaminant levels  (MCLs),  State ambient groundwater quality standards  (AGQSs) , New
Hampshire Surface Water Quality Standards and New Hampshire Primary Drinking Water Criteria were used to
determine appropriate soil clean-up levels based on acceptable leachate. The more stringent of these
standards and criteria were used to establish groundwater clean-up levels for the Site.

Location-Specific ARARs

Off-site wetlands preservation will be performed to satisfy the requirements of the Protection of
Wetlands Executive Order 11990, the Clean Water Act Dredge and Fill Regulations and New Hampshire
Criteria and Conditions for Fill and Dredge in Wetlands. Following completion of the source control
remedial action, the Site will be graded and vegetated to retain adequate flood storage capacity and
prevent erosion consistent the Floodplain Management Executive Order 11988 and RCRA Floodplain
Restrictions. New Hampshire Siting Regulations for Hazardous Waste Facilities will be attained since the
treated soils will no longer exhibit hazardous  characteristics prior to their placement on-site.

Action-Specific ARARs

The source control remedial action will comply with RCRA General Facility Standards, RCRA Preparedness
and Prevention Requirements, RCRA Groundwater Monitoring Requirements, RCRA Surface Impoundment Closure
Requirements, and other various RCRA requirements concerning the handling of hazardous materials through
operator training, inspections and design of a adequate treatment and monitoring programs. The source
control remedy will also comply with State standards including fugitive dust control, emergency
procedures, design and monitoring requirements and general operation, environmental and health
requirements. A Groundwater Monitoring Zone (GMZ) and associated sampling plan will be established under
the New Hampshire Groundwater Protection Rules.

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

    •  EPA Risk Reference Doses (RfDs);
    •  EPA Human Health Assessment Cancer Slope Factors  (CSFs);
    •  EPA Health Advisories, Human Health and Ecological Risk Assessment Guidances;
    •  EPA Final Groundwater Use and Value Determination Guidance;
    •  NHDES Contaminated Sites Risk Characterization and Management Policy,
    •  EPA Memorandum, "Policy on Floodplains and Wetland Assessments for CERCLA Actions," August 6, 1985;
    •  Memorandum of Agreement  (MOA) Between EPA and the US Dept. of the Army; and
    •  Guidance on Flexibility of the 404(b)(1) Guidelines.

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 in
combination with long term effectiveness and permanence; reduction in toxicity, mobility, and volume
through treatment; and short term effectiveness.  The relationship of the overall effectiveness of the
selected remedy was determined to be proportional to its costs. The costs of this remedial alternative
are:

                              Source Control    Management of    Total Costs
                                 (SC5-W)        Migration  (GW2)

          Capital Cost         $7,434,600         $20,000        $7,454,600
          0 & M Cost           $262,750           $56,500        $319,250
          Present Worth Cost   $9,134,000         $771,400       $9,905,400

This remedial approach represents the most cost-effective combination of source control and  management
of migration alternatives. Source control alternative SC2 (capping) would be approximately $1.8 million
less expensive than SC5.  However, SC2 would require a waiver from applicable Federal and State ARARs,
would not satisfy the Agency's statutory preference for treatment, and was opposed by the NHDES because
of concerns with long-term maintenance of a landfill in close proximity to the Merrimack River. Other
source control alternatives would be far more expensive with no additional protection. Alternative GW2 is
the least expensive management of migration alternative. Although GW2 does not employ active treatment,
it is protective of public health and the environment through the use of available institutional
-------
controls. Active restoration of the aquifer would reduce the overall time frame for achievement   of
groundwater clean-up levels. In addition, the cost of this approach would exceed $5 million dollars with
no increase in the level of protectiveness.  The impacted area is served by a public water supply
distribution system.

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 alternatives SCI and GW1 (no action) ,  all alternatives were determined to be
protective of public health and the environment and would attain (or be able to waive)  ARARs. Source
control alternatives SC2 - SC5 and management of migration alternatives GW2 and GW3 were compared using
the five balancing criteria above. In general, the combination of alternatives SC5 and GW2 best satisfy
these criteria and was chosen as the recommended alternative. There is no opposition to the source
control remedial alternative  (SC5); however, the local water distributor  (the Merrimack Village District)
would prefer active groundwater remediation since they would like to use the impacted aguifer as a future
potential public water supply source. EPA and DES agree that use of this aguifer as a public water supply
resource is unlikely, even in a post remedial state, since the entire area is in an industrial zone and
active businesses with various existing and potential environmental concerns are present. Also, active
groundwater treatment would not significantly reduce the amount of time required to achieve remedial
goals. GW2 is protective of public health and is a more cost-effective approach. If the Merrimack Village
District installs a municipal supply well in a mutually agreeable,  and legally permissible, area outside
the Groundwater Management Zone, and the supply well later becomes impacted by Site-related contaminants,
EPA and DES may evaluate options to isolate the plume from the well. Options could include the
installation of physical barriers or other appropriate methods to contain or isolate the plume from the
supply well. The probability of this scenario occurring appears to be extremely low. Options have not
been evaluated. Refer to the attached Responsiveness Summary for more detail.

The treatment of soil in alternative SC5 is irreversible, except under a significant pH drop in the
environment from the typical level of about 6 down to the 2-3 range, which is highly unlikely; SC5 will
result in a reduction is toxicity and mobility and will not increase the overall volume of materials  (as
does the more traditional solidification process); SC5 is an in-place technology which should result in
fewer dust concerns and will only take about 2 years to implement;  SC5 is readily implementable; and SC5
is the second least expensive alternative. All source control alternatives require an unavoidable impact
to on-site wetlands, Alternative GW2 is as effective and permanent as alternative GW3 (both require
institutional controls); GW2 does not result in any reduction in mobility however, toxicity and volume
will be reduced through attenuation mechanisms following successful completion of the source control
alternative; GW2 will not result in any potential impact to the community, and, although it will require
28 to 56 years to achieve clean-up standards, this is not significantly longer than active aquifer
restoration; GW2 is readily implementable; and GW2 is millions of dollars less than active aquifer
restoration.

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 source control remedy is chemical fixation. This element addresses
the primary threat at the Site, contamination of groundwater through continued leaching of excessive
levels of metals and potential exposure of sensitive ecological receptors. The selected remedy satisfies
the statutory preference for treatment as a principal element by treating the metal-contaminated soil to
levels which will not exceed acceptable leaching criteria (i.e., TCLP, SPLP or MEP). Although the
management of migration portion of the remedy relies on natural attenuation to achieve groundwater
clean-up standards, the overall remedy is effective only through the active treatment of the source area.
-------
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

EPA presented a Proposed Plan (preferred alternative) for remediation of the Site on January 8,  1998. The
preferred alternative presented was a combination of source control alternative SC5-W and management of
migration alternative GW2 including the following components:

    •  treating metal-contaminated soil by chemical fixation;
    •  redepositing the treated soil in lagoons 1 and 2;
    •  demolishing, testing and treating (as necessary)  the temporary storage unit and mixing it with the
      treated soil in lagoons 1 and 2;
    •  covering and revegetating treated areas;
    •  constructing or preserving an off-site wetland;
    •  performing long-term monitoring to confirm natural attenuation of groundwater,
    •  and establishing a Groundwater Management Zone and land-use restrictions.

Public and State comment did not result in any significant changes to the Proposed Plan. However,  the
following minor modifications to the preferred alternative were necessary.

1. EPA and DES jointly selected wetland preservation as the appropriate, off-site wetland mitigation
   action. Upland areas to a rare and highly valuable wetland, Grassy Pond,  have been acguired in the
   adjacent Town of Litchfield at a total cost of $1.39 million. Swift acguisition of the Grassy Pond
   upland areas was necessary to cease ongoing construction which would have resulted in the eventual
   destruction of this wetland.  In addition, to satisfy concerns raised by the Town of Merrimack,  an
   additional wetland area will be preserved in the Town of Merrimack at an approximate cost of $100k to
   $300k. Once the second acquisition is complete, a wetland Mitigation Report will be prepared which
   will demonstrate that these preservations satisfy the Clean Water Act and the Wetlands Executive
   Order. This approach is consistent with the proposed mitigation options and will not result in an
   increased cost to, this component of the remedy.

2. Two monitoring well clusters will be installed and approximately six residential wells will be added
   to the proposed long-term groundwater monitoring program to evaluate conditions across the Merrimack
   River in the Town of Litchfield. Exact locations are to be determined. These wells will be used to
   confirm our conclusion that site-related contamination does not extend beyond the Merrimack River. The
   addition of these monitoring points is within the original scope of the monitoring program and will
   not result in a significant impact to the proposed budget.

XIII. STATE ROIiE

The State of 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, Risk Assessment and Feasibility Study to determine if the selected remedy is in compliance
with applicable or relevant and appropriate State environmental laws and regulations. The State of New
Hampshire concurs with the selected remedy for the New Hampshire Plating Site. A copy of the declaration
of concurrence is attached as Appendix A.
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                                FIGURES




-------
                                   TABIiE  1
                     SUMMARY OF  SOIL ANALYTICAL RESULTS
                         NEW HAMPSHIRE PLATING SITE
     Parameter        No. of  Positive
                      Detections/
                        No. of
                        Samples
                       Collected  (1)

VOLATILE ORGANIC CHEMICALS  (ug/kg)
Acetone
Methylene chloride
8/22
 3/3
SEMIVOLATILE ORGANIC CHEMICALS  (ug/kg)

 Acenaphthene              1/22
 Benzo(a)anthracene        2/22
 Benzo(b)fluoranthene      7/22
 Benzo(g,h,i)perylene      2/22
 Chrysene                  5/22
 Di-n-butyl phthalate    14/22
 Fluoranthene              6/22
 Phenanthrene              2/22
 Benzo(a)pyrene            4/22
 Indeno(l,2,3-cd)pyrene    2/22
 Pyrene                    5/22

INORGANICS  (mg/kg)

Aluminum                   81/81

Antimony                   7/81
Arsenic                    80/81
Barium                     22/81
Beryllium                  81/81
Cadmium                  413/772
Calcium                    64/81
Chromium                 110/402
Cobalt                     79/81
Copper                     98/402
Cyanide                    46/74
               Range of Positive
                  Detections
                    [Average]  (2)
15.0-120.0 [59.3]
  71-110 [84]
                         Background
                        Concentration
                          Range
                        [Average]  (2)
ND
NA
                    Location of Maximum
                     Positive Detection
120 [120]
180-260 [220]
95-900 [454]
150-190 [170]
120-440 [230]
53-790 [344]
100-710 [300]
130-260 [195]
110-650 [330]
180-250 [215]
150-470 [256]
ND
ND
ND
ND
ND
380
ND
ND
ND
ND
ND
                   2270-16900             13300
                     [11051]
                   2.7-3.5  [3.1]           ND
                   2.3-11.5  [5.3]          6.3
                 26.3-43.0  [33.6]          42.8
                 0.23-1.40  [0.71]          0.96
                1.9-1277.0  [162.4]         ND
                  338-3890  [1291]          1250
                 10.9-403.0  [119.6]        16.2
                  2.8-8.6  [4.6]            5.7
                  4.1-139.0  [36.6]         11.2
                 0.65-509.0  [41.73]        ND
NHP-S-L2-D120-4
NHP-S-NWA-C2-1
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                               NHP-
                                                   S-NWA-
                                                   S-NWA-
                                                   S-SWA-
                                                   S-NWA-
                                                   S-NWA-
                                                   S-JCR-
                                                   S-NWA-
                                                   S-NWA-
                                                   S-SWA-
                                                   S-NWA-
                                                   S-NWA-
                             -Cl-1
                             -Cl-1
                             -01-1
                             -Cl-1
                             -Cl-1
                             -03-1
                             -Cl-1
                             -Cl-1
                             -01-1
                             -Cl-1
                             -Cl-1
                                              NHP-SL-L2-E400-2

                                              NHP-SL-L3-L200-0
                                              NHP-SL-L2-F275-4
                                              NHP-SL-NW-TN375-0
                                              NHP-SL-L3-LN125-2
                                              NHP-SL-1-275-0
                                              NHP-SL-L1-B550-0
                                              NHP-SL-DD-525-0
                                              NHP-SL-HN450-1
                                              NHP-SL-BD-SB4-2
                                              NHP-S-SWA-01-1
-------
TABIiE 1
SUMMARY OF SOIL ANALYTICAL RESULTS
NEW HAMPSHIRE PLATING SITE
PAGE 2 OF 2
   Parameter
No. of Positive
 Detections/
  No. of
 Samples
Collected (1)
Range of Positive
 Detections
 [Average](2)
                                                              Background
                                                             Concentration
                                                                 Range
                                                               [Average]  (2)
Location of Maximum
 Positive Detection
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Tin
Vanadium
Zinc
81/01
95/403
81/81
69/81
4/73
90/402
81/81
10/81
18/81
10/81
14/324
81/81
448/772
    PESTICIDES/PCBs  (ug/kg)
    Aroclor-1254      1/22
    4,4'-DDT          1/22
                                          3870-18500
                                             [10740]
                                      2.8-3742.0  [84.3]

                                         821-3370[2330]
                                       64.1-309.0  [128]
                                       0.05-0.10  [0.07]
                                       7.5-214.0  [49.3]
                                         610-1450  [993]
                                       0.45-0.95  [0.61]
                                       0.93-5.60  [2.45]
                                         51.5-1070.0
                                            [380.7]
                                         52-657  [181]
                                       6.4-34.9  [20.0]
                                          16.8-6490.0
                                             [563.6]
                        81  [81]
                       ll.Ofll.O]
                                            14900

                                             ND

                                            2820
                                             215
                                             ND
                                             10
                                            1350
                                             ND
                                             ND
                                             ND

                                             ND
                                            23.7
                                            43.8
                         ND
                         ND
                                             NHP-SL-L2-G375-1

                                             NHP-SL-Bn-475-4

                                             NHP-SL-HN450-1
                                             NHP-SL-HN450-1
                                             NHP-SL-TN375-0
                                             NHP-SL-L2-CN575-0
                                             NHP-SL-L1-AAN625-4
                                             NHP-SL-NW-TN375-0
                                             NHP-SL-L3-1175-2
                                             NHP-SL-L2-C525-3

                                             NHP-SL-DD-525-0
                                             NHP-SL-L2-D425-4
                                             NHP-SL-1-275-0
     NHP-S-BLD-03-1
     NHP-S-JCR-01-1
    Notes:
     (1)  The data presented on this table include both  Phase  I  and  Phase  II  results,  and only positive
         detects are listed.
     (2)  Arithmetic average of positive detections.
    NA   Not Analyzed
    ND   Not Detected
-------
                                  TABIiE 2
                       SUMMARY OF GROUNDWATER RESULTS
                       NEW HAMPSHIRE PLATING COMPANY
        Parameter              No. of Positive
                                Detections/
                                 No. of
                                Samples
                              Collected  (1)
VOLATILE ORGANIC CHEMICALS

1,1,1-Trichloroethane            80/124

1,1 -Dichloroethane              49/124
1,1-Dichloroethene               46/124
1,1-Dichloropropene               1/9
1,2,4-Trimethylbenzene            1/9
1,2-Dichlorobenzene               1/16

1,2-Dichloroethane                7/124
1,2-Dichloroethene               47/123
(Total)
2-Butanone                       1/124

Benzene                          1/124

Bromoform                        1/124

Carbon disulfide                 4/124
Carbon tetrachloride             1/124

Chloroform                      50/124

cis-l,2-Dichloroethene           5/9
Dibromochloromethane            1/124

Dichlorobromomethane            3/124

Ethane, Tri(chloro-fluoro)      7/8

Ethylbenzene                    1/124

Methyl isobutyl ketone         10/111

Methylene chloride              2/18

Tetra chloroethene             24/123

Toluene                        6/124

trans-l,2-Dichloroethene       1/9
Range of Positive
  Detections
  [Average]  (2)
  0.8-3330.0

  0.4-3500.0 [189]
  0.6-1100.0 [68.9]
     0.8 [0.8]
     0.4 [0.4]
     0.4 [0.4]

    0.5-53.0 [9.5]
    1.1-530 [23.4]

    0.4 [0.4]

    1.8 [1.8]

    1.1 [1.1]

    1.1-2.8 [1.7]
    0.3[0.3]

 1.2-200.0  [14.3]

  1.0-22.0  [10.7]
    1.6[1.6]

1.4-3.6 [2.3]

 2.6-60.0  [14.3]
 1.2-76.0 [15.9]

 1.2-2.4 [1.8]

  0.3-540 [46.2]

  0.3-64.0 [16.5]

    0.9[0.9]
  Background
 Concentration
   Range
  [Average]  (2)
    (ug/L)
     ND
    [145.9]
     ND
     ND
     ND
     ND
     ND

     ND
     ND

     ND

     ND

     ND

     ND
     ND

     ND

     ND
     ND

     ND

No background
    data
     ND

     ND

     ND

     ND
     ND
Location of Maximum
  Positive Detection
          NHP-GW-
       MW21 8S-262
    NHP-GW-B3S-020
    NHP-GW-B3S-020
    NHP-GW-JCMW2S-033
    NHP-GW-W1-013
          NHP-GW-
        JCMW4D-036
    NHP-GW-B3S-020
           NHP-GW-
        MW217S-260
           NHP-GW-
       JCMW4D-036
           NHP-GW-
        MW213S-244
           NHP-GW-
         JCMW6-037
    NHP-GW-B3D-267
           NHP-GW-
        JCMW4D-036
           NHP-GW-
        MW201D-249
    NHP-GW-B7S-023
           NHP-GW-
         JCMW6-037
           NHP-GW-
        MW201D-249
           NHP-GW-
        MW218S-262
           NHP-GW-
        JCMW2S-206
           NHP-GW-
         OHMW3-030
           NHP-GW-
        JCMW4D-036
           NHP-GW-
        MW204S-264
    NHP-GW-B3S-020

    NHP-GW-87S.023
-------
TABIiE 2
SUMMARY OF GROUNDWATER RESULTS
NEW HAMPSHIRE PLATING COMPANY
PAGE 2 OF 2
     Parameter
Trichloroethene

Trichlorofluoromethane

Vinyl chloride

Xylenes  (Total)
No. of Positive
  Detections/
    No. of
   Samples
  Collected  (1)

   95/124

   5/123

  10/124

   3/118
SEMIVOLATILE ORGANIC CHEMICALS

Bis(2-ethythexyl)phthalate   8/17
Pentachlorophenol

INORGANICS

Aluminum

Arsenic

Cadmium
Chromium

Cyanide

Iron

Lead

Manganese
Nickel

Sodium

Zinc

Notes:
  1/17



 51/75

 10/75

 45/75
 31/75

  6/54

 57/75

  4/77

 68/75
 33/75

 75/75

 27/75
Range of Positive
  Detections
    [Average]  (2)
      (ug/L)
    1.0-7500.0
      [183.2]
   1.0-310.0  [76.7]

    0.6-23.0  [6.4]

     1.3-6.9  [3.2]
    1.0-11.0 [3.3]

    l.Ofl.O]
     54-25,100
    [1,076]
     5-230 [48]

    1-1290 [157]
    10-1200 [86]

    39.5-232  [93.8

  51-45,700 [4129]

      8-16 [11.5]

     10-1330  [288]
     20-826 [221]

     3040-192,000
       [56,487]
     56-1310  [227]
  Background
Concentration
    Range
  [Average] (2)
    (ug/L)

      ND

      ND

      ND

      ND
                                                                l.Ofl.O]
  74-428 [185]

      ND

     1  [1]
      ND

      ND

    204 [12.5]

      ND

  12-432 [132]
      ND

10,300-128,000
   [55,057]
63-112  [87]
Location of Maximum
 Positive Detection
            NHP-GW-
         MW217S-260
   NHP-GW-B3S-LF-D-
             104
    NHP-GW-OHM9-257

            NHP-GW-
         JCMW2S-206
                                    GW-MW7R-025

                                     GW-B3S-020
            NHP-GW-
         MW102S-212
            NHP-GW-
         MW218S-262
    NHP-GW-OHM3-116
            NHP-GW-
         JCMW2S-206
            NHP-GW-
         MW213D-243
            NHP-GW-
         MW102S-212
            NHP-GW-
         MW102S-212
    NHP-GW-B10S-204
            NHP-GW-
         JCMW2S-206
            NHP-GW-
         MW201D-249
            NHP-GW-
        JCMW2S-206
 (1)  Based on Phase II results; only positive  detects  are  reported.
 (2)  Arithmetic average of positive detections.
-------
                                         TABIiE 3
                           CONTAMINANTS OF CONCERN FOR SOILS
                   NEW HAMPSHIRE PLATING COMPANY SITE, MERRIMACK, NH
       Contaminant
        of Concern
Arsenic
Beryllium
Cadmium
Chromium
Cyanide
Lead
Manganese
Nickel
Protection of
Human Health
    (1)

   X
   X
   X
Protection of
Groundwater
     (2)

      X

      X
      X
      X
      X
      X
      X
 Protection of
Ecological Rec.
NOTES:

 X Indicates the basis for selection of the contaminant as a COG.

(1) Human health COG selected if risk assess, results for care, risk > 1E-06 or non-care.
    risk HQ > 1.0.
(2) Groundwater protection COG selected if detected RI cone. > MCL or AGQS; or risk assess.
    results indicate groundwater cone, posing care, risk > 1E-06 or non-care, risk HQ >  1.0.


                            TABLE 4

             CONTAMINANTS OF CONCERN FOR GROUNDWATER
        NEW HAMPSHIRE PLATING COMPANY SITE, MERRIMACK, NH
      Contaminant
                        Human Health
                                        Exceeds
                                                    Exceeds
       of Concern         Risk  (1)     SDWA MCL    NH AGQS
Arsenic                    XXX
Cadmium                    XXX
Chromium                   XXX
Cyanide                    —            XX
Lead                       NA            X            X
Manganese                  X
Nickel                     XXX
1,1,1-Trichloroethane      XXX
1,1-Dichloroethene         XXX
1,2-Dichloroethene         XXX
1,2-Dichloroethane         XXX
Chloroform                 XXX
Trichloroethene            XXX
Tetrachloroethene          XXX
Vinyl Chloride             XXX

NOTES:

  X - Indicates the basis for selection of the contaminant as a COG
  (1) Selected as human health COG if risk assess results indicate
     care, risk > 1E-06 or non-care, risk HQ > 1.0.
 SDWA MCL - Federal Safe Drinking Water Act Maximum Contaminant Levels
 HN AGWQS - New Hampshire Ambient Groundwater Quality Standards  [Env-Ws 410.05, Feb.  1993]
 NA - Not Available
-------
                                                                     TABIiE 5

                                                 SUMMARY OF RISK ASSESSMENT RESULTS FOR SOILS
                                                      NEW HAMPSHIRE PLATING COMPANY SITE
 Area of Concern
                        Land Use Scenario
                                    Carcinogenic Risk Results
                                                                Noncarcinogenic Risk Results
Lagoon 1
Lagoon 2
Lagoon 3/4
Northern Wetlands
Southern Wetland
NHPC Building
Area
Trespass

Industrial

Trespass

Industrial

Trespass

Industrial

Trespass

Industrial

Trespass

Industrial

Residential(Phase I)
                      Residential(Phase
                      II/12/94)
                                               Summary Results
                                                 (Cancer Risk)
RME - 7.1 x 10 -7
CT - 3.5 x 10 -7
RME - 3.3 x 10 -6
CT - 1.7 x 10 -6
RME - 1.2 x 10 -6
CT - 6.2 x 10 -7
RME - 3.3 x 10 -6
CT - 1.7 x 10 -6
RME - 8.9 x 10 -7
CT - 4.4 x 10 -7
RME - 3.4 x 10 -6
CT - 1.7 x 10 -6
RME - 9.3 x 10 -7
CT - 4.7 x 10 -7
RME - 3.6 x 10 -6
CT 1.8 x 10 -6
RME - 1.0 X 10 -6
CT - 5.1 x 10 -7
RME - 3.5 x 10 -6
CT - 1.7 x 10 -6
RME - 1.1 x 10 -5
CT - 1.7 x 10 -6

RME - 4.1 x 10 -10
CT - 3.4 x 10 -8
   Predominant COCs(Cancer
Risk Greater than 10 -4, 10 -5,
            10 -6)

    Greater than 1 x 10 -6:
            Arsenic
    Greater than 1 x 10 -6:
            Arsenic
    Greater than 1 x 10 -6:
            Arsenic
                                                                       Greater than 1 x 10 -6:
                                                                               Arsenic
                                                                       Greater than 1 x 10 -6:
                                                                               Arsenic
    Greater than 1 x 10 -6:
            Arsenic
           Beryllium
                                                                                  Summary Results
                                                                                   (Hazard Index)
0.36
0.24
0.82
0.43
0.25
0.18
0.34
0.67
2.73
0.78
0.75
0.16
0.14
0.09
0.31
0.10
0.36
0.24
0.81
0.41
1.22
0.77

0.15
0.10
                                                                               Predominant COCs(HI
                                                                               greater than unity)
                                                                                                                              Cadmium
                                                                                                                              Cadmium
                                                           Cadmium
                                                                                                                              None
                                                                                                                              Cadmium
                                                           Cadmium
-------
 Area of Concern
                        Land Use Scenario
                                    Carcinogenic Risk Results
                                                                Noncarcinogenic Risk Results
Notes:
                                               Summary Results
                                                 (Cancer Risk)
                                                Predominant COCs(Cancer
                                             Risk Greater than 10 -4, 10 -5,
                                                         10 -6)
                                                         Summary Results
                                                          (Hazard Index)
                                                       Predominant COCs(HI
                                                       greater than unity)
NHPC Building
Area(cont'd)
Jones Chemical
Area
Trespass(Phase I)
Tresspass(Phase
II/12/94)
Industrial(Phase I)

Industrial(Phase
II/12/94)
Residential
RME - 8.7 x 10 -7
CT - 4.1 x 10 -7

RME - 1.4 x 10 -11
CT - 6.9 x 10 -12
RME - 3.8 x 10 -6
CT - 1.7 x 10 -6
RME - 1.1 x 10 -10
CT - 5.7 x 10 -11
RME - 5.0 x 10 -5
CT - 8.0 x 10 -6
Greater than 1 x 10 -6:
        Arsenic
   Beryllium(Cont'd)
                                                 Greater than 1 x 10 -5:
                                                         Arsenic
0.27
0.21

0.03
0.03
0.60
0.47
0.07
0.08
0.23
0.12
                                                                                                        None
                                                                       Greater than 1 x 10 -6:
                                                                              Beryllium
                      Trespass

                      Industrial
                         RME - 3.8 x 10 -6
                         CT - 1.9 x 10 -6
                         RME - 1.6 x 10 -5
                         CT - 7.8 x 10 -6
                                                              0.05
                                                              0.04
                                                              0.86
                                                              0.03
RME - Reasonable Maximum Exposure
CT  - Central Tendency Exposure
-------
                                                             TABIiE 6

                                          SUMMARY OF RISK ASSESSMENT RESULTS FOR GROUNDWATER
                                                   NEW HAMPSHIRE PLATING COMPANY SITE
Area Of Concern
                Carcinogenic Risk Results
                                 Noncarcinogenic Risk Results
Background
On Site and Wells
Affected by the
Site
                               Summary
                               Results
NA



RME Receptor:1.4 x 10 -2

CT Receptor: 1.7 x 10 -3
                                 Predominant COCs
                               (Cancer risk estimate
                              greater than 1 x 10 -4
                              1 x 10 -5, or 1 x 10 -6)

                             NA
Greater than 1x10-5:
   1,2-DCA
•  Chloroform

Greater than 1 x 10 -4:
•  1,1-DCE
•  TCE
•  PCE
•  VC
•  Arsenic
 COCs Exceeding
 Federal Primary
     Maximum
Contaminant Levels
Summary
Results


RME Receptor:
CT Receptor:
RME Receptor:

CT Receptor:









Predominant
COCs
(HI greater
than unity)
2.4 • Manganese
1.7
140 • 1,1-DCE
1,2-DCE, total
99 • PCE
• TCE
• Arsenic
• Cadmium
• Manganese
• Nickel
• Chloroform







None

• 1,1,1-TCA
1,1-DCE
• 1,2-DCE
1,2-DCA
• Chloroform
• PCE
• TCE
• VC
• Arsenic
• Cadmium
• Chromium
• Nickel
Notes:
 COG      -  Chemical of concern
 RME      -  Reasonable maximum
             exposure
 CT       - Central tendency exposure
 HI       - Hazard Index
 1,1-DCE  - 1,1-Dichloroethene
 1,2-DCE  - 1,2-Dichloroethene
 1,2-DCA  - 1,2-Dichloroethane
                          1,1,1-TCA  - 1,1,1-Trichloroethane
                          TCE     -    Trichloroethene
                          PCE     -    Tetrachloroethene
                          VC      -    Vinyl chloride
-------
                                                                      TABIiE 7A
                               SUMMARY OF SOURCE CONTROL ALTERNATIVES, REMEDIATION COSTS, AND TIME TO ACHIEVE CLEAN-UP GOALS
                                                           NEW HAMPSHIRE PLATING CO. SITE
        Alternative


1.  No Action

2.  Excavation, Consolidation, and Capping

3.  Excavation, Onsite Solidification, Offsite
    Disposal, and Wetlands Restoration

4.  Excavation, Offsite Disposal, and Wetlands
    Restoration

5.  Chemical Fixation, Onsite Backfilling, and
    Offsite Wetlands Restoration
Volume of Cont. Soils
       to be
     Addressed
     (cubic yard)

      41,000 CY

      41,000 CY

      41,000 CY


      41,000 CY


      41,000 CY
   Estimated
  Net Present
  Worth Cost

   $714,000

 $5,331,600(c)

$22,585,200(d)


$36,215,600(d)


 $7,197,800(c)
Leach/Flush of Soils Time to
      Achieve MCLs at
 Waste Unit Edge(years)(a)
        > 1000

0,  always below MCLs

        0.0000


        0.0000


        0.0000
Leach/Flush of Soils Time to
   Achieve MCLs at Edge of
       Merrimack River
          (years)(b)

            700

0. always below MCLs

           0.0000


           0.0000


           0.0000
NOTES:
      a)   These values represent the time required for soil contaminant levels to diminish to levels where the leachate from the areas of concern  (Lagoons  1-4,
          the Northern and Southern Wetlands, or the building area) leaching into groundwater, do not exceed MCLs or risk-based values. The time required
          represents the duration after the remedial action has been completed.

      b)   These values represent the time required for soil contaminant levels to diminish to levels where the leachate from the areas of concern  (Lagoons  1-4,
          the Northern and Southern Wetlands, or the building area) leaching into groundwater, and mixing and attenuated by groundwater, do not exceed MCLs  or
          risk-based values at the Merrimack River's edge.

      c)   Add $1,936,200 for off-site wetlands mitigation

      d)   Add $1,107,800 for on-site wetlands mitigation
-------
                                                        TABIiE 7B
                           SUMMARY OF MANAGEMENT OF MIGRATION ALTERNATIVES, REMEDIATION COSTS,
                                           AND TIME TO ACHIEVE CLEAN-UP GOALS
                                             NEW HAMPSHIRE PLATING CO. SITE
     Alternative
                                  PRG
GW1: No Action (a)
GW2 :  Institutional Controls
and Monitoring (b)

GW3:  Extraction,
Treatment, and Discharge  (c)

NOTES:
MCLs and
NH AGQS

MCLs and
NH AGQS

MCLs and
NH AGQS
Vol. of Cont.
 Groundwater
    to be
 Addressed  (d)
    (cu ft)

17,418,600  (d)
  17,418,600
  17,418,600
                                Estimated
                               Net Present
                                Worth Cost
 $751,400
 $771,400
$5,644,200
GW Flushing Time
 to Achieve MCLS
at Waste Unit Edge
      (years)
      [TCE/Cd]

   ~ 26/> 1000
     26/54 (e)
     38/184 (f)
GW Flushing Time to
   Achieve MCLs
 at River's Edge
     (years)
     [TCE/Cd]

     ~ 26/700
     - 26/58 (g)


      40/112 (h)
      a) No source control remedial actions are anticipated with GW1.
      b) Assumes that a source control remedial action  (that achieves PRG-W or PRG-ER in soils) , which would be implemented with  GW2  to
         minimize contaminant leaching from soils into groundwater.
      c) Assumes that GW3 is implemented independent of any source control action, and is principally a hydraulic  containment  action  that prevents  the
         offsite migration of groundwater contaminants. This alternative is not meant to address the portion of the plume  already downgradient  of the site.
      d) Estimated combined shallow and deep overburden aguifer groundwater for TCE plume in excess of MCL.
      e) Estimated number of years for contaminated groundwater underlying the site to diminish to MCLS.
      f) Estimated number of years for contaminated groundwater underlying the site to diminish to MCLs, which is  longer than  GW2's because  the
         pumping and treating under GW3 would reduce the flushing of the contaminated portion of the aguifer.
      g) Estimated number of years for contaminated groundwater plume to diminish to MCLs at edge of Merrimack River.
      h) Estimated number of years for contaminated groundwater plume to diminish to MCLs at edge of Merrimack River, which is longer than GW2's
         because the pumping and treating under GW3 would reduce the flushing of the contaminated portion of the aguifer.
         TCE - Trichloroethene
         Cd - Cadmium
-------


























-------
TABLE 12A
CHEMICAL-SPECIFIC ARARs AND  TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
CHEMICAL FIXATION, ON-SITE BACKFILLING,  and OFF-SITE WETLANDS RESTORATION
NEW HAMPSHIRE PLATING COMPANY SITE
PAGE 3 OF 3
                                                                               REQUIREMENT SYNOPSIS
                                                                                                                             ACTIONS  TO BE TAKEN TO ATTAIN
                                                                                                                                       REQUIREMENT
             EPA Final  Groundwater
             Use and Value
             Determination  Guidance
                                             To Be Considered
             NH DES Contaminated
             Sites Risk
             Character!zation  and
             Management  Policy
This regional guidance  establishes an
approach allowing  states  to  play a
pivotal role in determining  the  relative
"use" and "value"  of  site ground
water resources. The  determination
of the aqui fer as  a "high",  "medium",
or "low" use aqui fer  impacts the
appropriateness of restoration  time
periods and the extent  of restoration
of the contaminated ground water
plume as called for in  the remedial
alternatives.
This policy identi fies  a  tiered  risk-
based approach to  characterizing risk
and the process used  to manage
exposures to contaminants remaining
at the site.
The site's groundwater  aqui fer  was
determined to be of  'medium  to  high1  use
and value. SCS will  be  implemented to
provide for the most rapid restoration
possible.
Actions implemented under  SC5  would
conform to this policy1s requirements to
manage exposures.
-------
                                                          TABLE 12B
                           LOCATION-SPECIFIC ARARs; AND TBCs; for SOURCE  CONTROL ALTERNATIVE (SC5)
                         CHEMICAL FIXATION, ON-SITE BACKFILLING, and OFF-SITE  WETLANDS RESTORATION
                                           NEW HAMPSHIRE PLATING COMPANY  SITE
                                                                                             REQUIREMENT SYNOPSIS
                                                                                                                                             ACTIONS TO BE TAKEN  TO ATTAIN
                                                                                                                                                        REQUIREMENT
Federal
Regulatory
Requirements
Protection of Wetlands
(Executive Order 11990),  40
CFR 6.302(a) and 40  CFR  6,
App.  A  (Policy on
Implementing E.O.  11990)
                        Floodplain Management
                        (Executive Order 11988,  40
                        CFR  6.302(b)  and 40 CFR 6,
                        App. A (Policy on
                        Implementing  E.O. 11988)

                        RCRA Floodplain Restrictions
                        for  Solid Waste Disposal
                        Facilities and Practices   (40
                        CFR  257.3-1)
Applicable
                                   Applicable
Federal agencies are  required to avoid
undertaking or providing  assistance for
new construction located  in  wetlands
unless there is no practicable
alternative and the proposed action
includes all practicable  measures to
minimize harm to wetlands which may
result from such use.
Federal agencies are  required to avoid
impacts associated with the
occupancy and modification of a
floodplain and avoid  support of
floodplain development wherever there
is a practicable alternative.
Solid waste practices must not restrict
the flow of a 100-year flood,  reduce
the temporary water storage  capacity
of the floodplain, or result in washout
of solid waste, so as to  pose a hazard
to human li fe, wildli fe,  or  land or water
resources.
Under SC5, soil treatment  and
excavation would result  in the
unavoidable destruction  of the
existing wetland system. Off-site
compensatory wetlands mitigation
would be performed, which  would
comply with this ARAR.

The flood storage capacity within the
100-year floodplain would  not be
diminished once remediation is
completed. SC5 would comply with
this ARAR.
                                                                                                                  Treated  materials that constitute so
                                                                                                                  waste  would be backfilled on site
                                                                                                                  within the  100-year floodplain. The
                                                                                                                  treated  materials would be covered
                                                                                                                  with a soil cover to prevent erosion
                                                                                                                  and washout.  No loss of flood
                                                                                                                  storage  capacity, is anticipated. SC5
                                                                                                                  would  comply with this ARAR.
                                                                                                                                                      • lid
-------
TABLE 12B
LOCATION-SPECIFIC ARARS AND  TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
CHEMICAL FIXATION, ON-SITE BACKFILLING,  and OFF-SITE WETLANDS RESTORATION
NEW HAMPSHIRE PLATING  COMPANY SITE
PAGE 2 OF 4
                                   REQUIREMENT
                                                                                                REQUIREMENT SYNOPSIS
                                                                                                                                                 ACTIONS TO BE TAKEN  TO ATTAIN
                                                                                                                                                        REQUIREMENT
                                                                Applicable
                          These  regulations of which 40 CFR
                          230  are  also known as the CWA
                          Section  404(b)(i) Guidelines, outline
                          requirements for the discharge of areas.
                          dredged  or fill  materials into surface
                          water, including wetlands.  Under
                          these  requirements,  no activity that
                          impacts  a wetland shall be permitted i f
                          a  practicable alternative which would
                          have less adverse impact exists.
                                                  SC5 involves the excavation  and
                                                  treatment of contaminated  soils in the
                                                  former lagoon, wetland  and building
                                                  SC5 would comply with this
                                                  ARAR since there is no  practicable
                                                  alternative that would  have  less
                                                  adverse impacts to the  wetlands and
                                                  the anticipated wetlands loss  would
                                                  be mitigated through an offsite
                                                  action.
                             Endangered Species Act  (16
                             USC 1531 et.  seq.; 40 CFR
                             6.302(h))
Applicable
This statute requires  that  Federal
agencies avoid activities which
j eopardi ze threatened  or endangered
species or adversely modify habitats
essential to their  survival.  Mitigation
measures should be  considered if a
listed species or habitat may be
j eopardi zed.
During the RI, the  effects  on
endangered and threatened  species
were considered and the  U.S.  Fish
and Wildlife  Service was consulted.
No endangered or threatened
species were  identi fied  on  site,  but
their presence has  been  noted  in  the
area.
                                                                                         This regulation requires that  any
                                                                                         Federal agency that proposes to
                                                                                         modi fy a body of water must take
                                                                                         action to prevent, mitigate or
                                                                                         compensate for project-related losses
                                                                                         of fish and wildli fe resources.
                                                                            During the identi fication, screening,
                                                                            and evaluation of alternatives, the
                                                                            effects on fish and wildlife resources
                                                                            were evaluated. If an alternative
                                                                            modifies the wetlands on site, EPA
                                                                            will ensure that losses to these
                                                                            resources will be prevented, mitigated
                                                                            or  compensated and that the U.S.
                                                                            Fish and Wildlife Service will be
                                                                            consulted. SC5 would comply with
                                                                            this ARAR.
-------
TABLE 12B
LOCATION-SPECIFIC ARARs AMD  TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
CHEMICAL FIXATION, ON-SITE BACKFILLING,  and OFF-SITE WETLANDS RESTORATION
NEW HAMPSHIRE PLATING COMPANY SITE
PAGE 3 OF 4
  Federal
  Regulatory
  Requirements
  (Cent'd)
         REQUIREMENT

An Act Relating to  the
Preservation of Historical  and
Archeological Data  (16  USC
469a-l)
Applicable, i f
encountered
                          Archeological Resources
                          Protection Act (16 USC
                          470aa-mm,  36 CFR 296, 32
                          CFR 229,  43 CFR7,  and 18
                          CFR 1312)
                          Rules Relative to Prevention of
                          Pollution from Dredging,
                          Filling,  Mining,  Transporting,
                          and Construction (Env-Ws
                          415)
                                       Relevant and
                                       Appropriate, i f
                                       encountered
                                       Applicable
This statute requires  that,  whenever
any Federal agency  finds  or  is made
aware that its activity in connection
with any construction  project  or
federally licensed  project,  activity or
program may cause irreparable  loss or
destruction of signi ficant scientific,
prehistorical, historical, or
archeological data,  such  agency shall
undertake the recovery, protection and
preservation of  such data or noti fy the
Secretary of Interior. The undertaking
could include a  preliminary  survey (or
other investigation as needed)  and
analysis and publication  of  the reports
resulting from such investigation.
This regulation  develops  procedures for
the protection of archeological
resources.
                          These rules establish criteria for the
                          protection of surface water quality
                          resulting from activities which
                          significantly alter the terrain or occurs
                          in or on the border of surface water.
         ACTIONS  TO  BE  TAKEN TO ATTAIN
            REQUIREMENT
If significant  scientific,  prehistorical,
historical, or  archeological data are
encountered during soil excavation,
steps will be implemented  to recover,
protect and preserve such  data.  SC5
would comply with this  ARAR.
 If archeological  resources  are
 encountered during  soil  excavation,
 they must be reviewed  by Federal and
 State archaeologists.  This
 requirement is applicable to  any
 excavation onsite.  SC5 would  comply.

 Under SC5, the site terrain would be
 modi fled during excavation.
 However, SC5 would  comply with
 this ARAR by regrading and
 vegetating the created storm  water
 retention basins  to prevent erosion or
 washout.
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     TABLE 12B
     LOCATION-SPECIFIC ARARs  AMD TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
     CHEMICAL FIXATION,  ON-SITE BACKFILLING, and OFF-SITE WETLANDS RESTORATION
     NEW HAMPSHIRE PLATING COMPANY SITE
     PAGE 4 OF 4
                                                                                                             REQUIREMENT  SYNOPSIS
                                                                                                                                                    ACTIONS  TO BE  TAKEN TO ATTAIN
                                                                                                                                                             REQUIREMENT
                                       New Hampshire Criteria and
                                       Conditions for Fill and Dredge
                                       in Wetlands  (Env-Wt 300)
                                        Applicable
Criteria,
Advisories,
Guidance
New Hampshire Siting
Regulations for Hazardous
Waste Facilities  (Env-Wm
353.09 and 353.10)
U.S. EPA Memorandum,
"Policy on Floodplains  and
Wetland Assessments for
CERCLA Actions"  (Aug.  6,
1985)
                                       Memorandum of Agreement
                                       (MOA)  between EPA and the
                                       U.S. Department of the Army
                                                                              Applicable
                                                                              To Be Considered
These regulations provide  requirements
for the dredge and/or  fill  of wetlands
and establish criteria  for  protection of
fish, wildli fe, commerce,  and public
recreation. Under this  requirement,  no
activity that impacts  a wetland shall be
permitted i f a practicable  alternative
exists that would have  less adverse
impact on the areas  and environments.
These rules impose restrictions on
where hazardous waste  facilities can
be located, specifically locations  near
geologic fault areas or near floodplains.
This guidance discusses situations  that
require preparation  of  a floodplains or
wetlands assessment, and the factors
which should be considered  in
preparing an assessment, for response
actions undertaken pursuant to section
104 or 106 of CERCLA.
This notice provides clari fication  and
general guidance regarding  the level of
mitigation necessary to demonstrate
compliance with the  Clean Water Act
section 404(b)(1) Guidelines.
This document provides  guidance on
the flexibility that the U.S.  Army  Corps
of Engineers should  be  utilizing when
making determinations  of compliance
with the Section 404(b)(1)  Guidelines,
and guidance on the  use of  mitigation
banks as a means of  providing
compensatory mitigation for Corps
regulatory decisions.
Under SC5, the site  terrain  would be
modi fled during excavation.  SC5
would comply with this ARAR  since
compensatory wetlands would  be
established offsite.
The treated soils would  no  longer be
hazardous by characteristic.  SC5
would comply with this ARAR.

SC5 would be consistent  with  this
TBC because no practicable
alternative outside  the  wetlands or
floodplain exist.
                                                                                                         SC5 would be  consistent  with this
                                                                                                         TBC because all  practicable steps
                                                                                                         have been undertaken to  first avoid
                                                                                                         and then minimi ze  adverse impacts to
                                                                                                         the aquatic ecosystem.
                                                                                                         SC5 would be  consistent  with this
                                                                                                         TBC because an  appropriate level of
                                                                                                         analysis has  been  provided supporting
                                                                                                         the conclusion  that  there is no
                                                                                                         practicable alternative  to the
                                                                                                         treatment, excavation and filling in of
                                                                                                         the on-site wetlands.
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                                                                      TABLE  12C
                                        ACTION-SPECIFIC ARARs AND  TBCs  for  SOURCE CONTROL ALTERNATIVE  (SC5)
                                      CHEMICAL FIXATION, ON-SITE BACKFILLING,  and OFF-SITE WETLANDS RESTORATION
                                                       NEW HAMPSHIRE  PLATING COMPANY SITE
                              REQUIREMENT
Federal
Regulatory
Requirements
RCRA - General
Facility Standards  (40
CFR 264 Subpart B)
Applicable
                     RCRA  -  Groundwater
                     Monitoring (40 CFR
                     264 Subpart  F)
                     Requirements for
                     Hazardous  Waste
                     Tank  Systems (40
                     CFR 264  Subpart J)
                             Applicable
                             Applicable,  i f
                             ex-situ
                             treatment is
                             required

                             Applicable
These regulations  outline  requirements for
general waste analysis,  security,  inspections,
personnel training,  and  handling of ignitable,
reactive or incompatible wastes for hazardous
waste facilities.
The regulations in this  subpart outline
requirements for the safe  design and operation
of a facility, safety equipment,  and
communication systems for  RCRA hazardous
waste facilities.
Details requirements for groundwater
monitoring and responding  to releases from
Solid Waste Management Units.
These regulations  sped fy  the  design,
installation, operation, monitoring, inspection,
contingency plan,  and closure  requirements for
the storage or treatment of hazardous waste
using a tank system.
Details the design,  construction,  operation,
monitoring, inspection,  and contingency plans
for a RCRA surface impoundment. Also
provides three closure options for CERCLA
sites: clean closure,  containment  closure, and
alternate closure.
                                                                                SC5 would comply since long-term and post-
                                                                                closure groundwater monitoring  would be
                                                                                implemented.
                                                                                If ex-situ chemical fixation  is required,  then
                                                                                SC5's use of tank systems would comply
                                                                                with this ARAR.
                                                                                                                                  SC5 would comply since all  lagoon contents
                                                                                                                                  considered "hazardous" would  be  treated and
                                                                                                                                  closure and post-do sure plans will  be
                                                                                                                                  prepared to comply with these requirements
                                                                                                                                  in case not all contaminated  soils can be
                                                                                                                                  practically excavated and treated.
-------
TABLE 12C
ACTION-SPECIFIC ARARs  AMD TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
CHEMICAL FIXATION,  ON-SITE BACKFILLING, and OFF-SITE WETLANDS  RESTORATION
NEW HAMPSHIRE  PLATING  COMPANY SITE
PAGE 2 OF 3
                                                      STATUS
                                                                                                                                                ACTIONS  TO BE TAKEN TO ATTAIN
                                                                                                                                                          REQUIREMENT
Federal
Regulatory
Requirements
(Cent'd)
Requirements  for             Applicable
Hazardous Waste Pile.
(40 CFR 264 Subpart
L)
                                                 Relevant and
                                                 Appropriate

                                                 Applicable
RCRA - Land
Treatment  (40 CFR
264 Subpart M)
New Hampshire
Abandonment of Well
Rules  (Env-We 604)
New Hampshire  Applicable
General Design
Requirements  (Env-
Wm 702.09)
New Hampshire
Environmental and
Health Requirements
(Env-Wm 702 .08)
New Hampshire                Applicable
Monitoring of
Hazardous Waste
Treatment Facilities
(Env-Wm 702 .10-
702.13)
These regulations identi fy design,  operating,
monitoring, closure,  and  post-closure
requirements for the  storage  or treatment of
RCRA hazardous waste  in piles.  If the
hazardous waste is  accumulated  on-site for 90
days or less, these regulations reference 40
CFR 262.34, 264.1,  and 265 Subpart  W,
which allows for the  use  of drip pads.
These regulations detail  the  requirements for
conducting land treatment of  RCRA hazardous
wa s t e.
These requirements  regulate well closure.
                                                                         All hazardous waste treatment  and  transfer
                                                                         facilities are to meet sped fied design
                                                                         requirements.

                                                                         These rules require the operator of  a hazardous
                                                                         waste facility to meet environmental standards
                                                                         for surface water, groundwater, and  air.

                                                                         The regulations specify requirements for
                                                                         installation and operation of  one  or more of the
                                                                         following monitoring systems:
                                                                         •  Groundwater monitoring network
                                                                         •  Air emission monitoring network
SC5's use of the  "pugmill  area" for stockpile
and staging will  comply with these
requirements.
SC5's in-place chemical  fixation process
would be conducted  in  compliance with this
requirement.
The abandonment of  existing monitoring
wells would comply  with  this ARAR.  SC5
would comply.
SC5 on-site treatment  systems would be
designed to meet  these requirements.
                                                          SC5 would  comply since groundwater and air
                                                          emission monitoring consistent with this
                                                          regulation would implemented during the
                                                          remedial action.
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TABLE 12C
ACTION-SPECIFIC ARARs AMD  TBCs for SOURCE CONTROL ALTERNATIVE  (SC5)
CHEMICAL FIXATION,  ON-SITE BACKFILLING,  and OFF-SITE WETLANDS RESTORATION
NEW HAMPSHIRE PLATING COMPANY SITE
PAGE 3 OF 3
                                                         STATUS
                                                                                                                                       ACTIONS TO BE TAKEN TO ATTAIN
                                                                                                                                                 REQUIREMENT
                              New Hampshire
                              General Operation
                              Requirements (Env-
                              Wm 708)
                              New Hampshire
                              Groundwater
                              Protection Rules,
                              Groundwater
                              Management Zone
                              (Env-Ws 410.26)
                              NH Groundwater
                              Protection Rules,
                              Water Quality
                              Sampling,  Analysis,
                              and Reporting;
                              Groundwater
                              Monitoring Wells  (Env-
                              Ws 410.30  and 410.
                              31)
                              New Hampshire Toxic
                              Air Pollutants  (Env-A
                              1302)
                         Applicable
                         Applicable
                         Applicable
                              New Hampshire
                              Testing and
                              Monitoring Procedures
                              (Env-A 805)
                         Applicable
                         Applicable
These rules establish  requirements for
hazardous waste  facility  operation.
These rules establish  the  requirements for
sampling and monitoring  groundwater,  and
sped fy monitoring well  design  and installation.
These rules establish Ambient  Air Limits (AALs)
and air quality impact  analyses  to protect  the
public from concentrations  of  pollutants in
ambient air that may cause  adverse health
effects. If AALs are not met,  then corrective
action, which may include Best Available
Control Technology or Reasonably Available
Control Technology, shall be implemented to
meet the AALs.
These regulations identi fy  requirements for air
emission testing for stationary  sources which
are subj ect to opacity  and/or  emission limits.
\ GMZ will be established for the  delineated
 contaminant plume. Institutional  controls
 such as deed restrictions will be imposed  to
 prevent the use of groundwater within  the
 GMZ as a potable water supply. SC5 would
 comply with this ARAR.
 Under SC5,  groundwater would be sampled
 and monitored in accordance with  these
 requirements to assess groundwater quality
 downgradient of the source areas.
 SC5 remedial actions would be implemented
 to prevent air emissions in excess  of  the
 pertinent AALs.
 During on-site remedial action, air  emissions
 would be monitored and tested to  ensure
 that these sources do not exceed  pertinent
 standards.
New Hampshire
Fugitive Dust, Control
(Env-A 1002)
                                                       Applicable
                                                       Applicable
These regulations require  precautions to
prevent, abate, and control  fugitive dust during
specified activities,  including excavation,
construction, and bulk hauling.
The regulations impose obligations on sources
of air pollution in emergency situations.
 Fugitive dust emissions would be  controlled
 during remedial activities. SC5 would
 comply with this ARAR.

 During remedial actions, SC5 would  comply
 in the event of "warning" and/or
 "emergency" status.
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                                                                            TABLE ISA
                                      CHEMICAL-SPECIFIC ARARs AND TBCs  for  MANAGEMENT OF MIGRATION ALTERNATIVE  (GW2)
                                             NATURAL ATTENUATION WITH INSTITUTIONAL CONTROLS AND MONITORING
                                                            NEW HAMPSHIRE PLATING COMPANY SITE
Federal
Regulatory
Requirements
State
Regulatory
Requirements
SDWA-Maximum
Contaminant
Levels  (MCLs)  (40
CFR 141.11 -
141.16)
New Hampshire
Groundwater
Protection Rules
(Env-Ws, 410.03,
410.04 and
410.05)
                                                 Applicable
MCLs have been promulgated  for a number of
common organic and inorganic  contaminants to
regulate their concentrations in public drinking water
supply systems. MCLs  are  relevant and appropriate
for NHPC groundwater  because  the aquifer beneath
the site is a potential drinking water supply.
 These regulations establish  state ambient groundwater
 quality standards  (AGQSs).  410.03 requires that all
 groundwater of the state  shall  be suitable for drinking,
 shall not contain regulated  contaminants in excess of
 the 410.05 requirements,  and shall result in
 discharges to surface water  in  excess of surface water
 quality standards. The  410.03 regulations are derived
 from MCLs and health-based  limits to protect quality
 of ambient groundwater. Exemptions from
 groundwater quality  criteria (410.04)  include areas
 designated as GMZs.
MCLs were used in determining potential
action levels for the  aquifer.

GW2 would comply with  this  ARAR by
establishing a GMZ,  implementing a source
control action, using  deed  restrictions to
prohibit use of contaminated groundwater for
drinking and allowing  attenuation of the
contaminant plume to occur  over time.
NH AGQSs were used along  with Federal
MCLs in determining  clean-up levels for the
aqui fer. Where the state  AGQSs are more
stringent than Federal MCLs and non-zero
MCLGs, the state standards  were used.

GW2 would comply with  this  ARAR by
establishing a GMZ,  implementing a source
control action, using  deed  restrictions to
prohibit use of contaminated groundwater for
drinking and allowing  attenuation of the
contaminant plume to occur  over time.
-------
TABLE ISA
CHEMICAL-SPECIFIC ARARS AND  TBCs for MANAGEMENT OF MIGRATION ALTERNATIVE  (GW2)
NATURAL ATTENUATION WITH  INSTITUTIONAL CONTROLS AND MONITORING
NEW HAMPSHIRE PLATING COMPANY SITE
PAGE 2 OF 3
                New Hampshire
                Surface Water
                Quality Standards
                 (Env-Ws 430-
                 437)
Relevant          This  regulation establishes water quality criteria  for
and               toxic substances and establishes rules for determining
Appropriate       acceptable  point- and non-point-source discharges to
                  the state's surface waters.
Because contaminated groundwater
originating from the site  is  currently
discharging to the Merrimack  River,  these
regulations were considered in  determining the
level of groundwater treatment  necessary at
the site.
                                                                                                                    Because  under  GW2  a  source control action
                                                                                                                    will be  implemented  to  prevent further
                                                                                                                    degradation  of groundwater quality,  this ARAR
                                                                                                                    will be  met  over time as the attenuation of the
                                                                                                                    contaminant  plume  occurs.
                REQUIREMENT

                New Hampshire
                Primary  Drinking
                Water  Criteria
                 (Env-Ws  316,
                 317 & 319)
                  New Hampshire  MCLs and MCLGs establish
                  contaminant  levels that are allowable in public water
                  supplies,  and  can be used as action levels or clean up
                  standards  for  aqui fers that are potential drinking water
                  sources. The regulations are generally equivalent to
                  SDWA MCLs.
ACTIONS TO BE TAKEN  TO ATTAIN
REQUIREMENT
New Hampshire MCLs,  non-zero  MCLGs  and
SMCLs were used to determine  acceptable
cleanup levels where they  are more  stringent
than federal MCLs  and non-zero MCLGs.
GW2 would comply with this ARAR by
implementing a source control action to
prevent further degradation of groundwater
quality, and using deed  restrictions to prohibit
use of contaminated  groundwater for drinking
and allowing attenuation of the contaminated
plume to occur over  time.
                                                        RfDs are dose levels  developed by EPA for use in
                                                        estimating the non-cardnogenie risk resulting from
                                                        exposure to toxic  substances.
                                                                               RfDs  were used to assess health risks due to
                                                                               exposure  to no n-card no genie chemicals in
                                                                               groundwater,  and to develop of acceptable
                                                                               groundwater PRG concentrations.
                                                                               GW2 would be  consistent with this TBC since
                                                                               remedial  actions would be implemented to
                                                                               prevent  ingestion and mitigate contaminant
                                                                               migration and the PRG concentration levels
                                                                               will  be  met over time as the attenuation of the
                                                                               contaminant plume occurs.
-------
TABIiE ISA
CHEMICAL-SPECIFIC ARARs AND TBCs for MANAGEMENT OF MIGRATION ALTERNATIVE  (GW2)
NATURAL ATTENUATION WITH INSTITUTIONAL CONTROLS AND MONITORING
NEW HAMPSHIRE PLATING COMPANY SITE
PAGE 3 OF 3
Criteria
Advisories
and Guidance
(Continued)
AUTHORITY
Criteria
Advisories
and Guidance
(Continued)
EPA Human
Health
Assessment
Cancer Slope
Factors  (CSFs)
                  REQUIREMENT
EPA Health
Advisories,
Human Health
Risk Assessment
Guidance and
Ecological Risk
Assessment
Guidance
To Be        CSFs are developed by EPA for health effects
Considered   assessment or evaluation by the Human Health
             Assessment Group. These values present the most
             up-to-date cancer risk potency information and are
             used to compute the individual incremental cancer risk
             resulting from exposure to carcinogens.
                   STATUS                      REQUIREMENT SYNOPSIS
To Be        These advisories and guidance documents provide
Considered   guidance for developing health risk information and
             environmental assessment at Superfund sites.
CSFs were used to compute the individual
cancer risk resulting from exposure to
chemicals and in developing acceptable
contaminant levels.
GW2 would be consistent with this TBC since
remedial actions would be implemented to
prevent ingestion and mitigate contaminant
migration and since the PRG concentration
levels will be met over time as the attenuation
of the contaminant plume occurs.

        ACTIONS TO BE TAKEN TO ATTAIN
                  REQUIRED

These advisories and guidance documents
were used in assessing health risks and in
considering environmental effects from
contaminants present at the site. GW2 would
be consistent with this TBC.
                EPA Final
                Groundwater Use
                and Value
                Determination
                Guidance
                 To Be        Provides a rating system for the State to establish
                 Considered   restoration goals for a groundwater aguifer based on
                              its vulnerability, use, and value.
                                                                       This guidance was considered in conjunction
                                                                       with the Federal SDWA and New Hampshire
                                                                       Groundwater Protection Rules in order to
                                                                       determine groundwater cleanup levels. The
                                                                       aguifer was classified as medium to high
                                                                       Value. GW2 is consistent with this TBC.
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                                                   TABLE 13B
                 ACTION-SPECIFIC ARARs AND TBCs for MANAGEMENT OF MIGRATION ALTERNATIVE  (GW2)
                        NATURAL ATTENUATION WITH INSTITUTIONAL CONTROLS AND MONITORING
                                      NEW HAMPSHIRE PLATING COMPANY SITE
  AUTHORITY       REQUIREMENT              STATUS
State           New Hampshire            Applicable
Regulatory      Groundwater Protection
Requirements    Rules, Groundwater
                Management Zone  (Env-
                Ws 410.26)
                New Hampshire            Applicable
                Groundwater Protection
                Rules, Water Quality
                Sampling, Analysis, and
                Reporting; Groundwater
                Monitoring, Wells  (Env-Ws
                410.30 and 410.31)
         REQUIREMENT SYNOPSIS
These regulations specify the requirements of
a GMZ at sites with contaminated
groundwater that exceeds the AGQS.
These rules establish the requirements for
sampling and monitoring groundwater, and
specify monitoring well design and
installation.
  ACTIONS TO BE TAKEN TO ATTAIN
            REQUIREMENT

GW2 would comply with this ARAR. A GMZ
will be established for the delineated
contaminant plumes. Deed restrictions and
local ordinances would be used to prevent
the use of groundwater within the GMZ for
drinking.

GW2 would comply since groundwater
would be sampled and monitored in
accordance with these requirements to
ensure that groundwater quality outside the
GMZ is not degraded.
-------
                                          APPENDIX A
                                   DBS Letter of Concurrence


Patricia L. Meaney, Director
Office of Site Remediation and Restoration
US EPA - Region 1
John F. Kennedy Federal Building (HBO)
1 Congress Street
Boston, MA 02203-2211

SUBJECT: MERRIMACK - New Hampshire Plating Superfund Site, Record of Decision
         Declaration of Concurrence

Dear Ms. Meaney:

   The New Hampshire Department  of Environmental  Services  (Department) has  reviewed  and  concurs with  the
"Record of Decision" (ROD) for the New Hampshire Plating  (NHP) Superfund Site in Merrimack, New
Hampshire. The ROD addresses the remedial actions necessary to address potential threats to human health,
welfare and the environment at NHP which resulted from releases of hazardous substances and documents the
remedial actions to protect human health and the environment.

   EPA prepared the NHP ROD in accordance with  the provisions of  the  Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA).  The Department has participated in the oversight of EPA's Remedial
Investigation, Risk Assessment and Feasibility Study. The Department has also reviewed the various
alternatives and has indicated its support for the selected remedy.

   The selected source control remedy (SC-5)  includes  in-situ treatment  of  metal-contaminated  soils by
chemical fixation and removal, testing and on-site placement of solidified material presently contained
in a temporary storage cell. The management of migration remedy (GW-2) consists of establishing a
Groundwater Management Zone (GMZ),  under WS 410.26,  performing long-term monitoring of groundwater
guality, and allowing the natural attenuation of metals and volatile organic compounds (VOCs) to reduce
these constituents to the State's Ambient Groundwater Quality Standards  (AGQS)  over time. If a municipal
well is installed in a mutually agreeable area outside the GMZ and is later found to be impacted by
on-site contamination,  EPA and the Department will evaluate options to isolate the plume from the well.

   As  a demonstrated state-of-the-art chemical  process,  chemical  fixation can  treat  soils  containing
leachable heavy metals by using in-situ or ex-situ processing eguipment.  In the Department's review of
available literature,  no heavy metal bearing wastes have been found to be resistant to the chemical
fixation process. The intent of the source control remedy is to initially perform a treatability scale
viability demonstration and then use the resultant data of the study to engineer and implement to a full
scale project application.

   Natural attenuation has been  determined by EPA's  consultant, using modeling results developed during
the RI, to be egual or superior to an active pump and treat system because,  with source controls measures
implemented at the site,  there is little difference in the predicted time required to attain AGQS.  In
fact, for some pumping scenarios, the impact was negative due to aguifer characteristics and the
proximity of the Merrimack River. Because the groundwater extraction system would remove approximately 30
to 50 gallons per minute from the aguifer system,  there would be less groundwater available to flush out
the remaining downgradient portion of the aguifer. Hence, a longer remediation time frame would be
required. The management of migration remedy as discussed in the text of the NHP ROD is consistent with
the State's "Draft Guidelines for Selection of Natural Attenuation for Groundwater Restoration under
Env-Ws 410" in that it meets the guidance for implementation of natural attenuation at contaminated sites
and for monitoring of the natural attenuation process.
http://www.state.nh.us                                                      TDD Access: Relay NH
1-800-735-2964
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Patricia L. Meaney, Director
Merrimack - NH Plating Superfund Site
Page 2

    Following  the procedures  outlined  in  EPA' s  guidance  entitled, Ground Water Use  and Value Determination
Guidance, Final Draft, dated April 3,  1996, the Department determined that the groundwater in the
vicinity of the NHP site is medium to high value. This determination is consistent with the Merrimack
Village District's  (MVD) long-term strategy to reevaluate the use of the groundwater in the area as an
alternative to meet future drinking water supply demands. The NHP site is in a high transmissive aguifer
that has potential for high yielding wells. Current indications are that the Town of Merrimack will need
additional drinking water supply sources, which may include the use of the "Horseshoe Pond aguifer,"
within the next decade. The MVD and the Department realize that the guality of the groundwater in this
area has been temporarily impaired by NHP and other industrial activities in the areas which continue to
have significant commercial/industrial activity. Conseguently the Department believes that any future
development of drinking water supply wells in this area will reguire careful aguifer management and will
have to comply with the State's wellhead protection reguirements under Env-Ws 378.

    As  part  of the  remedy, EPA and  the Department have worked  jointly  to secure wetland  areas  to
compensate for the loss of wetland at the NHP site. On March 23, 1998, the State purchased an
ecologically rare and significant wetland in the adjacent Town of Litchfield known as Grassy Pond. The
Department, under an agreement with the EPA, will be reimbursed 90% of its costs once the ROD is
complete. In addition to Grassy Pond,  a second wetland acguisition will occur in the Town of Merrimack.
Negotiations for the so-called Naticook Road wetland in Merrimack,  will begin after the ROD is complete.
If negations fail,  EPA and the Department will help with the Town to identify an alternative wetland of
egual ecological and monetary value.

    The selected remedy will  include a provision to  construct  and sample monitoring wells  on the
Litchfield side of the Merrimack River to determine if contaminated groundwater has migrated under and
across the river.  EPA and the Department will evaluate existing hydrogeologic information from the Town
of Litchfield to help understand groundwater flow and evaluate existing potential receptors as possible
sampling locations. Installation of well couplets will be installed in the shallow and deep overburden
and will be used to determine if NHP-related contamination extends beyond the Merrimack River.

    The Department  reviewed all  information in  the NHP Administrative  Record, evaluated  the cumulative
risks associated with current and future potential exposures to the contaminants whose presence is
associated with a CERCLA release and determined the actions set forth in the NHP ROD are consistent with
State applicable or relevant and appropriate reguirements. Acting as agent for the State of New
Hampshire, the Department concurs with the remedial decision selected under CERCLA for NHP.

    In  striving to  achieve the maximum benefit  with  limited public  (and private)  resources, the Department
continues to seek reasonable and practical solutions to the often costly and complex environmental
challenges associated with contaminated site cleanups. Through the partnership and dedication exhibited
by all parties, the rapid implementation of the actions necessary to protect human health and the
environment will serve to expedite the achievement of our mutual environmental goals and facilitate
efforts to restore the local economy in order to protect the welfare of those in communities surrounding
the NHP site.  As always, the Department stands ready to provide the guidance and assistance EPA may
reguire in order to take the actions necessary to protect human health and the environment in a complete
and cost-effective manner.



A:\MEANEY.LET
cc:    Dana Bisbee, Esg. ,  Assistant Commissioner, NHDES
       Carl W. Baxter, P.E.,  Administrator, Hazardous Waste Remediation Bureau,  WMD
       Richard H.  Pease, P.E., Hazardous Waste Remediation Bureau,  WMD
       Michael Walls, Esg.,  NH Department of Justice
       Richard Boynton, EPA - New England
       Jim Dilorenzo, EPA - New England
-------
                                       APPENDIX B
                                 Responsiveness Summary

                                     FEASIBILITY STUDY

                      NEW HAMPSHIRE  PLATING COMPANY SUPERFUND SITE
                                 MERRIMACK,  NEW HAMPSHIRE
                               CERCLIS ID  NO.  NHD001091453

                                   Tetra Tech  NUS,  Inc.
                               EPA Contract No.  68-W6-0045
                         EPA Work Assignment No.  018-RIFS-01G1
                                 TtNUS Project No.  N7691

                                     SEPTEMBER  1998

                                  TABLE OF CONTENTS
                               RESPONSIVENESS  SUMMARY
                                  FEASIBILITY  STUDY
                            NEW HAMPSHIRE  PLATING COMPANY
                               W.A.  No. 018-RIFS-01G1
SECTION
PREFACE 	
I.
II.
Ill
OVERVIEW (Site history, RI/FS objectives, 	
alternatives evaluated)
A Preferred Alternative
B. General Reaction to the Preferred Alternative 	
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 	
COMMENTS RECEIVED DURING THE PUBLIC COMMENT 	
PAGE
	 1
	 2
3
	 4
	 4
	 5
      PERIOD AND EPA RESPONSES

                                       ATTACHMENTS

A.    COMMUNITY RELATIONS ACTIVITIES  CONDUCTED AT THE  NHPC SUPERFUND SITE IN MERRIMACK, NH

B.    TRANSCRIPT OF THE JANUARY  28, 1998  PUBLIC  HEARING

C.    COMPLETE TEXT OF COMMENTS  RECEIVED  DURING  THE  PUBLIC COMMENT PERIOD
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                                             PREFACE

The U. S. Environmental Protection Agency  (EPA) held a 30-day public comment period, from January 16,
1998 through February 14, 1998, to provide an opportunity for interested parties to comment on EPA's
preferred alternative to address soil and groundwater contamination at the New Hampshire Plating Company
(NHPC) Superfund Site in Merrimack, New Hampshire. The preferred alternative was selected after EPA
developed a feasibility study that scrutinized various options for addressing soil and groundwater
contamination resulting from past waste disposal practices at the site. EPA identified its preliminary
recommendation of a preferred alternative in a proposed plan, issued in January 1998, at the start of the
NHPC public comment period. On the evening of January 15, 1998, EPA conducted a public meeting to discuss
the feasibility study and the preferred alternative. On January 28,  1998, EPA held a formal public
hearing at which two commenters spoke. Six comments were received during the public comment period;  one
commenter responded at the public hearing and in writing three times.

The purpose of this responsiveness summary is to document EPA responses to the comments and questions
raised during the public comment period. EPA considered all of the comments summarized in this document
before selecting the cleanup plan to address soil and groundwater contamination at the site.

The responsiveness summary is divided into the following sections:

Section I.    Overview. This section discusses the site history, outlines the objectives of the
feasibility study, identifies the alternatives evaluated in the feasibility study, and identifies and
summarizes general reaction to EPA's preferred alternative.

Section II.  Background on Community Involvement and Concerns. This section contains a summary of the
history of community interest and concerns regarding the NHPC site.

Section III. Comments Received During the Public Comment Period and EPA's Response to those Comments.
Each written and oral comment from the public and interested parties on the feasibility study and
proposed plan are repeated and responded to directly.

ATTACHMENT A - This attachment provides a list of the community relations activities that EPA has
conducted for the NHPC site.

ATTACHMENT B - This attachment is the transcript of the January 28,  1998, public hearing held in
Merrimack,  New Hampshire.

ATTACHMENT C - This attachment includes the complete text of comments received during the public comment
period.

I.          OVERVIEW

The NHPC Superfund Site is located on Wright Avenue in Merrimack, New Hampshire, a community midway
between Nashua and Manchester. The NHPC site is a 13.1 acre lot where NHPC provided electroplating
services to local industries from 1962 to 1985. Plating process wastes, including metals and organic
solvents, were disposed by discharging to unlined trenches in the building's concrete floor, which
directed wastes through a discharge pipe to four lagoons in a wetland behind the building.

In the early 1980s, the New Hampshire Department of Environmental Services (NHDES) and EPA began attempts
to regulate NHPC's hazardous waste disposal activities under the Resource Conservation and Recovery Act
(RCRA). The state issued a Notice of Violation and Order of Abatement in which New Hampshire Plating was
required to treat its wastes prior to discharge into the lagoons. NHPC ceased operations in 1985 because
it was unable to meet the financial assurance provisions of RCRA and to continue to pursue the field
investigation necessary to determine the nature and extent of the contamination it caused. In 1987,  a
contractor for the state stabilized the plating waste in the lagoon system with lime and a sodium
hypochtorite solution; removed debris, drums, and plating tank liquids; and conducted a limited
decontamination of the NHPC building. An EPA emergency removal action, conducted from 1989 to 1991,
confirmed that a number of volatile organic compounds (VOCs) including trichloroethylene  (TCE) and
1,1,1-trichloroethane (1,1,1-TCA); metals such as arsenic, cadmium,  chromium, lead, zinc; and cyanide
were present in the lagoon system. Since these contaminants were detected in monitoring wells on and
around the site, in July 1991, EPA proposed to add the site to its National Priorities List (NPL),  making
it eligible for funds for long-term cleanup. Final NPL listing occurred in October 1992. Soon thereafter,
EPA initiated a remedial investigation/feasibility study  (RI/FS) for the site.

During the RI, initial data indicated that a portion of the contaminated groundwater beneath the site
might be flowing south toward and possibly underneath Horseshoe Pond. Later investigations determined
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that groundwater was migrating off site and discharging to the Merrimack River. The dilapidated NHPC
building and the contaminated underlying soils resulting from the use of unlined trenches for waste
disposal were deemed potential continuing sources of contamination to soil and groundwater. As a result,
EPA prepared an Engineering Evaluation/Cost Analysis (EE/CA)  to support selection of a short-term action,
referred to as a Non-Time-Critical Removal Action (NTCRA).  NTCRAs allow EPA to spotlight and address
portions of Superfund sites that tend themselves to rapid short-term cleanup approaches. The goal of the
NTCRA was to reduce those sources of contamination,  thereby limiting contaminant migration into
underlying soil and groundwater, while the RI studies necessary for long-term cleanup continued.

In 1993, EPA signed an action memorandum selecting the NTCRA components. They included decontaminating,
dismantling, and disposing the NHPC building and contents;  sampling and potentially removing an
underground storage tank; disposing off site contaminated soil beneath the former building; and placing a
temporary cover over the former building location. These activities were completed in 1994.

In 1996, EPA issued the site-wide RI report; the FS was released in January 1998. A proposed plan,
outlining the findings of the RI and the FS, and detailing EPA's preferred alternative, was sent to the
site mailing list. The proposed plan, and notices in the local newspapers  (Nashua Telegraph, Union
Leader, Village Crier, and Bedford-Merrimack Bulletin), announced the January 15 public meeting, the
January 28 public hearing, and the comment period, extending from January 16 through February 14.

A.         Preferred Alternative

EPA identified cleanup objectives that would address site risks. The objectives included:

    •  minimizing metals leaching from soil into groundwater;  metal contamination rendered groundwater
      unsafe for human consumption

    •  preventing ingestion of groundwater that exceeds levels set to protect human health

    •  minimizing off-site migration of contaminated groundwater and protecting the Merrimack River

    •  preventing contact between burrowing animals and contaminated soil

EPA identified response actions that might be taken to satisfy these objectives that included: no action,
which serves as a comparative baseline; limited action, which restricts access and monitors the site;
contain contamination (leave it where it is and cover it);  move the contamination off site; and treat it
on site.

Based on these general response actions, EPA evaluated five soil alternatives in the FS:

    1    No action
    2    Consolidate contaminated soils, cap them, implement institutional controls
    3    Excavate contaminated soils, solidify them, dispose them off site, restore wetlands
    4    Excavate contaminated soils, dispose them off site,  restore wetlands
    5    Chemically treat contaminated soils in place,  construct an off-site wetland

and three groundwater alternatives:

    1    No action
    2    Establish a Groundwater Management Zone, monitor natural attenuation, and implement deed
         restrictions
    3    Prevent off-site migration  (contain) of contaminated groundwater, treat and discharge it,
         establish a Groundwater Management Zone and implement deed restrictions

After reviewing the FS alternatives against the nine cleanup criteria cited in the regulations, the
proposed plan identified EPA's preferred alternative, which is Alternative 5 for soil and Alternative 2
for groundwater.

The preferred soil alternative included:

    •  treating metals-contaminated soil with a binding agent to significantly reduce leaching  (fixation)
    •  redepositing the treated soil on site in two lagoons
    •  demolishing the temporary storage unit and using its material as additional backfill
    •  constructing or preserving an off-site wetland
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The preferred groundwater alternative included:

    •  implementing a Groundwater Management Zone to monitor the progress of natural attenuation and
      restrict groundwater use

    •  conducting long-term monitoring of surface and groundwater

When combined, Alternatives 5 and 2 will meet all of EPA's objectives for this action. Implementation of
Soil Alternative 5 will prevent the continuing migration of contaminants to groundwater by binding
contaminants to the soil. Once the contaminated soil has been addressed, the level of contamination in
groundwater will naturally attenuate and will achieve the state's groundwater guality standards in the
future.

B.         General Reaction to the Preferred Alternative

Except for one commenter who expressed concern about possible short-term health effects on nearby
residents during excavation activities, little comment was expressed on the preferred soil cleanup
alternative. Of the comments received either in writing or at the public hearing, concerns revolved
around whether the preferred alternative for groundwater (limited action)  took into consideration the
town's need for additional potable water supplies. Other concerns addressed the location of the off-site
wetland mitigation area selected to be protected or constructed to replace wetland functions lost as a
result of the soil cleanup strategy, and whether contaminated groundwater was migrating beneath the
Merrimack River to the Town of Litchfield.

II.        BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The level of community concern about the site was highest in the early 1990s at the end of EPA's
emergency removal action, when town officials learned that waste would remain stored on site
indefinitely. Concerns expressed by people interviewed in the spring of 1993 for the Community Relations
Plan included the credibility of the federal bureaucracy, safety and public health issues  (including the
NHPC building itself) , future uses f or the NHPC site, contamination from other sites, and water supply
guality.

Implementing the NTCRA addressed the first two of these concerns: by decontaminating, dismantling, and
disposing the NHPC building off-site, the public's concern about its safety and public health
implications was reduced. EPA demonstrated that when a threat was defined, guick action was taken to
protect the community. EPA anticipates that implementation of the proposed plan will respond to the three
of four remaining concerns. Although the EPA is working with them, the NHDES has taken the lead on
studying contamination that may be coming from other nearby properties.

Attachment A lists community relations activities conducted at the NHPC site.

III.       COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S RESPONSE TO THOSE COMMENTS

Two people testified at the public hearing: one offered general support for the proposed plan; the second
argued that the groundwater component of the proposed plan was technically unsound and compromised the
town's future drinking water supply source. A copy of the hearing transcript is attached as Attachment B.
Eight written comments were received, one of which was also read into the hearing record. Attachment C
summarizes the written public comments. Appendix D contains the complete text of written comments
submitted during the public comment period.

Comment 1: Soil Alternative 5, the preferred alternative, would result in airborne contamination during
excavation that could impact the health of people living nearby. The commenter prefers Soil Alternative
4, featuring off-site disposal and wetlands restoration.

Response:  Soil excavation is necessary under both Soil Alternatives 4 and 5 so that remediation can be
completed. In Soil Alternative 4, excavation would be reguired to move the contaminated soil into
temporary stockpiles and then loaded into dump trucks for shipping to an off-site location. Soil
Alternative 5 features first treating the soil with a binding agent, then excavating it in successive
"lifts" until subsurface soil is reached that meets acceptable limits. The treated soil would be placed
in Lagoons 1 and 2, covered, and vegetated. Table 3 of the proposed plan indicates that both alternatives
are egually protective, however, Alternative 4 (off-site disposal) is four times more expensive than
Alternative 5. Measures would be taken under either alternative to minimize dust generation and potential
impacts to nearby residences.
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The column entitled "The Nine Criteria for Choosing a Cleanup" on page 7 of the proposed plan explains
the criteria EPA uses to assess alternatives. Number 5, Short-term effectiveness, addresses whether the
cleanup could cause short-term hazards to workers, residents, or the environment. Section 4 of the FS
addresses these issues for both alternatives by stating that, "During monolith [temporary storage unit]
demolition, excavation, truck loading, backfilling and grading,  risks posed by fugitive dusts to off-site
workers [and residents] would be minimized by appropriate engineering control measures  (dust
suppressants, water sprays)." And "While engineering controls can be implemented during excavation,
grading, and loading to minimize impacts of fugitive air emissions, some releases may occur. Air
monitoring would be performed during remediation to assess the need to provide engineering controls or to
stop excavation activities."

Finally, toward the end of the design phase, EPA will hold a public meeting to explain the details of the
remediation, including the steps planned to ensure that there are no unacceptable levels of fugitive
emissions.

Comment 2:  I support the current proposal. I "urge a solution that can bring the site back to viable use
as expeditiously as possible."

Response:   EPA appreciates the Community Development Director's support of the Proposed Plan. By
remediating on-site soils and removing the Temporary Storage Unit, a large portion of the site will be
available for commercial or industrial use. The entire front parcel, which housed the former plating
building,  will be available for unrestricted commercial or industrial use. Approximately 3 to 4 acres of
the rear parcel that will receive the treated soil will be suitable for non-intrusive uses such as a
parking lot or recreational field. The rest of the parcel will remain as wetlands. The entire site lies
within a 100-year floodplain.

It is EPA's intention to perform the soil clean up as guickly as possible. However, as a federal fund
lead, EPA needs to compete with other clean up projects across the nation. It has been EPA's experience
that some projects have reguired as long as three years to secure funding. In the interim, necessary
pre-design and design work will be performed that will reguire about a year to complete.

Comment 3:  Groundwater Alternative 3, Treat Contaminants On Site, would enable the Horseshoe Pond aguifer
to be retained for use as a source of potable water by the year 2008. The preferred alternative,
Groundwater Alternative 2, Limited Action, would not retain the aguifer's high value.

Response:   Groundwater Alternative 2, Limited Action (long-term monitoring and institutional controls)
was formulated as a passive groundwater remedial approach that will be implemented only in conjunction
with active soil remediation. Once the source of groundwater contamination (the metals-laden soil and
sediments on the NHPC property) is addressed (treated,  removed,  covered,  etc.), there will no longer be
any future migration of metals into the underlying groundwater.  With this aggressive source reduction
approach,  the contaminated groundwater will gradually be flushed from the aguifer until levels are
reduced to below the New Hampshire Ambient Groundwater Quality Criteria.

Groundwater Alternative 3, Groundwater Collection, Treatment, and Discharge,  will also, in time, restore
groundwater guality for the portion of the aguifer underlying the NHPC site and extending eastward to the
Merrimack River. Groundwater Alternative 3 was formulated as an active groundwater extraction and
treatment option whether or not any soils  (source) remediation occurred.  The purpose of Groundwater
Alternative 3 is to prevent, contaminated groundwater from migrating from the NHPC site. This means, even
if the soils were never cleaned up, contaminated groundwater would not migrate off site and cause further
degradation of groundwater east of the site. Using a series of interceptor wells, Groundwater Alternative
3 would capture groundwater migrating from the site. In time, groundwater guality for the portion of the
aguifer extending from the site to the Merrimack River would be naturally restored.

Groundwater Alternatives 2 and 3 of the FS were developed based on the following considerations:

1)    there are no current residential or public wells in the site's vicinity.

2)    the current land use is commercial/industrial, and it is expected that the future land use will
      remain the same.

3)    restrictions (WS 410) will be enacted to prevent the use of underlying groundwater as a potable
      supply.

4)    NHDES' groundwater use and value determination.

5)    EPA and NHDES'  desire to develop a cost-effective remedial approach consistent with the aguifer use
      and value.
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The Merrimack Village District (MVD) expressed concern regarding the length of time needed under
Groundwater Alternatives 2 and 3 to restore groundwater guality in the site's vicinity.  The extended
restoration duration would preclude siting a public supply well near Horseshoe Pond, which is located
near the site. Based on a meeting between EPA, the NHDES,  and the MVD on February 13, 1998, the MVD
reguested that EPA prepare a more aggressive groundwater alternative that would result in a shorter
remediation time frame than offered by either Groundwater Alternatives 2 or 3. The MVD stated that
information developed by their consultant (Emery and Garrett) indicated that the area underlying the
"Horseshoe Pond aguifer" could yield sufficient guantities of water for future use.

EPA appreciates the need to identify and protect future potential drinking water supplies in the Town of
Merrimack and the MVD's desire to use this highly productive aguifer. However, EPA and NHDES guestioned
whether it was realistic to install a public water supply well in a commercial/industrial area.

To address the MVD's concern, EPA performed the following activities:

    •  Reviewed the Groundwater Exploration Program Phase I Report (prepared by Emery and Garrett
      Groundwater, Inc. for the MVD) and the state's well siting criteria to determine if a supply well
      placement in the Horseshoe Pond vicinity is practicable

    •  Identified the closest viable location to situate a hypothetical municipal supply well in the
      vicinity of the NHPC Site and within the "Horseshoe Pond aguifer" by reviewing land use zoning,
      groundwater contamination sources, and the state's well siting regulations,

    •  Evaluated whether a hypothetical well could yield a desired 300 to 400 gallons per minute rate by
      assessing the MVD consultant's report and United States Geological Survey geologic and groundwater
      data,

    •  Evaluated whether pumping this hypothetical supply well could potentially induce contaminated
      groundwater to flow from the NHPC site plume to the well.

      A detailed evaluation of the viability of siting a municipal supply well was prepared and forwarded
      to the MVD  (letter report of May 28, 1998 prepared by Brown & Root Environmental,  Inc. on behalf of
      EPA). Based on the assessment of current and future land use,  state well siting regulations, and
      the hydrogeology of the area of interest, EPA concluded the following:

    •  It would be highly infeasible to site a hypothetical municipal supply well in the NHPC site's
      immediate vicinity that would have an adeguate wellhead protection area and a reguired protective
      radius of at least 400 feet. There are five known hazardous waste sites with groundwater concerns
      surrounding the NHPC site.  In addition, land use in the NHPC vicinity is either commercial or
      industrial, and siting a water supply well in this area would be infeasible because of inadeguate
      wellhead protection.

    •  A parcel of undeveloped land situated to the southeast of Horseshoe Pond was identified as a viable
      municipal water supply well siting location because it is adeguately distant from identified
      potential contaminant sources, but within the desirable "Horseshoe Pond Aguifer".

    •  Sustained pumping rates of between 125 to 250 gpm are likely for a hypothetical municipal well
      situated in the undeveloped parcel located southeast of Horseshoe Pond  (higher yields may be
      possible).

    •  Pumping the hypothetical supply well would not likely draw contaminated groundwater from the NHPC
      vicinity to the supply well because of the limited influence over a long distance. Horseshoe Pond
      would recharge the supply well under sustained pumping conditions.

Based on the above assessments, more aggressive remediation of the groundwater plume at the NHPC site
would not allow for a successful siting of a high yield water supply well in the site's immediate
vicinity because of the need to meet state well siting reguirements, its proximity to four known
hazardous waste sites, and its proximity to commercially and industrially zoned lands and properties.
Therefore, consideration of a more aggressive active groundwater remediation system to address the NHPC
groundwater plume will not be pursued further.

Comment 4: The commenter raises several points:

a) The model used indicates that limited action (Groundwater Alternative 2)  would attain cleanup goals
   faster than the active remediation (Groundwater Alternative 3). The model must not be representative
   of real conditions.
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b)  Describe how modeling was conducted, and present a discussion of why more realistic cleanup
   alternatives were not evaluated or presented.

c)  Describe how EPA's proposed cleanup plan will affect the MVD's future use for a well in the Horseshoe
   Pond area, because the MVD is concerned about obtaining "new source approval" status.

Response:  EPA's response parallels the comments characterizations.

a)  A groundwater fate and transport model was used during the FS Report development to estimate the
   approximate number of years needed to restore, groundwater guality to acceptable levels, which are the
   state's Ambient Groundwater Quality Criteria. The details, assumptions,  input values, and printouts of
   numerous iterations are presented in the FS Report. As indicated in the previous response, the
   groundwater alternatives were based on current and projected future aguifer use considerations. The
   focus of the modeling was to assess the effect of performing different degrees of contaminated soil
   remediation, thereby improving and protecting groundwater guality in the long term through a more
   passive approach.

   Groundwater Alternative 2 assumed that a level of source control, meaning active remediation of the
   soil, would be enacted, thereby eliminating further contaminant migration into groundwater. Aguifer
   contaminants, meaning contaminants in the groundwater and those adsorbed to saturated soil particles,
   would gradually be flushed out by precipitation infiltration and by groundwater entering the affected
   portion of the aguifer. Based on the most aggressive remediation of soils possible, the model
   estimates that up to 54 years may be reguired before contaminant levels diminish to the Ambient
   Groundwater Quality Standards throughout the plume.

   Based on the considerations discussed in the response to Comment 3, Groundwater Alternative 3 was
   developed to prevent contaminant migration off site from the NHPC property regardless of whether the
   source control cleanup was implemented. Only one line of interceptor wells was considered because of
   the proximity of the site to the Merrimack River. At the time the FS Report was being prepared (prior
   to the public comment period) ,  there had been no indication from either town officials or the state
   that groundwater in the site's vicinity would be considered for future drinking water, considering
   the nearby industrial land use, the number of active industrial and commercial facilities, and the
   proximity of the railroad tracks and sewer lines. In this particular scenario, one line of interceptor
   wells would be effective in capturing contaminated groundwater occurring at the NHPC site. The
   groundwater that had already left the site would continue on its path to the Merrimack River. Because
   the groundwater extraction system would remove approximately 30 to 50 gallons per minute from the
   aguifer system, there would be less groundwater available to flush out the remaining downgradient
   portion of the aguifer. Hence,  a longer remediation time frame would be reguired.

   Information used in the model was developed during the RI, or was supplemented by data from various
   literature and journal sources. The same input parameters were applied for each model run for each
   groundwater alternative including: size and concentration of contaminant plume, thickness of the
   aguifer, hydraulic gradient, porosity, precipitation and infiltration, contaminant retardation rates,
   and contaminant partitioning coefficients, etc. The differences in modeling for each alternative
   related to how the groundwater was being removed from the aguifer: under natural flow conditions, or
   under artificial conditions by pumping.

b)  During the development of Groundwater Alternative 3, active groundwater extraction and treatment and
   several variations were considered. An evaluation considered recharging extracted and treated
   groundwater into the NHPC site to aid in flushing the contaminants from the aguifer. Appendix D of the
   FS Report presents a hydrogeologic evaluation of recharging (injecting)  the treated groundwater on
   site.

   Groundwater would be extracted from the shallow overburden aguifer and from the deep overburden
   aguifer; these two aguifers appear to be separated by a semi-confining unit. Discharging treated water
   into the shallow overburden would be difficult because of its limited thickness and low hydraulic
   conductivity, meaning the shallow overburden aguifer would not be able to accept the estimated 30 to
   50 gallons per minute of water that would need to be reinjected. Injecting treated water into the deep
   overburden was more plausible because it is a more hydraulically conductive unit. Mounding of
   groundwater would occur, which could benefit flushing, but could foster contaminant migration in other
   directions  (toward Horseshoe Pond) if not captured by Ihe extraction well. Excess groundwater could
   also be injected into the bedrock aguifer; however, because of the uncertainties and the nature of
   fractured bedrock, the injected water could "short circuit" and discharge to the overburden aguifer,
   causing complications in the extraction system or causing contaminants to migrate in an undesired
   manner. Because of the unknowns, potential for fostering contaminant migration through reinjection,
   the inability of the shallow overburden to accept treated groundwater, and the considerations cited
   previously, and lack of any groundwater users in the vicinity of the site, an active aguifer flushing
-------
   alternative was not pursued.

   Because of the MVD's concern regarding the extended remediation time frame under Groundwater
   Alternatives 2 and 3, EPA and MVD did discuss the possible development of a more aggressive active
   aquifer flushing alternative, if information was developed that indicated that situating a municipal
   supply well in the NHPC site's vicinity was viable. However, following the completion of the well
   siting and hydrogeologic evaluation  (see Response to Comment 3),  it was determined that developing
   another groundwater remediation option was unnecessary.

   EPA has expended considerable effort to assess whether a municipal supply well could be situated in
   the vicinity of the NHPC site vicinity. As presented in the response to Comment 3, EPA's well siting
   and hydrogeologic evaluations concluded that the proximity to several industrial facilities (which are
   known or potential groundwater contamination sources) ,  to the sewer line that runs parallel to the
   Boston and Maine railroad right of way, and proximity to Daniel Webster Highway commercial facilities
   (gas stations, automobile painting establishments, dry cleaners,  etc.) would preclude establishing a
   public supply well near the NHPC site. However, EPA did identify a parcel of undeveloped land that is
   in the area of the "Horseshoe Pond aquifer" that could potentially be developed as a well field. Any
   alternative, whether passive or active, will require that a WS 410 GMZ be established until ambient
   groundwater quality standards are attained. No well can be installed within a GMZ during the
   remediation time frame. However, this undeveloped parcel falls outside the GMZ and could be more fully
   evaluated and potentially developed to meet the MVD's needs in a much shorter time frame.

Comment 5: One commenter opposes selection of a wetland mitigation area not within the Town of Merrimack.

Response:  As explained in a letter from EPA Region 1 to the Nature Conservancy on March 4, 1998, EPA
intends to purchase two wetland areas to compensate for the unavoidable loss of wetlands on the New
Hampshire Plating Site. EPA has been pursuing a unique and threatened wetland located in the Town of
Litchfield (Grassy Pond) as adequate mitigation. On March 23, 1998,  EPA and the NHDES purchased Grassy
Pond to stop imminent development. However, EPA realizes that the benefit to the Merrimack community from
the preservation of Grassy Pond is not adequate because the property is located on the opposite side of
the Merrimack River. EPA therefore intends to purchase an unnamed wetland in the Town of Merrimack to:
(1) address the Conservation Commission's desire to compensate for the loss of on-site wetlands within
the town; (2) ensure adequate mitigation for wetlands loss through the joint preservation efforts; and
(3) ensure well-head protection for town wells. If the purchase of this property is not viable, i.e. the
owner will not sell, EPA will work with the Conservation Commission to determine other suitable
compensation.

Comment 6: Two commenters  (the Merrimack Conservation Commission and the Merrimack Village District
Wellhead Protection Committee) support selection of land denoted in town tax maps as Lot 3B-260  (the
White Pine Swamp Area) as the wetland mitigation area discussed in the proposed plan. The Conservation
Commission notes that this land "is within the wellhead protection area of Merrimack Village District
Wells No. 1,  2, and 3."

Response:  EPA intends to purchase the unnamed wetland in the Town of Merrimack. Lot 260 of Tax Map 3B is
among the properties being considered. EPA has began the process of securing this property, in
cooperation with the Nature Conservancy, by hiring an independent certified appraiser and performing a
use and value wetland delineation.

Comment 7: One commenter requests that the selected remedy include a provision to construct and sample
monitoring wells on the Litchfield side of the Merrimack River to determine if contaminated groundwater
has migrated "deeper into the water table and potentially move(d) under and across..." the river. The
commenter requests that sampling results be sent to the Litchfield Board of Health and the Conservation
Commission.  The commenter encloses a copy of the town tax maps with names and addresses of property
owners.

Response:  During the RI, wells were not installed on the Litchfield side of the river because:  (1)
contamination is confined primarily to the shallow overburden aquifer on the Merrimack side of the river
and it is likely that the contaminants are discharging to the Merrimack River and (2) groundwater flow on
the Litchfield side is likely to be toward the river. However, to address the Town's concern, EPA will
perform the following activities:  (1) evaluate any existing hydrogeologic, information from the Town of
Litchfield to help understand groundwater flow  (2) evaluate existing potential receptors, i.e. well
users, as possible sampling locations and  (3) determine the best location and number of wells that should
be installed as permanent long-term monitoring points. EPA may need assistance from the town to obtain
access to potential well locations through use of public land or rights of way. EPA will request the town
designate an official representative, i.e. health officer, to coordinate well installations and submit
future data.
-------
Comment 8:   One commenter requests that EPA conduct a public hearing on this issue for the information
and education of the residents of Litchfield

Response:    As stated above,  EPA believes that the Litchfield aquifer is not affected by the NH Platinq
plume. Hopefully,  this finding will be confirmed through the initial and long-term periodic monitoring of
existing and/or newly installed wells in Litchfield. EPA believes that this issue does not warrant a
public hearing that may have the unintended result of worrying area residents without basis. Instead,
EPA:  (1) addressed the Litchfield selectmen in a public forum (2) will contact area property owners for
permission to access existing and/or install wells for sampling and (3)  will hold a public hearing later
if sampling results indicate a potential problem exists.

Several comments were offered after the close of the public hearing.

Comment:     What is the executive order referenced at the public meeting?

Response:    President Clinton has ordered that sites that can complete all cleanup levels stipulated in
their RODs by the end of the year 2000 should receive priority for funding.

Comment:     Does the approximately $10 million estimated cost of the proposed plan include funds spent
to date on the site?

Response:    No. It does not include the money spent conducting the two removal actions in 1989 and 1994
and the RI/FS. The total past costs for the site are approximately $7 million.

Comment:     Who owns the site?

Response:    The former plating company owners still hold the titles.  EPA holds a lien on them and back
taxes are due the town. EPA will not take the properties but the town could take the land without
incurring liability.

Comment:  If the town took the land, could the area behind the former building be used as a recreation
area?

Response: Yes. A portion of the lagoon system will receive the treated soil so the area would be
flattened out. Uses such as a parking lot, a playing field, or any other use that does not include
excavation should be acceptable. Excluding areas that will continue to be wetlands, approximately 3 to 4
acres could be available for such uses.

Comment:  Does the proposed plan include any land use restriction on abutting properties?

Response: The only restriction would be that wells in the Groundwater Management Zone could not be used
for potable purposes.

Comment:  Is EPA working with the NHDES to monitor abutting properties?

Response: Yes. NHDES is the lead; EPA is working with the state.
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                            ATTACHMENT A

           COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE NHPC
                 SUPERFUND SITE IN MERRIMACK, NEW HAMPSHIRE

Community relations activities conducted at the NHPC Site include:

      •       EPA conducted local  interviews  to assist in developing a Community Relations  Plan (April/May
              1993).

              EPA issued the NHPC  Community Relations  Plan (July 1993).

      •       EPA published notices in early  November  1993 in the Nashua Telegraph,  Union Leader,  Village
              Crier,  and Bedford-Merrimack Bulletin announcing the establishment of  the  Administrative
              Record for the NTCRA and the date of the public meeting and public hearing to discuss  the
              NTCRA preferred alternative and solicit  public  comment on the preferred alternative.

      •       EPA released a fact  sheet,  dated November 1993,  discussing the EE/CA and its  preferred
              alternative for the  NTCRA.

      •       EPA conducted a public meeting  to discuss the preferred alternative and a  public hearing to
              solicit public comment on the preferred  alternative.  Both activities were  held on November
              15,  1993.  Twenty-six people signed the sign-in  sheet;  eight people testified  during  the
              public hearing.  A copy of the hearing transcript is included in the Administrative Record  at
              the Information Repositories at the Merrimack Public Library and at the EPA Records  Center.

      •       EPA conducted a public comment  period from November 3  through December 2,  1993.  Two  people
              submitted  written comments.

      •       EPA issued a press release on February 24,  1994,  announcing it would remove the NHPC
              building the following summer.

      •       EPA issued a press release on November 3,  1994,  announcing the initiation  of  the removal
              action on  the NHPC building.

      •       EPA published notices in January 1998, in the Nashua Telegraph,  Union  Leader,  Village  Crier,
              and Broadcaster announcing the  establishment of the Administrative Record  for the RI/FS, and
              the dates  of the public meeting,  the public hearing,  and public comment period.

      •       In early January 1998,  EPA issued a proposed plan,  which described the results of the  RI and
              FS,  and identified EPA's preferred cleanup alternative.  The proposed plan  was sent to  the
              NHPC site  mailing list.


      •       EPA conducted a public meeting  on January 15, 1998,  to discuss the Preferred  Alternative.
              Eleven people signed the sign-in sheet.

      •       EPA conducted a public hearing  on January 28, 1998,  to solicit public  comment on the
              Preferred  Alternative.  Twelve people signed the sign-in sheet:  two people  testified  during
              the hearing.

      •       EPA conducted a public comment  period from January 16,  1998 through February  14,  1998. Eight
              written comments were submitted.

              EPA and NHDES met with the Merrimack Village District  on February 13,  1998.

              EPA and NHDES met with the Litchfield selectmen on April 13,  1998.
-------
                              ATTACHMENT B

            TRANSCRIPT OF THE JANUARY 28, 1998 PUBLIC  HEARING

                            EPA REGION 1 NEW ENGLAND

                         NEW HAMPSHIRE PLATING COMPANY
                                SUPERFUND SITE

                  Public Hearing in Merrimack, New Hampshire

                                January 28, 1998

This hearing held at the Courtroom at Merrimack Town Hall,  6  Baboosic Lake  Road,
                       Merrimack, New Hampshire 03054

                           LEGAL DEPOSITION SERVICE

               PROFESSIONAL AUDIO RECORDING AND TRANSCRIPTION SERVICE

                      JO ANN M. BREEN •  CORI CRUMB

56 LOGGING HILL ROAD                               BOW, NEW HAMPSHIRE
03304
                        603-225-4301 / 888-834-8581
-------
EPA PUBLIC HEARING IN MERRIMACK, N.H. - January 28,1998

                            APPEARANCES
 RICHARD BOYNTON, Hearing Officer
 U.S. EPA - Region 1
 Office of Site Remediation & Restoration
 1 Congress Street
 Boston, MA. 02203
 JAMES DiLORENZO, Remedial Project Manager
 U.S. EPA (HBO)
 J.F.K. Building
 Boston, MA. 02203
 BETSY HORNE, Community Relations Specialist
 Brown & Root Environmental
 55 Jonspin Road
 Wilmington,  MA. 01887
 ANGELA BONARRIGO, Community Involvement Coordinator
 U.S. EPA
 J.F.K. Building  (RAA)
 Boston, MA. 02203
 CARL BAXTER, N.H. DES Chief
 TAL HUBBARD, N.H. DES State Project Manager

LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,1998        Page 1





 1                 MR.  BOYNTON:  Good evening.  My name





 2       is Richard Boynton.  I'm the supervisor in EPA's Superfund





 3       Program out of the Boston office. I have the





 4       responsibility for implementing response actions at the





 5       National Priorities  List sites in New Hampshire. I think





 6       we have 18. I'11 be  the Hearing Officer for tonight's





 7       hearing on the New Hampshire Plating Superfund Site.  Also





 8       present with me tonight are James DiLorenzo, who is U.S.





 9       EPA's project  manager for the site; Angela Bonarrigo in the





10       front row,  who is our community relations specialist; Betsy





11       Home of Brown and Root Environmental at the table near the





12       door and to my left  is  Carl Baxter, who is New Hampshire





13       DES chief for  the Bureau of Waste Management and Tal





14       Hubbard of the New Hampshire DES. He's the project manager





15       for the state.  The purpose for this hearing is to





16       accept oral comments on the New Hampshire Plating





17       Feasibility Study and on EPA's proposed plan for addressing





18       the contamination at the site. This is a formal hearing





19       and we will not be responding to the comments tonight but





20       will respond to them in writing after the closure of the





21       comment period in a  document called a Responsiveness





22       Summary.





23            EPA conducted a public information meeting on the





24       Feasibility Study Proposed Plan on January 15th at this





   LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H. - January 28,  1998        Page 2





 1             location. At that meeting we presented information





 2            concerning the proposed plan and responded to guestions





 3            about the site. The public comment period began on January





 4            16th, 1998 and will end on February 14th, 1998.





 5                 Now, let me describe the format of the hearing.  First





 6            Jim DiLorenzo will give a brief overview of the proposed





 7            plan to clean up the site. Following Jim's presentation we





 8            will accept oral comments for the record. If you wish to





 9            make a comment please fill out an index card, available





10            from Betsy in the rear of the room and also we have extra





11            copies of the proposed plan available if you don't have





12            one. I'll call on those wishing to make comments in the





13            order in which I receive the cards. When I call on you I





14            would ask you to stand and come forward,  we have a





15            microphone, and state your name and address and





16            affiliation.  The reason for this is we're recording these





17            proceedings verbatim and we'll need this information for





18            the record. If you have comments that may take longer than





19            say, 15 minutes, please summarize your main points and





20            provide us with a copy of the full text which I'll enter





21            into the record in its entirety. Following your comments





22            anybody at the table,  Jim, I or the State, may ask you a





23            guestion regarding your statement for clarification.  After





24            all the comments have been heard I will close the formal





   LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998        Page 3








 1       hearing and at that point we can take guestions that will





 2       be off the record.  If you wish to submit written comments





 3       you can give those  to us tonight or you can mail them to





 4       our Boston office and the address is in the proposed plan.





 5       If you have any guestions about how to submit comments you





 6       can  talk to Angela or anyone of us. As I mentioned





 7       earlier,  we will have a Responsiveness Summary that will





 8       become part of the  administrative record for the site and





 9       it will be included with our record of decision that we





10       prepare at the end  of the comment period.





11            Are there any  guestions about the format for the





12       hearing? (No response from the audience). Before I ask Jim





13       to talk about the site I just wanted to mention that we





14       have received a comment from the Merrimack Village District





15       dated January 12th, 1997. I want to correct that for the





16       record and that date should be 1998. This comment in





17       general talks about the Horseshoe Pond aguifer which may be





18       needed by the year  2008. This letter, signed by Mr.





19       Moreau, the chairman, will be entered into the record in





20       its  entirety as part of the comments.





21            We also received some comments from some local





22       residents who were  concerned about the implementation of





23       the actual work at  the site and what kind of risks that





24       might cause them as local people living near the site.





   LEGAL DEPOSITION SERVICE
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  EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998        Page 4





 1     With that,  Jim why don't you begin.





 2             MR.  DiLORENZO:  What I'm going to do is





 3     provide a very brief overview of what's already in the





 4     proposed plan just to try to clarify the main points of





 5     what is contained in that document.  I'm sure many of you





 6     have come here with guestions and we want to get right to





 7     those statements and guestions.





 8             So with that in mind, the proposed plan puts forth





 9     EPA's remedy for the New Hampshire Plating Superfund Site,





10     which is located off of Wright Ave.  and is delineated here





11     on this map and the proposed plan. It includes  treatment





12     of soil and groundwater, active treatment of soil,  passive





13     treatment of groundwater. What that means is that the





14     soil, which contains primarily cadmium but also many other





15     plating metals,  will be treated on site. The contaminated





16     soil currently exists in the former lagoon locations where





17     they were discharged from the plating facility and





18     underneath the former plating building itself.  So this





19     area here and throughout this area here. Together that





20     represents about 40,000 yards of contaminated soil. The





21     soil will be treated down to the groundwater table on-site





22     through a process called chemical fixation. The purpose of





23     which is to eliminate the leach-ability of the  metals





24     through treatment of the metals itself. It chemically





  LEGAL DEPOSITION SERVICE
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  EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998        Page 5





 1       binds the metals to the soil rendering them unleachable.





 2       That process would be performed on-site in one-foot lifts.





 3       The process involves spraying the soil with this reagent





 4       which reacts with the soil in a 24 hour time frame and





 5       renders the soil unleachable. It is excavated in one-foot





 6       lifts,  temporarily stockpiled.  Once all the soil has been





 7       treated it will be redeposited back in roughly this area  of





 8       the  site and revegetated, the top of it will be





 9       revegetated.





10            Once that is done, that will remove the ongoing source





11       of contamination to the groundwater.  The groundwater right





12       now is  contaminated with the same metals,  primarily Cadmium





13       and also some solvents, primarily Trichloroethene. The





14       solvents were not found in the soils  on-site, we tested for





15       them but they are in the groundwater. I want to note too





16       that the groundwater contamination is limited to the





17       shallow aguifer. We did sample the shallow, which is





18       basically the water table aguifer. And then there's also





19       a deeper aguifer which was sampled. That had some traces  of





20       the  metals but no contamination that exceeds ambient





21       groundwater guality standards.  That's also true of the





22       bedrock. So the contamination is limited to the shallow





23       aguifer.





24            What we're proposing to do with groundwater is once








  LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998     Page 6





 1    the source of contamination is removed and treated we feel





 2    that over a period of time,  26 to 54 years,  that





 3    groundwater will attenuate.  And we would propose





 4    establishing a groundwater management zone around





 5    basically this area here,  something of that fashion.  What





 6    that groundwater management zone does is establishes  a





 7    monitoring program and establishes restrictions on





 8    groundwater use in that area.  Currently the only





 9    groundwater user is the Jones  Chemical Corporation who has





10    a production well. What we would be looking to restrict is





11    water used for potable uses. So that would act to protect





12    the public in terms of not allowing them to drink the water





13    and establish a monitoring program to ensure that the





14    levels do begin to decrease once the source control is





15    complete. We would expect to see a decrease begin within





16    five years after the start of  the remedy.  If not, then we





17    would re-evaluate the approach at that time.





18          Included in the monitoring program,  we will continue





19    to sample surface water on Horseshoe Pond and the Merrimack





20    River. Past sampling has indicated no impact to those





21    surface water bodies and we would expect that trend to





22    continue. With that done that  would open for re-use this





23    front parcel as industrial/commercial redevelopment in the





24    future. This back parcel would have some use in the





   LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998        Page 7





 1            nonwetland areas.  These former lagoons were a wetland and





 2            are reguired under the Clean Water Act and the Federal





 3            Executive Order to be  either restored or compensated.





 4                   As I said earlier,  we need to excavate material from





 5            this area no matter which remedial approach we take.





 6            Therefore,  impact to the wetlands is unavoidable,  in fact





 7            it's already been impacted by the former plating operation.





 8            So what we're proposing to do is leave the treated material





 9            on-site which is going to reguire us to compensate for the





10            approximately three acre wetland. For compensatory





11            measures we are working with the Merrimack Conservation





12            Commission and others  to find suitable off-site locations,





13            either inside the town or outside the town. The preference





14            is to find something in the same watershed area and in near





15            proximity to the site  if possible.





16                   With that said, the plan schedule is to have a





17            Responsiveness Summary following the close of the public





18            comment period on February 14. Thirty to 60 days we will





19            have a record of decision out with our final determination.





20            Any issues that are raised will be responded to in writing





21            and we could also discuss them in an informal fashion





22            directly if you would  like during that time period. Once





23            those issues are addressed we would anticipate having a





24            record of decision in  30 to 60 days, sometime hopefully by








   LEGAL DEPOSITION SERVICE
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  EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998           Page





 1  the end of March,  and then we would have to compete for





 2  federal funds to perform the work.  Right now I don't have





 3  a firm estimate of how long that may take.  It's a





 4  federally funded project and it could take several months





 5  or even longer to obtain the funding. So that is hard to





 6  predict. But once we have the record of decision finalized





 7  it will be put forth to a national  review panel who looks





 8  at this remedial action and all the other remedial actions





 9  that EPA is putting forth across the country and they





10  basically rank them and determine who gets funding for





11  what. The entire cost of this proposed remedy is just shy





12  of ten million dollars including the soil treatment, the





13  monitoring program and any incidental costs with the





14  institutional controls, the groundwater management zone.





15         So with that said, once the  soil treatment starts we





16  estimate it would take two years to complete. I think that





17  covers everything in a nutshell. Like Richard said, we'll





18  open it up to formal comments now and then afterwards, once





19  we close the hearing, if you want to come up and ask





20  specific guestions we'll hang around as long as it takes to





21  try to answer them. Thank you.





22          MR. BOYNTON: The first person to make





23  a comment is Mr. Jay Minkarah,  Town of Merrimack Community





24  Development Director.








  LEGAL DEPOSITION SERVICE
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  EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998      Page 9





 1         MR.  MINKARAH: I'll keep my comments





 2  brief and I have to apologize because I don't really have





 3  a strong understanding of the technical aspects of the





 4  cleanup. Overall,  as I understand it the current proposal





 5  is most likely the proposal that would most swiftly return





 6  the property to an economically viable use, which from the





 7  prospective of the Community Development Department is our





 8  greatest interest. From that perspective I think at this





 9  point I am at least supportive of the current proposal.  We





10  certainly do have concerns that the  cleanup be done in a





11  manner that protects the interests of the existing viable





12  uses in the area.  We do have active  industrial sites and





13  we certainly have a concern that there not be an adverse





14  impact to those.





15        We do have a concern for the quality of the





16  groundwater and the speed in which it will be restored to





17  an acceptable level. However, from my limited





18  understanding it appears that the alternative that is





19  currently proposed, basically the attenuation, is probably





20  as effective as any more aggressive  approach. Perhaps I'm





21  wrong in understanding that but that seems to be -- that is





22  at least my understanding. Otherwise I would just urge a





23  solution that can bring this site back to viable use as





24  expeditiously as possible. Thank you.





  LEGAL DEPOSITION SERVICE
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   EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998       Page 10





 1              MR.  BOYNTON:  The next comment is from





 2  Mr.  Brian J. Wilson,  Merrimack Village District.





 3              MR.  WILSON:  Good evening.  I have a





 4       letter dated today.  It's directed at Mr.  Jim DiLorenzo and





 5       I need to read it into the record





 6              MR.  BOYNTON:  If you'd like to and





 7       then  if you could just hand it  to us,  if it's not 25 pages





 8       long.





 9              MR.  WILSON:  No, actually  it's only





10       two and I think I can go through it pretty good.  This is





11       in  comment after the fact that  we came to the informational





12       meeting, we asked some questions, we heard some answers and





13       we sat down and thought about how we felt about the whole





14       project itself.





15              The Merrimack Village District Wellhead Protection





16       Committee has reviewed the proposed plan for the New





17       Hampshire Plating Superfund Site. While we agree with the





18       soil cleanup portion of the plan we are extremely concerned





19       about the groundwater cleanup proposal. We understand that





20       this portion of the project consists of Alternative 2:





21       Limited Action.  The limited action would indeed be





22       limited, providing only natural  attenuation of groundwater





23       pollution.  This is virtually the same as the No Action





24       alternative with the minor exception that a groundwater





   LEGAL DEPOSITION SERVICE
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  EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998       Page 11





 1      management zone be established and there would be long term





 2      monitoring of the groundwater.





 3           We are also concerned with evaluation that was done





 4      for the project. Your table 4 of the proposed plan dated





 5      January 19, 1998 shows Alternative 2 with a shorter cleanup





 6      time for groundwater than Alternative 3, an active cleanup.





 7      We suspect the modeling that this is based on is not





 8      representative of real conditions since it suggests that





 9      your pump and treat system be less effective than no system





10      at all. What are the assumptions used in the model? We do





11      not believe that the model or the evaluation represents





12      what would really happen if a competent groundwater cleanup





13      scenario were used. We do not agree that the only





14      groundwater cleanup option available would make the





15      situation worse instead of better. Perhaps the model's





16      assumption should be re-examined or the cleanup scenario





17      should be modified so that it represents a more realistic





18      situation.





19           The town of Merrimack's water situation is such that





20      we cannot afford to write off major sources of water.  The





21      Horseshoe Pond aguifer is such a source. We have not





22      tested the area because of the presence of this superfund





23      site, however our hydrogeologic evaluation of the town





24      identified it as one of the highest, if not the highest,





  LEGAL DEPOSITION SERVICE
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    EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998        Page 12





 1       groups in Merrimack.  The same hydrogeologic study also





 2       revealed to us that are no other sites left in Merrimack.





 3       Our two most recent well sites are located just over the





 4       town line in Hollis because of the fact that there were no





 5       other sites left in Merrimack.





 6            The town is also working with DES to get Merrimack





 7       industrial metal sites cleaned up as soon as possible so





 8       that we may restore well 6 to good production capability.





 9       Once well 6 has been restored our next most cost effective





10       alternative is to purchase water from one of our neighbors.





11       Somewhat less cost effective is an intake and treatment





12       plant on the Merrimack River. Currently not a very





13       practical alternative because of the expense, difficulty of





14       operation and low water levels during our maximum daily





15       demand. As a result of these factors this Horseshoe Pond





16       aguifer is of critical importance to the town of Merrimack





17       and the Merrimack Village District.





18            As a result of these concerns we reguest that the EPA





19       provide us with the following information: a written





20       description of how the modeling of the groundwater cleanup





21       alternative was conducted and a discussion of why more





22       realistic cleanup alternatives were not evaluated or





23       presented. Please also tell us how the model's assumptions





24       could be modified to show a more realistic situation or





   LEGAL DEPOSITION SERVICE
-------
EPA PUBLIC HEARING IN MERRIMACK,  N.H.  - January 28,  1998    Page 13





 1       alternatively discuss why other alternatives were not





 2       presented or their benefits not estimated if the





 3       hydrogeologic situation is too complex to model. Please





 4       describe how EPA' s proposed cleanup will effect Merrimack





 5       Village District's future use of the Horseshoe Pond area





 6       for  a production well.  We are most concerned about how we





 7       would be able to obtain new source approval for a well in





 8       the Horseshoe Pond area if the site has not been cleaned up





 9       adeguately.





10                  Based on the current proposal and our concerns as





11       described above we do not support the cleanup as proposed.





12       Should you have any guestions there's phone numbers of





13       where we can be reached and it's signed by Eilene





14       Pannetier, Wellhead Chairman.





15                  MR. BOYNTON:  Thank you Mr. Wilson.





16       Does anyone else wish to make a comment at this time?





17  (No response from the audience)





18                  MR. BOYNTON:  If there are no further





19       comments for the record I am going to close the hearing and





20       then we can take general guestions after that. So with





21       that, I thank you all for coming and I want to thank you





22       for your comments. This hearing is closed.





23  OFF THE RECORD (7:35 p.m.)





24





  LEGAL DEPOSITION SERVICE
-------
EPA PUBLIC HEARING IN MERRIMACK, N.H. - January 28, 1998

       STATE OF NEW HAMPSHIRE

       MERRIMACK, SS.

         I, Cori Crumb, a Notary Public in the State of New Hampshire, do hereby certify
    that I transcribed from a tape recording the foregoing thirteen  (13) pages and that the same
    is a true, full and correct transcript of all of the testimony, to the best of my knowledge
    and belief.

         I further certify that I am neither attorney nor counsel for, nor related to, or
    employed by any of the parties to this action, and further that I am not a relative or
    employee of any attorney or counsel employed in this case, nor am I financially interested
    in this action.

    IN WITNESS WHEREOF, I hereunto set my hand this 5th day of February 1998.



-------
                                 ATTACHMENT C

      COMPIiETE TEXT OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD



Mr. Jim DiLorenzo
Remedial Project Manager
USEPA(HBO)
JFK Federal Building
Boston, MA 02203

Dear Mr. DiLorenzo:

A study performed by the Merrimack Village District's hydrogeologists in 1994-1995 showed that the
Horseshoe Pond area near New Hampshire Plating may be one of the only significant aguifers remaining in
Merrimack.

We have recently added a well online in the adjacent town of Hollis and we have an additional tap site,
also in Hollis. These are small yield wells and we will need more wells in the future. After expected
restoration of a well in South Merrimack that had been contaminated by Merrimack Industrial Metals and
the added Hollis well, by the year 2004 we will be facing a critical need for other sources.

Your proposal to clean up the New Hampshire Plating site is of vital interest to us as we plan for the
future. Your groundwater clean up alternatives found listed on page 9 of your plan we received this date
caused us to focus on "Alternative 3" - Treat Contaminants on Site. We feel that this procedure would
enable the Horseshoe Pond aguifer to be retained in our planning for use by the year 2008 and that the
high value that this aguifer represents would be retained.

We need to take what steps possible to avoid having Horseshoe Pond abandoned as a potential source of
water. If we can be of further assistance, please do not hesitate to call.




-------


January 28, 1998

Mr. Jim DiLorenzo
Remedial Project Manager
US EPA
JFK Federal Building
Boston, MA 02203

    Dear Mr. DiLorenzo:

The Merrimack Village District Wellhead Protection Committee has reviewed the proposed plan for the New
Hampshire Plating Superfund site. While we agree with the soil clean up portion of the plan, we are
extremely concerned about the groundwater clean up proposal. We understand that this portion of the
project consists of Alternative 2: limited action. The limited action would indeed be limited: providing
only "natural attenuation" of groundwater pollution. This is virtually the same as "no action"
alternative, with the minor exception that a groundwater management zone would be established, and there
would be long- term monitoring of the groundwater.

We are also concerned with the evaluation that was done for the project. Your Table 4 of the proposed
plan dated January 19, 1998 shows Alternative 2 with a shorter clean up time for groundwater than
Alternative 3: an active clean up. We suspect that the modeling that this is based on is not
representative of real conditions, since it suggests that your pump and treat system be less effective
than no system at all. What are the assumptions used in the model? We do not believe that the model, or
the evaluation, represents what would really happen if a competent groundwater clean up scenario were
used. We do not agree that the only groundwater clean up option available would make the situation worse
instead of better. Perhaps the model's assumption should be reexamined, or the clean up scenario should
be modified so that it represents a more realistic situation.

The Town of Merrimack's water situation is such that we cannot afford to "write-off" major sources of
water. The Horseshoe Pond aguifer is such a source. We have not tested the area because of the presence
of this Superfund site, however, our hydrogeologic evaluation of the town identified it as one of the
highest, if not the highest producing area in Merrimack.
    Field office Tel.  (603) 424-7171 • Business Office Tel.  (603) 424-9241 • Fax (603) 424-0563
-------


Mr. Jim DiLorenzo

The same hydrogeologic study also revealed to us that there are no other sites left in Merrimack. Our two
most recent well sites are located just over the town line in Hollis, because of the fact that there are
no other sites left in Merrimack. The town is also working with DES to get the Merrimack Industrial
Metals site cleaned up as soon as, possible, so that we may restore well 6 to good production capability.
Once well 6 has been restored, our next most cost-effective alternative is to purchase water from one of
our neighbors. Somewhat less cost-effective is an intake and treatment plant on the Merrimack River,
currently not a very practical alternative because of the expense, difficulty of operation, and low water
levels during our maximum day demand. As a result of these factors, this Horseshoe Pond aguifer is of
critical importance to the Town of Merrimack and the Merrimack Village District.

As a result of these concerns, we reguest that EPA provide us with the following information:

1) A written description of how the modeling of groundwater clean up alternatives was conducted and a
   discussion of why more realistic clean up alternatives were not evaluated or presented. Please also
   tell us how the model's assumptions could be modified to show a more realistic situation, or
   alternatively, discuss why other alternatives were not presented or their benefits not estimated if
   the hydrologic situation is just too complex to model.

2) Please describe how EPA's proposed clean up will affect Merrimack Village District's future use of the
   Horseshoe Pond area for a production well. We are most concerned about how we would be able to obtain
   "new source approval" for a well in the Horseshoe Pond area if the site has not been cleaned up
   adeguately.

Based on the current proposal and our concerns described above, we do not support the clean up as
proposed. Should you have guestions regarding this matter, please do not hesitate to contact me at
424-8444 x301 or Brian Wilson, MVD Assistant Superintendent, at 424-7171. Thank you in advance to your
response to these reguests.

Sincerely,

Eileen Pannetier
Chairman
Wellhead Protection Committee
    Field Office Tel.  (603) 424-7171 • Business Office Tel.  (603) 424-9241 • Fax  (603)424-0563
-------


Mr. Jim DiLorenzo
Remedial Project Manager
U.S. Environmental Protection Agency (HBO)
JFK Federal Building
Boston, MA 02203

Re: N.H. Plating Superfund Site - Official Comment

Dear Mr. DiLorenzo:

The Town of Litchfield, situated directly across the Merrimack River from the N.H.  Plating Company
Superfund site has reviewed the proposed plan for cleanup and wishes to make the following comments part
of the official records.

The Town of Litchfield has reviewed the proposed cleanup documents presented at the Public Informational
meetings held on January 15 & 28, 1998. In reviewing these documents and the comments made by EPA
personnel at the meetings, the Town has a concern surrounding the contamination of the groundwater
present at the site in Merrimack and its migration towards the Merrimack River. As stated by EPA,  the
contamination of the groundwater on the Merrimack side currently resides in the upper strata of the water
table and there has been to date no detection of the contamination in the River water, its sediments or
fauna. The Town of Litchfield is concerned that the contamination of the N.H. Plating Company site may
migrate deeper into the water table and potentially move under and across the Merrimack River thus
presenting a hazard to residents of Litchfield.

The Town of Litchfield bordering the Merrimack is composed mostly of agricultural and residential
property. Residents of the Town currently utilized the water from our aguifer for both drinking as well
as agricultural purposes. The utilization of water contaminated by heavy metals and organic compounds as
described in Table 2 (Groundwater Standards and Average Concentrations Detected in your informational
bulletin presented at the Public Meetings we believe to be inappropriate and warrants monitoring by EPA
and the Town of Litchfield.

The Town of Litchfield is reguesting that as part of the cleanup of the N.H. Plating Company Superfund
Site that monitoring wells sampled at an appropriate freguency be established on the Litchfield side of
the Merrimack River. The purpose of the monitoring wells would be to detect as early as possible any
migration of groundwater contaminants and thus provided some assurance of protection to Litchfield
residents. Furthermore, the Town of Litchfield reguests that any results of groundwater monitoring
performed on either the Merrimack or Litchfield side of the river be provided to the Litchfield Board of
Selectmen and the Litchfield Conservation Commission. The Town of Litchfield also reguests that the EPA
conduct a Public hearing on this matter for the information and education of the town residents. It is
anticipated that the establishment, monitoring and reporting of results for the monitoring wells would be
performed at the expense of the EPA Superfund Program. We have enclosed in this letter a photocopy of the
Town's tax maps with the names and addresses of property owners.

Should you have any guestions on this matter, please do not hesitate to contact the Board of Selectmen or
Conservation Commission.

                                                                        Respectfully submitted,

    
-------


February 13, 1998

Jim DiLorenzo
Environmental Protection Agency
HAND DELIVERED

Dear Mr. DiLorenzo:

The Merrimack Village District Wellhead Protection Committee supports the mitigation procedures set forth
by the Merrimack Conservation Committee. This 50.337 acre plot (29.6 acres we believe to be wetlands)
marked by Town of Merrimack tax maps as lot 3-B-260 has numerous benefits to the town. It is an
environmentally sound decision, by the Conservation Committee, to protect this area from future
development for several socio-economic reasons. This area is an excellent recharge source for an
underlying aquifer system. Your cooperation in supporting the efforts of our Conservation Committee is
appreciated.


    Field Office Tel. (603) 424-7171 • Business Office Tel. (603)  424-9241 • Fax(603)424-0563
-------
                                                Town of Merrimack, New Hampshire 03054

                                                                      603/424-3531
Community Development Department. P.O. Box 940                        603/424-3931
Town Hall, West Wing, 8 Baboosic Lake Road                        Fax 603/424-1408
Divisions: Code Enforcement & Building - Conservation - Health - Planning & Zoning

February 13, 1998

Mr. James M. DiLorenzo, Environmental Eng.
U.S. Environmental Protection Agency
Office of Site Remediation and Restoration
JFK Federal Building (HBO)
Boston, MA 02203-2211
                                   RE: New Hampshire Plating
                                       Wetland Mitigation Sites
Dear Mr. DiLorenzo:

    This  letter  is  submitted by  the Merrimack  Conservation Commission  to urge the U.S. Environmental
Protection Agency  (EPA) to select a parcel of land within the Town of Merrimack to be used as a
mitigation site for the wetlands which will be destroyed as a result of site redemption activities at the
New Hampshire Plating Site on Wright Avenue in Merrimack, NH.

    At  the Conservation Commission's  January 27,  1998 meeting which was attended by you and Mr. Tal
Hubbard of the NHDES, three potential sites were suggested for mitigation: l)the Skylar Property,  Tax Map
3D-1/3, 2) an area in the White Pine Swamp area, Tax Map 3B/260, and 3)  an area owned by the Manchester
YMCA located adjacent to Horseshoe Pond, Tax Map 4D-4/43. On January 9,  1998 site inspections were made
of the Skylar and White Pine Swamp properties. At our January 10,  1998 Conservation Commission meeting it
was reported to us that of these two properties the White Pine Swamp lot looked more favorable. However,
it was also reported that EPA may consider selecting properties outside of the Town of Merrimack as a
mitigation site.

    The Conservation  Commission  wishes  to  go on  record  as opposing EPA' s selection of mitigation sites
outside of the Town of Merrimack. We believe that it is inappropriate to spend Federal monies  (tax payers
dollars) on land acguisition outside of Merrimack when the loss of valuable wetland areas has occurred
within the Town. Merrimack, as you may well know, relies on groundwater for nearly 100 percent of its
potable drinking water supply. It is imperative that the Town protect its groundwater supply by
practicing wise land management and controlling those activities in the vicinity of our water supply
wells and wellhead protection areas.  One method of control is for the Town to acguire lands within and
adjacent to wellhead protection areas. Accordingly, it would be very appropriate for the Town to acguire
the 55 + acre parcel of land in the White Pine Swamp area.  As was pointed out in the Commission's January
27, 1998 meeting, this land is within the wellhead protection area of Merrimack Village District Wells
No. 1,  No. 2 and No.  3. Acguisition of the White Pine Swamp property provides the following benefits for
the Town:

    •  Property is located in the headwaters of a stream which runs into Greenspond which is adjacent to
      MVD Well #3;
    •  The property itself is a source of recharge within the recharge area for MVD Well #3;
    •  It is a nursery and brooding area for waterfowl;
    •  It is a suitable habitat for mink, otters and beavers;
    •  It serves as a nesting area for songbirds and marsh dwellers;
    •  It is located in the same watershed as the NH Plating Site wetlands;
    •  Ensures protection of a large upland area around the wetlands by removing development options which
      are currently being considered; and finally
    •  Is within the Town where the remediation site is located.

    The Merrimack Conservation Commission  urges  you and your  staff to  select the White Pine Swamp property
(or other appropriate area within the Town) as the mitigation area for the wetlands which will be
destroyed during the site remediation activities at the NH Plating remediation site.  If you have any
guestions regarding this matter, please do not hesitate to call me at (603)595-4504.

           

           CC:  Dean Shankle,  Town Manager
           Merrimack Board of Selectmen
           Jay Minkarah, Community Development Director
           Brian Wilson, Asst. Superintendent, MVD
-------
                                                APPENDIX C
                                        Administrative Record Index

                                       New Hampshire Plating Company
                                  NPL Site Remedial Administrative Record

                                                   Index

                                         Compiled:  January 9,  1998

                                               Prepared for

                                                 Region I
                                         Waste Management Division
                                   U.S. Environmental Protection Agency

                                           With Assistance from

                                               TECHLAW,  INC.
                  160 North Washington Street, Suite 400, Boston, MA 02114  (617)720-0320


                                               INTRODUCTION

This document is the Index to the Administrative Record File compiled for the New Hampshire Plating
Superfund Site. The index cites site-specific documents. Site-specific documents in the Administrative
Record File are in order by the Document No. included at the end of each citation.

The Administrative Record File is available for public review, by appointment, at the EPA Region I OSRR
Records Center, 90 Canal Street, Boston, MA,  (617-573-5729)  and at the Merrimack Public Library, 470
Daniel Webster Highway, Merrimack, New Hampshire 03054.

Questions concerning this Administrative Record File should be addressed to the EPA Region I site
manager.

An Administrative Record is reguired by the Comprehensive Environmental Response, Compensation, and
Liability Act  (CERCLA) , as amended by the Superfund Amendments and Reauthorization Act  (SARA).

    Table  of Contents

    Volume I

         Documents 000001 - 000029

    Volume II

         Documents 000030 - 000040

    Volume III

         Documents 000041

    Volume IV

         Documents 000042 - 000043

    Volume V

         Documents 000044 - 000046

    Volume VI

         Documents 000047 - 000062
-------
    Administrative Record Index
    Alphabetical List of Compendium Documents
SF Document Indexing System
NEW HAMPSHIRE PLATING COMPANY Quik-List Report
All Documents
Ordered by: JBERGGRE.IDX

Jberggre.idx    Title
                                         Author
                                                                06/10/98 REP_QUIK
                                                                      Page     1
                                                             Date
                                  Doc #
000001


000002

000003

000004



000005



000006



000007



000008


000009


000010
000011
000012
Trip Report For The Initial Waste
Management Division Visit to New
Hampshire Plating Site.
Transmittal of Initial Release Public
Health Assessment.
Transmittal of Site Photo Frame No.
7920 and Reguest for Additional Copies.
Letter from Richard Goehlert, U.S.
EPA RI, to C. Porfert, U.S. EPA RI.
Review of Removal data to focus the
Remedial Investigation.
Letter from Pheobe Call, Badger
Engineers, to Richard Goehlert, U.S.
EPA RI. Summary of July 22, 1992,
Kickoff Meeting.
Letter from Pheobe Call, Badger
Engineers, to Richard Goehlert, U.S.
EPA RI. Addendum to July 22, 1992,
Kickoff Meeting.
Transmittal of Draft Work Plan and
Draft Detailed Cost Estimate, New
Hampshire Plating, Technical
Assistance.
Letter Reguesting Technical
Assistance in Characterizing
Contaminated Solid Wastes.
Transmittal of Community Relations
Material, Technical Assistance, New
Hampshire Plating Superfund Site.
Transmittal of Draft Work Plan and
Draft Detailed Cost Estimate,
Remedial Investigation/Focus
Feasibility Study, New Hampshire
Plating Company Site.
Transmittal of Site Base Maps
Pertaining to the Remedial
Investigation.
Transmittal of Draft Health and
Safety Plan, New Hampshire Plating
Company Site.
RICHARD WILLEY


LOUISE HOUSE

RUTH LEABMAN

RICHARD GOEHLERT



PHEOBE CALL



PHEOBE CALL



GEORGE GARDNER



RICHARD WILLEY


ROBERT PALERMO


GEORGE GARDNER
                                                         RICHARD GOEHLERT
                                                         ROBERT PALERMO.
1992- 2-25    000001


1992- 5-27    000002

1992- 5-29    000003

1992- 6- 2    000004



1992- 7-31    000005
1992- 8- 6
1992- 8-14
1992- 8-26
1992- 9-17
                                                                             1992-10-20
              000006
              000007
              000008
              000009
                                                                                           000010
                                                                             1992-11- 9    000011
                                                                             1992-11-16    000012
-------
SF Document Indexing System
NEW HAMPSHIRE PLATING COMPANY Quik-List Report
All Documents
Jberggre.idx    Title
000013



000014


000015



000016

000017

000018



000019


000020



000021

000022



000023


000024

000025


000026
Letter from Lucy Guzman, Halliburton
NUS, to Richard Goehlert, U.S. EPA
RI.  Changes needed in NHDES Data
Format to Facilitate CLP Comparisons.
Transmittal Letter for Groundwater
Level Measurements and Groundwater
Sampling Information.
Transmittal of Draft Location and
Elevation Survey Services
Specifications, RI/FS, New Hampshire
Plating Company Site.
Letter Concerning Sampling Locations
and Water Level Evaluations.
Letter Concerning Remedial
Investigation, Activities List.
Transmittal of the Agency For Toxic
Substances and Disease Registry
(ASTDR) Public Health Assessment -
Public Comment Release.
Letter Concerning the Use of
Merrimack's Wastewater Treatment
Facility.
Transmittal of Wastewater Quality
Regulations, Ground Water Protection
Rules, Hazardous Waste Rules and
Solid Waste Rules.
Letter Concerning Soil Testing and
Remedy Alternatives.
Transmittal of Quality
Assurance/Quality Control
Documentation for VOC Samples
Analyzed by NHDES.
Transmittal of One Diskette
Containing Water Quality Analysis
Conducted by NHDES.
Letter Concerning the Location of
Monitoring Wells on YMCA Property.
Transmittal of Reguested Information,
RI Field Program, New Hampshire
Plating Company Site.
Sampling and Analysis Data:
Available for review at EPA Records
Center.
Author

LUCY GUZMAN



ROBERT PALERMO


GEORGE GARDNER
            06/10/98
             Page  2

Date          Doc

1992-12-15    000013



1993- 2- 4    000014


1993- 3- 1    000015
RICHARD GOEHLERT    1993- 3- 5    000016

JIM DI LORENZO      1993- 3-11    000017

MAX HOWIE           1993- 3-15    000018



RICHARD GOEHLERT    1993- 3-24    000019


MICHAEL ROBINETTE   1993- 4- 9    000020



RICHARD GOEHLERT    1993- 8-11    000021

MICHAEL ROBINETTE   1993-10-15    000022
C. WAYNE IVES
                    1993-10-29    000023
JIM DI LORENZO      1994- 9- 1    000024

ROBERT PALERMO      1994- 3-22    000025


                                  000026
-------
SF Document Indexing System
NEW HAMPSHIRE PLATING COMPANY Quik-List Report
All Documents
Jberggre.idx    Title
                                         Author
000027


000028


000029


000030

000031



000032

000033


000034

000035



000036


000037

000038

000039


000040

000041


000042
Sampling and Analysis Plan, Technical
Assistance with Transmittal Letter
(Draft).
Sampling and Analysis Plan, Phase I
Lagoon and Surficial Soil Sampling,
RI/FS  (Draft Final).
Final Phase II Sampling and Analysis
Plan, RI/FS, New Hampshire Plating
Superfund site.
Letter Concerning Soil Screening
Treatability Results.
Letter from Steven Safferman, U.S.
EPA, to Richard Goehlert, U.S. EPA
RI.  Revised Memo - Soil Screening
Treatability Results.
Letter Concerning Groundwater
Sampling Results.
Transmittal of Horseshoe Pond
Inorganic Data Validation Packages
for Surface Water and Sediments.
Conceptual Wetland Mitigation Plan,
RI/FS.
Geophysical Investigations in the
Vicinity of a Former Electroplating
Facility in Merrimack, New Hampshire
with Transmittal Letter.
Ecological Characterization for New
Hampshire Plating Site with
Transmittal Letter.
Sampling and Analysis Plan for Soil
Characterization, RI/FS, (Draft).
Summary of Phase I and Surficial Soil
Sampling XRF Metals And CLP Cyanides Map.
Health and Safety Plan, Phase I
Lagoon and Surficial Soil Sampling,
RI/FS, (Draft).
Phase II Lagoon Sampling Remedial
Investigation Report Map.
Remedial Investigation Report, Volume
1 - Text, RI/FS, with Transmittal
Letter (Draft Final).
Remedial Investigation Report, Volume
2 - Tables, RI/FS,  (Draft Final).
STEVEN SAFFERMAN
STEVEN SAFFERMAN
RICHARD GOEHLERT
ROBERT PALERMO
THOMAS MACK
GORDON BECKETT
                    Date

                    1992- 8-


                    1993- 4-


                    1993-11-
            06/10/98
              Page 3

              Doc #

              000027


              000028


              000029
1993-11-23    000030

1993-12-13    000031



1994- 2- 3    000032

1994- 5-13    000033


1994- 8-      000034

1994- 9-27    000035



1994- 9-29    000036


1994-12-      000037

1994-12-      000038

1992-11-      000039


1996- 2-13    000040

1996- 5-      000041
                                                                             1996- 5-
                                                                                           000042
-------
SF Document Indexing System
NEW HAMPSHIRE PLATING COMPANY Quik-List Report
All Documents
Jberggre.idx    Title
000043

000044

000046



000047


000048

000049



000050

000051

000052

000053

000054

000055

000056

000057

000058


000059
000060
000061
000062
Remedial Investigation Report, Volume
3 - Figures, RI/FS,  (Draft Final).
Remedial Investigation Report, Volume
4 - Appendices, RI/FS, (Draft Final).
Work Plan, Remedial
Investigation/Focus Feasibility
Study, with Transmittal Letter  (Draft
Final).
Baseline Human Health Risk
Assessment, Appendix E, RI/FS,  (Draft
Final).
Final Feasibility Study,  New
Hampshire Plating Company Site.
Letter from Michael Robinette, NHDES,
to Charles Watson, Town of Merrimack.
Questions regarding the remediation
process.
Community Relations Plan, RI/FS, with
Transmittal letter.
"EPA to Resume Cleanup at Waste Site
in Merrimack."
"EPA Proposes 22 Site to Superfund
List, Two in New England."
"Health Report Expected on New
Hampshire Metals Site."
"Public Comment Sought on Merrimack
Site."
"EPA Studying Merrimack Waste Site
Contamination."
"Merrimack Residents Told Site is not
a Health Threat."
"EPA to Monitor Merrimack Pollution
Site."
Letter Containing a Summary of Issues
Raised at June 13, 1990,  Public
Meeting.
New Hampshire Plating Superfund Site,
Wednesday June 9, 1993, Meeting
Agenda with Transmittal Letter.
"Remedial Activities Underway."
Letter from Merrill Hohman, U.S. EPA
Region I to Ken Finkelstein, National
Oceanic and Atmospheric
Administration with attached Trustee
Notification
Proposed Plan, New Hampshire Plating
Company Superfund Site.

Author Date
1996- 5-
1996- 4-
1993- 1-
1995-10-
1997-12-
MICHAEL ROBINETTE 1992- 7-22
1993- 7-
1990- 5-15
1991- 7-25
1993- 3-16
1993- 3-31
1993- 5-28
1993- 6-10
1993-10-23
EBER CURRIER 1990- 6-27
06/10/98
Page 4
Doc #
000043
000044
000046
000047
000048
000049
000050
000051
000052
000053
000054
000055
000056
000057
000056
                                                         ROBERT PALERMO
                                                         MERRILL HOHMAN
                                                                             1993- 6- 9
                                                                                           000059
1993- 5-      000060
1993- 2-25    000061
                                                                             1998- 1-
                                                                                           000062
-------
03.01
                       ADMINISTRATIVE RECORD INDEX
                      NEW HAMPSHIRE PLATING COMPANY
                            All Operable Units

        REMEDIAL INVESTIGATION - CORRESPONDENCE
                                             01/12/98
                                          Page      1
        Title:       Trip Report For The Initial Waste Management Division Visit to New Hampshire Plating
                    Site.
        Addressee:  U.S. EPA REGION 1
        Authors:    RICHARD WILLEY - HYDROLOGIST
        Date:       February 25, 1992
        Format:      CORRESPONDENCE               No. Pgs:   5
        AR No.       03.01.1                      Document No.  000001

        Title:       Transmittal of Initial Release Public Health Assessment.
        Addressee:  FRANK CIAVATTIERI - U.S. EPA REGION 1
        Authors:    LOUISE HOUSE - DEPT.  OF HEALTH AND HUMAN SERVICES
        Date:       May 27, 1992
        Format:      CORRESPONDENCE               No. Pgs:   1
        AR No.       03.01.2                      Document No.  000002
        Title:       Transmittal of Site Photo Frame No. 7920 and Reguest for Additional Copies.
        Addressee:  DENNIS MORGAN - U.S.  EPA REGION 1
        Authors:    RUTH LEABMAN - U.S. EPA REGION 1
        Date:       May 29, 1992
        Format:      CORRESPONDENCE               No. Pgs:   1
        AR No.       03.01.3                      Document No.  000003

        Title:       Letter from Richard Goehlert, U.S. EPA RI, to C. Porfert, U.S. EPA RI. Review of
                    Removal data to focus the Remedial Investigation.
        Addressee:  C PORFERT - U.S. EPA REGION 1
        Authors:    RICHARD GOEHLERT - U.S. EPA REGION 1
        Date:       June 2, 1992
        Format:      CORRESPONDENCE               No. Pgs:   2
        AR No.       03.01.4                      Document No.  000004
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Letter from Pheobe Call, Badger Engineers, to Richard Goehlert, U.S. EPA RI. Summary
of July 22, 1992, Kickoff Meeting.
RICHARD GOEHLERT - U.S. EPA REGION 1
PHEOBE CALL - BADGER ENGINEERS
July 31, 1992
CORRESPONDENCE
                    03.01.5
                              No. Pgs:  3
                              Document No.  000005
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Letter from Pheobe Call, Badger Engineers, to Richard Goehlert, U.S. EPA RI. Addendum
to July 22, 1992, Kickoff Meeting.
RICHARD GOEHLERT - U.S. EPA REGION 1
PHEOBE CALL - BADGER ENGINEERS
August 6, 1992
                                       2
CORRESPONDENCE
03.01.6
No. Pgs:
Document No.  000006
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Transmittal of Draft Work Plan and Draft Detailed Cost Estimate, New Hampshire
Plating, Technical Assistance.
DIANE KELLEY - U.S. EPA REGION 1
GEORGE GARDNER - HALLIBURTON NUS
August 14, 1992
CORRESPONDENCE               No. Pgs:  1
                    03.01.7
                                                 Document No.  000007
        Title:       Letter Reguesting Technical Assistance in Characterizing Contaminated Solid Wastes.
        Addressee:  JOAN COLSON - U.S. EPA OFFICE OF RESEARCH & DEVELOP.
        Authors:    RICHARD WILLEY - HYDROLOGIST
        Date:       August 26, 1992
        Format:      CORRESPONDENCE                No. Pgs:  2
        AR No.       03.01.8                       Document No.  000008
-------
 Title:      Transmittal of Community Relations Material, Technical Assistance, New Hampshire
             Plating Superfund Site.
 Addressee:  RICHARD GOEHLERT - U.S. EPA REGION 1
 Authors:    ROBERT PALERMO - BADGER ENGINEERS
 Date:       September 17, 1992
 Format:     CORRESPONDENCE                No. Pgs:  1
 AR No.      03.01.9                       Document No.000009
 Title:
 Addressee:
 Authors:
 Date:
 Format:
 AR No.
Transmittal of Draft Work Plan and Draft Detailed Cost Estimate, Remedial
Investigation/Focus Feasibility Study, New Hampshire Plating Company
Site.
DIANE KELLEY - U.S. EPA REGION 1
GEORGE GARDNER - HALLIBURTON NUS
October 20, 1992
CORRESPONDENCE
             03.01.10
                            No. Pgs:  1
                            Document No.
                                                       000010
 Title:      Transmittal of Site Base Maps Pertaining to the Remedial Investigation.
 Addressee:  ROBERT PALERMO - BADGER ENGINEERS
 Authors:    RICHARD GOEHLERT - U.S. EPA REGION 1
 Date:       November 9, 1992
 Format:     CORRESPONDENCE               No. Pgs:  1
 AR No.      03.01.11                     Document No.  000011

 Title:      Transmittal of Draft Health and Safety Plan, New Hampshire Plating Company Site.
 Addressee:  RICHARD GOEHLERT - U.S. EPA REGION 1
 Authors:    ROBERT PALERMO - BADGER ENGINEERS
 Date:       November 16, 1992
 Format:     CORRESPONDENCE               No. Pgs:  1
 AR No.      03.01.12                     Document No.  000012

 Title:      Letter from Lucy Guzman, Halliburton NUS, to Richard Goehlert, U.S. EPA RI. Changes
             needed in NHDES Data Format to Facilitate CLP Comparisons.
 Addressee:  RICHARD GOEHLERT - U.S. EPA REGION 1
 Authors:    LUCY GUZMAN - HALLIBURTON NUS
 Date:       December 15, 1992
 Format:     CORRESPONDENCE               No. Pgs:  2
 AR No.      03.01.13                     Document No.  000013
 Title:      Transmittal Letter for Groundwater Level Measurements and Groundwater Sampling
             Information.
 Addressee:  RICHARD WILLEY - U.S. EPA REGION 1
 Authors:    ROBERT PALERMO - BADGER ENGINEERS
 Date:       February 4, 1993
 Format:     CORRESPONDENCE               No. Pgs:  2
 AR No.
             03.01.14
                                          Document No.  000014
 Title:      Transmittal of Draft Location and Elevation Survey Services Specifications, RI/FS,
             New Hampshire Plating Company Site.
 Addressee:  DIANE KELLEY - U.S. EPA REGION 1
 Authors:    GEORGE GARDNER - HALLIBURTON NUS
 Date:       March 1, 1993
 Format:     CORRESPONDENCE               No. Pgs:  1
 AR No.
             03.01.15
                                          Document No.  000015
Title:      Letter Concerning Sampling Locations and Water Level Evaluations.
Addressee:  ROBERT PALERMO - BADGER ENGINEERS
Authors:    RICHARD GOEHLERT - U.S. EPA REGION 1
Date:       March 5, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.16                     Document No.  000016
-------
Title:      Letter Concerning Remedial Investigation Activities List.
Addressee:  KATHY DONOVAN - BADGER ENGINEERS
Authors:    JIM DI LORENZO - U.S. EPA REGION 1
Date:       March 11, 1993
Format:     CORRESPONDENCE               No. Pgs:  2
AR No.      03.01.17                     Document No.  000017

Title:      Transmittal of the Agency For Toxic Substances and Disease Registry  (ASTDR) Public
            Health Assessment - Public Comment Release.
Addressee:  FRANK CIAVATTIERI - U.S. EPA REGION 1
Authors:    MAX HOWIE - DEPT. OF HEALTH AND HUMAN SERVICES
Date:       March 15, 1993
Format:     CORRESPONDENCE               No. Pgs:  2
AR No.      03.01.18                     Document No.  000018

Title:      Letter Concerning the Use of Merrimack's Wastewater Treatment Facility.
Addressee:  ROBERT PALERMO - BADGER ENGINEERS
Authors:    RICHARD GOEHLERT - U.S. EPA REGION 1
Date:       March 24, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.19                     Document No.  000019

Title:      Transmittal of Wastewater Quality Regulations, Ground Water Protection Rules,
            Hazardous Waste Rules and Solid Waste Rules.
Addressee:  KATHY DONOVAN - BADGER ENGINEERS
Authors:    MICHAEL ROBINETTE - N.H. DEPT. OF ENVIRONMENTAL
            SERVICES
Date:       April 9, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.20                     Document No.  000020

Title:      Letter Concerning Soil Testing and Remedy Alternatives.
Addressee:  WILLIAM SLACK - UNIVERSITY OF CINCINNATI
Authors:    RICHARD GOEHLERT - U.S. EPA REGION 1
Date:       August 11, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.21                     Document No.  000021

Title:      Transmittal of Quality Assurance/Quality Control Documentation for VOC Samples
            Analyzed by NHDES.
Addressee:  LUCY GUZMAN - HALLIBURTON NUS
Authors:    MICHAEL ROBINETTE - N.H. DEPT. OF ENVIRONMENTAL
            SERVICES
Date:       October 15, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.22                     Document No.  000022

Title:      Transmittal of one Diskette Containing Water Quality Analysis Conducted by NHDES.
Addressee:  AMY HOYT - U.S. EPA REGION 1
Authors:    C. WAYNE IVES - N.H. DEPT. OF ENVIRONMENTAL SERVICES
Date:       October 29, 1993
Format:     CORRESPONDENCE               No. Pgs:  1
AR No.      03.01.23                     Document No.  000023
Title:      Transmittal of Requested Information, RI Field Program, New Hampshire Plating Company
            Site.
Addressee:  RICHARD GOEHLERT - U.S. EPA REGION 1
Authors:    ROBERT PALERMO - BADGER ENGINEERS
Date:       March 22, 1994
Format:     CORRESPONDENCE               No. Pgs:  2
AR No.      03.01.24                     Document No.  000025
-------
       Title:       Letter Concerning the Location of Monitoring Wells on YMCA Property.
       Addressee:   TERRY BENHARDT - MERRIMACK YOUTH ASSOCIATION
       Authors:     JIM DI LORENZO - U.S. EPA REGION 1
       Date:        September 1,  1994
       Format:      CORRESPONDENCE               No. Pgs:   1
       AR No.       03.01.25                     Document No.  000024

03.02  REMEDIAL INVESTIGATION - SAMPLING & ANALYSIS DATA

       Title:       Sampling and Analysis Data:  Available for review at EPA Records Center.
       Format:                                   No. Pgs:   1
       AR No.       03.02.1                      Document No.  000026

       Title:       Sampling and Analysis Plan, Technical Assistance with Transmittal Letter  (Draft).
       Authors:     HALLIBURTON NUS
       Date:        August 1992
       Format:      REPORT, STUDY                 No. Pgs:  109
       AR No.       03.02.2                       Document No.  000027

       Title:       Sampling and Analysis Plan, Phase I Lagoon and Surficial Soil Sampling, RI/FS  (Draft
                   Final).
       Authors:     HALLIBURTON NUS
       Date:        April 1993
       Format:                                    No. Pgs:  80
       AR No.       03.02.3                       Document No.  000028

       Title:       Final Phase II Sampling and Analysis Plan, RI/FS, New Hampshire Plating Superfund
                   Site.
       Addressee:   U.S. EPA
       Authors:     HALLIBURTON NUS
       Date:        November 1993
       Format:      REPORT, STUDY                 No. Pgs:  145
       AR No.       03.02.4                       Document No.  000029
       Title:
       Addressee:
       Authors:

       Date:
       Format:
       AR No.
Letter Concerning Soil Screening Treatability Results.
RICHARD GOEHLERT - U.S.
STEVEN SAFFERMAN - U.S.
DEVELOP.
November 23, 1993
CORRESPONDENCE
03.02.5
EPA REGION 1
EPA OFFICE OF RESEARCH &
      No. Pgs:  2
      Document No.  000030
       Title:       Letter from Steven Safferman, U.S. EPA, to Richard Goehlert, U.S. EPA RI.  Revised Memo
                   - Soil Screening Treatability Results.
       Addressee:   RICHARD GOEHLERT - U.S. EPA REGION 1
       Authors:     STEVEN SAFFERMAN - U.S. EPA OFFICE OF RESEARCH & DEVELOP.
       Date:        December 13,  1993
       Format:      CORRESPONDENCE                No. Pgs:  10
       AR No.       03.02.6                       Document No.  000031

       Title:       Letter Concerning Groundwater Sampling Results.
       Addressee:   ROBERT PALERMO - BADGER ENGINEERS
       Authors:     RICHARD GOEHLERT - U.S. EPA REGION 1
       Date:        February 3,  1994
       Format:      CORRESPONDENCE                No. Pgs:  1
       AR No.       03.02.7                       Document No.  000032
       Title:       Transmittal of Horseshoe Pond Inorganic Data Validation Packages for Surface Water and
                   Sediments.
       Addressee:   RICHARD GOEHLERT - U.S. EPA REGION 1
       Authors:     ROBERT PALERMO - BADGER ENGINEERS
       Date:        May 13, 1994
       Format:      CORRESPONDENCE                No. Pgs:  2
       AR No.       03.02.8                       Document No.  000033
-------
       Title:       Conceptual Wetland Mitigation Plan, RI/FS.
       Addressee:   U.S.  EPA
       Authors:     HALLIBURTON NUS
       Date:        August 1994
       Format:      REPORT,  STUDY                 No. Pgs:   44
       AR No.       03.02.9                       Document No.  000034

       Title:       Geophysical Investigations in the Vicinity of a Former Electroplating Facility in
                   Merrimack, New Hampshire with Transmittal Letter.
       Addressee:   RICHARD WILLEY - U.S. EPA REGION 1
       Authors:     THOMAS MACK - UNIVERSITY OF CINCINNATI
       Date:        September 27, 1994
       Format:      REPORT,  STUDY                 No. Pgs:   47
       AR No.       03.02.10                      Document No.  000035
       Title:       Sampling and Analysis Plan for Soil Characterization, RI/FS,
       Addressee:   U.S.  EPA
       Authors:     HALLIBURTON NUS
       Date:        December 1994
       Format:      REPORT,  STUDY                 No. Pgs:  75
       AR No.       03.02.11                      Document No.  000037
                                                              (Draft).
       Title:
       Addressee:
       Authors:
       Date:
       Format:
       AR No.
Summary of Phase I and Surficial Soil Sampling XRF Metals and CLP Cyanides Map.
U.S. EPA
HALLIBURTON NUS
December 1994
MAP
03.02.12
No. Pgs:  1
Document No.
                                                               000038
03.04  REMEDIAL INVESTIGATION - INTERIM DELIVERABLES

       Title:       Health and Safety Plan, Phase I Lagoon and Surficial Soil Sampling, RI/FS,  (Draft).
       Addressee:   U.S.  EPA
       Authors:    HALLIBURTON NUS
       Date:        November 1992
       Format:      WORK PLAN                     No. Pgs:  131
       AR No.       03.04.1                       Document No.  000039

       Title:       Ecological Characterization for New Hampshire Plating Site with Transmittal Letter.
       Addressee:   CARL DELOI - U.S. EPA REGION I
       Authors:    GORDON BECKETT - U.S. DEPT. OF INTERIOR
       Date:        September 29, 1994
       Format:      REPORT, STUDY                 No. Pgs:  36
       AR No.       03.04.2                       Document No.  000036

03.06  REMEDIAL INVESTIGATION - REMEDIAL INVESTIGATION REPORTS

       Title:       Phase II Lagoon Sampling Remedial Investigation Report Map.
       Authors:    HALLIBURTON NUS
       Date:        February 13, 1996
       Format:      MAP                           No. Pgs:  14
       AR No.       03.06.1                       Document No.  000040

       Title:       Remedial Investigation Report, Volume 4 - Appendices, RI/FS,  (Draft Final).
       Addressee:   U.S.  EPA
       Authors:    HALLIBURTON NUS
       Date:        April 1996
       Format:      REPORT, STUDY                 No. Pgs:  488
       AR No.       03.06.2                       Document No.  000044
       Title:       Remedial Investigation Report, Volume 1 - Text, RI/FS, with Transmittal Letter  (Draft
                   Final).
       Addressee:   U.S.  EPA
       Authors:     HALLIBURTON NUS
       Date:        May 1996
       Format:      REPORT,  STUDY                 No. Pgs:  423
       AR No.       03.06.3                        Document No.  000041
-------
       Title:      Remedial Investigation Report, Volume 2 - Tables, RI/FS,  (Draft Final).
       Addressee:  U.S. EPA
       Authors:     HALLIBURTON NUS
       Date:       May 1996
       Format:      REPORT, STUDY                 No. Pgs:   171
       AR No.      03.06.4                       Document No.  000042

       Title:      Remedial Investigation Report, Volume 3 - Figures, RI/FS,  (Draft Final).
       Addressee:  U.S. EPA
       Authors:     HALLIBURTON NUS
       Date:       May 1996
       Format:      REPORT, STUDY                 No. Pgs:   53
       AR No.      03.06.5                       Document No.  000043

03.07  REMEDIAL INVESTIGATION - WORK PLANS AND PROGRESS REPORTS

       Title:      Work Plan,  Remedial Investigation/Focus Feasibility Study, with Transmittal Letter
                   (Draft Final).
       Addressee:  U.S. EPA
       Authors:     HALLIBURTON NUS
       Date:       January 1993
       Format:      WORK PLAN                     No. Pgs:   144
       AR No.      03.07.1                       Document No.  000046

03.10  REMEDIAL INVESTIGATION - ENDANGERMENT/BASELINE RISK ASSESSMENTS

       Title:      Baseline Human Health Risk Assessment,  Appendix E, RI/FS,  (Draft Final).
       Addressee:  U.S. EPA
       Authors:     HALLIBURTON NUS
       Date:       October 1995
       Format:      REPORT, STUDY                 No. Pgs:   256
       AR No.      03.10.1                       Document No.  000047

04.06  FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS

       Title:      Final Feasibility Study, New Hampshire Plating Company Site.
       Addressee:  U.S. EPA
       Authors:     BROWN & ROOT
       Date:       December 1997
       Format:      REPORT, STUDY                 No. Pgs:   698
       AR No.      04.06.1                       Document No.  000048

04.09  FEASIBILITY STUDY - PROPOSED PLANS FOR SELECTED REMEDIAL ACTION

       Title:      Proposed Plan,  New Hampshire Plating Company Superfund Site.
       Authors:     U.S. EPA
       Date:       January 1998
       Format:      REPORT, STUDY                 No. Pgs:   16
       AR No.      04.09.1                       Document No.  000062

13.01  COMMUNITY RELATIONS - CORRESPONDENCE

       Title:      Letter from Michael Robinette, NHDES, to Charles Watson, Town of Merrimack. Questions
                   regarding the remediation process.
       Addressee:  CHARLES WATSON - TOWN OF MERRIMACK
       Authors:     MICHAEL ROBINETTE - N.H. DEPT. OF ENVIRONMENTAL
                   SERVICES
       Date:       July 22, 1992
       Format:      CORRESPONDENCE                No. Pgs:   2
       AR No.      13.01.1                       Document No.  000049
-------
13.02  COMMUNITY RELATIONS - COMMUNITY RELATIONS PLANS

       Title:       Community Relations Plan,  RI/FS, with Transmittal Letter.
       Addressee:  U.S.  EPA REGION 1
       Authors:     HALLIBURTON NUS
       Date:        July 1993
       Format:      REPORT, STUDY                 No. Pgs:   23
       AR No.       13.02.1                       Document No.  000050

13.03  COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES

       Title:       "EPA to Resume Cleanup at Waste Site in Merrimack."
       Authors:     U.S.  EPA REGION 1
       Date:        May 15, 1990
       Format:      FACT SHEET, PRESS RELEASE     No. Pgs:   2
       AR No.       13.03.1                       Document No.  000051

       Title:       "EPA Proposes 22 Site to Superfund List, Two in New England."
       Authors:     U.S.  EPA REGION 1
       Date:        July 25,  1991
       Format:      FACT SHEET, PRESS RELEASE     No. Pgs:   2
       AR No.       13.03.2                       Document No.  000052

       Title:       "Health Report Expected on New Hampshire Metals Site."
       Authors:     TELEGRAPH NEWS
       Date:        March 16, 1993
       Format:      NEWS CLIPPING                 No. Pgs:   1
       AR No.       13.03.3                       Document No.  000053

       Title:       "Public Comment Sought on Merrimack Site."
       Authors:     ROCKINGHAM COUNTY NEWS
       Date:        March 31, 1993
       Format:      NEWS CLIPPING                 No. Pgs:   1
       AR No.       13.03.4                       Document No.  000054

       Title:       "EPA Studying Merrimack Waste Site Contamination."
       Authors:     UNION LEADER NEWSPAPER
       Date:        May 28, 1993
       Format:      NEWS CLIPPING                 No. Pgs:   1
       AR No.       13.03.5                       Document No.  000055

       Title:       "Merrimack Residents Told Site is not a Health Threat."
       Authors:     UNION LEADER NEWSPAPER
       Date:        June 10,  1993
       Format:      NEWS CLIPPING                 No. Pgs:   1
       AR No.       13.03.6                       Document No.  000056

       Title:       "EPA to Monitor Merrimack Pollution Site."
       Authors:     UNION LEADER NEWSPAPER
       Date:        October 23, 1993
       Format:      NEWS CLIPPING                 No. Pgs:   1
       AR No.       13.03.7                       Document No.  000057

13.04  COMMUNITY RELATIONS - PUBLIC MEETINGS/HEARINGS
       Title:       Letter Containing a Summary of Issues Raised at June 13,
       Addressee:   PAUL GROULX - U.S. EPA REGION 1
       Authors:     EBER CURRIER - TOWN OF MERRIMACK
       Date:        June 27,  1990
       Format:      CORRESPONDENCE                No. Pgs:  1
       AR No.       13.04.1                       Document No.  000058
1990,  Public Meeting.
-------
       Title:      New Hampshire Plating Superfund Site, Wednesday June 9, 1993, Meeting Agenda with
                   Transmittal Letter.
       Addressee:  RICHARD GOEHLERT - U.S. EPA REGION 1
       Authors:     ROBERT PALERMO - BADGER ENGINEERS
       Date:       June 9, 1993
       Format:      PUBLIC MEETING RECORDS        No. Pgs:   4
       AR No.      13.04.2                       Document No.  000059

13.05  COMMUNITY RELATIONS - FACT SHEETS/INFORMATION UPDATES

       Title:      "Remedial Activities Underway."
       Authors:     U.S. EPA REGION 1
       Date:       May 1993
       Format:      FACT SHEET, PRESS RELEASE     No. Pgs:   8
       AR No.      13.05.1                       Document No.  000060

16.04  NATURAL RESOURCE TRUSTEE - TRUSTEE NOTIFICATION FORM AND SELECTION GU
       Title:      Letter from Merrill Hohman, U.S. EPA Region I to Ken Finkelstein, National Oceanic and
                   Atmospheric  Administration with attached Trustee Notification
       Addressee:  KENNETH FINKELSTEIN - NATL. OCEANIC AND
                   ATMOSPHERIC ADMIN.
       Authors:     MERRILL HOHMAN - U.S. EPA REGION 1
       Date:       February 25, 1993
       Format:      CORRESPONDENCE                No. Pgs:  4
       AR No.      16.04.1                       Document No.  000061
-------
                                            APPENDIX D
                               Groundwater Use and Value Determination

                                         January 12, 1998

Mr. Harley Laing
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
1 Congress Street
Boston, MA 02203-2211

SUBJECT:  Merrimack, New Hampshire Plating Site, Groundwater Use and Value Determination  (DES #840630)

Dear Mr. Laing:

    The New Hampshire  Department  of Environmental Services  (Department)  has  completed  the  groundwater  use
and value determination for the New Hampshire Plating Superfund Site  (Site)  located in Merrimack, 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 Site is Medium to High Value. Attached is a worksheet  (Appendix A)
summarizing the site-specific use and value considerations and a list of the sources of information used
for the determination.

    EPA and the Department  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, 3) reflects
the Town of Merrimack's intentions with respect to their long term plans for use of the groundwater in
the vicinity of the Site (Appendix B), and 4) facilitates making a decision that is consistent with the
state and federal corrective action programs. The Department has an increased role because 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 remedies that: (1) achieve treatment, removal or containment
of the source of groundwater contamination and  (2)  restore groundwater guality to Ambient Groundwater
Quality Standards (AGQS) ,  i.e., drinking water standards. The proposed remedy for the Site includes
capping the existing lagoon area to contain the contamination source,  the off-site replacement of
wetlands damaged by Site waste disposal practices,  and natural attenuation of groundwater contamination.
In this case,  it is expected that groundwater contamination levels will diminish with time after the
source has been controlled by capping. Natural attenuation was determined by EPA's consultants to be
egual or superior to an active pump and treat system because, with a cap in-place, there is little or no
difference in the predicted time reguired to attain AGQS at the site.  In fact,  for some pumping
scenarios, the impact was negative due to aguifer characteristics  and the proximity of the Merrimack
River. As at other sites in New Hampshire,  the groundwater contamination plume will be managed through a
Groundwater Management Zone which is likely to diminish in size over time as the contamination source is
contained and groundwater is remediated.

    This determination is also  consistent with  the Town  of Merrimack's long  term strategy  to  reevaluate
the use of the groundwater in the area as an alternative to meet future water supply demands. The Site is
on an aguifer area that has the potential for high yielding wells. Current indications are that the Town
will need additional water supply sources,  which may include the use of the Horseshoe Pond aguifer, in
just over 10 years.  The Department concurs with the Town that the Horseshoe Pond aguifer should not be
abandoned. However,  both the Town and Department also realize that the guality of the groundwater in this
area has been temporarily impaired by the Site and other industrial activities in the area.  It will take
time to remediate the groundwater in this area. The area also continues to have significant
commercial/industrial activity. Conseguently, any future development of water supply wells in this area
will reguire careful aguifer management,  the need for which may diminish with time somewhat as water
guality improves,  and an aggressive wellhead protection program.

http://www.state.nh.us                                           TDD Access: Relay NH 1-800-735-2964
-------
Mr. Harley Laing
Merrimack, NH Plating Site  (DES #840630)
January 12, 1998
Page 2

    If  you have  any  guestions  on this  declaration,  please contact Carl  Baxter at (603)271-2909.

                                      

Attachment
cc:  Philip J. O'Brien, Ph.D., Director, WMD
     Harry Stewart,  P.E., Chief Engineer, WMD
     Carl Baxter, P.E., WMD
     Tal Hubbard, P.E., WMD
     Larry Brill, EPA-New England
     Richard Boynton, EPA-New England
     James DiLorenzo, EPA-New England
     Bruce W. Moreau, Chairman, Merrimack Village District
     Dean Shankle, Jr., Town Manager, Town of Merrimack
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                                           APPENDIX A
                             NEW HAMPSHIRE PLATING SITE, MERRIMACK
                SUMMARY OF GROUNDWATER SITE-SPECIFIC USE AND VALUE CONSIDERATIONS
      FACTORS

1. QUANTITY
2.  QUALITY
HIGH    MEDIUM      LOW                 COMMENTS

                             U.S.G.S. Water Resources Investigation report 86-4358 states that
                             permeable, coarse-grained deposits capable of yielding large guantities of
                             Water to well are located along the Merrimack River from 1 mile south of
                             the Thortons Ferry toll gate of the F.E. Everett Turnpike northward to the
                             Bedford town line (includes study area). However, these discontinuous
  X                          aguifers are surrounded by finer, grained materials. The transmissivity
                             varies from less than 2,000 ft 2/d to more than 8000 ft 2/d. Saturated
                             thickness ranges from about 20 to 1000 ft; the greatest saturated thickness is
                             between Horseshoe Pond and the Southegan River (includes study area).
                             This aguifer has potential for additional high-yield wells, especially north of
                             the Southegan river (north of the study area) because of the large area and
                             saturated thickness or the aguifer and its potential for induced recharge.

            X                Area is commercial/industrial with some residential with other actual and
                             potential future contamination sources. The proximity of the aguifer to the
                             Merrimack River  (induced recharge) may subject it to recent treatment
                             reguirements (Safe Drinking Water Act) for some potential well sites in the
3. CURRENT PUBLIC WATER
SUPPLY SYSTEMS  (PWSS)
4.  CURRENT PRIVATE
DRINKING WATER SUPPLY
WELLS
                             The Merrimack Village Water District (MVWI)) provides drinking water
                             to the study area. The MVWI) operates four municipal wells that draw
                             groundwater from the overburden. Two or the production wells are located
                             one mile north of the site, and the other two production wells are located
                             approximately two miles southwest of the site.

                             The nearest residential well is located 3500 feet to the west and upgradient
                             or the site. A private well located along the western bank of Horseshoe
                             Pond was originally used as an irrigation well for watering lawns. Due to
                             low yields, the well is no longer in use. Jones Chemical Inc., (within
                             study area) has a bedrock water supply well that is used for non-contact
                             cooling water in its manufacturing process. The process water is
                             discharged directly to the Merrimack River. A Groundwater Management
                             Zone  (GMZ)  will be established to control future use of groundwater.
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                                           APPENDIX A
                             NEW HAMPSHIRE PLATING SITE, MERRIMACK
                SUMMARY OF GROUNDWATER SITE-SPECIFIC USE AND VALUE CONSIDERATIONS
       FACTORS
                           HIGH
                                   MEDIUM
                                               LOW
                                                                   COMMENTS
5. LIKELIHOOD AND
IDENTIFICATION OF FUTURE
DRINKING WATER USE
6. OTHER CURRENT OR
REASONABLE EXPECTED
GROUNDWATER USE(S)  IN
REVIEW AREA
U.S.G.S. Water Resources Investigation report 86-4358 states that
permeable, coarse-grained deposits capable of yielding large guantities of
water to wells are located along the Merrimack River from 1 mile south of
the Thortons Ferry toll gate of the F.E. Everett Turnpike northland to the
Bedford town line  (includes study area). However, these discontinuous
aguifers are surrounded by liner, grained materials. The transmissivity
varies from less than 2,000 ft 2/d to more than 8,000 ft 2/d. Saturated
thickness ranges from about 20 to 100 ft; the greatest saturated thickness is
between Horseshoe Pond and the Southegan River (includes study area).
This aguifer has potential for additional high-yield well, especially north of
the Southegan river  (north of the study area) because of the large area and
saturated thickness of the aguifer and its potential for induced recharge.
Current indications are that the Town may need the aguifer in the study
area or other water sources in a little over 10 years. Nevertheless all parties
realize that the guality of the groundwater has been stressed because of
several industries in the area and the area contains significant
industrial/commercial development. It will take time to remediate the
groundwater and institute a well head protection area for the aguifer.

Municipal water available to site area. A Groundwater Management Zone
(GMZ)  will control future use of groundwater. However, area
groundwater is currently used as process water for one industry.
7. ECOLOGICAL VALUE
8. PUBLIC OPINION
Groundwater discharges to Merrimack River and Horseshoe Pond, both
Class B surface waters (swimmable, fishable and with treatment can be
used as a drinking water source).  Both surface waters are used for
recreational purposes.

Town may need to use the aguifer in the study area in a little over 10 years.
The area has potential for high yield wells.
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                                             APPENDIX E
                             Letter/Report to Merrimack Village District


                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                    REGION 1
                           JOHN F. KENNEDY FEDERAL BUILDING
                           BOSTON, MASSACHUSETTS 02203-0001

June 6, 1998

Brian J. Wilson
Assistant Superintendent
Merrimack Village District
2 Greens Pond Road
P.O. Box 1949
Merrimack, NH 03054

Subject:  Additional Hydrogeologic Evaluation from February 13, 1998 Meeting
           Response to Merrimack Village District's Concerns
           New Hampshire Plating Superfund Site

Dear Mr. Wilson:

During EPA's public comment period on the Proposed Cleanup Plan for the New Hampshire Plating Superfund
Site (NHP Site) , the MVD expressed concerns with the passive natural attenuation approach to groundwater
remediation which was presented as EPA's preferred alternative. In a meeting between the MVD, EPA and
NHDES on February 13, 1998, EPA agreed to perform the following activities:

1.   review State and local well siting criteria to determine the feasibility of installing a
     hypothetical municipal supply well in the vicinity of the NHP Site and preferably within the highly
     productive "Horseshoe Pond Aguifer";

2.   evaluate existing hydrogeolic information to determine the anticipated radius of influence of a
     hypothetical supply well and determine the need to isolate the NHP Site contaminant plume; and

3.   present and evaluate a more aggressive groundwater remediation alternative which incorporates active
     flushing to accelerate aguifer restoration.

EPA's consultant, Brown and Root Environmental  (BRE),  has completed an extensive evaluation of the
State's well siting criteria and Emery & Garrett' s  (EG)  town-wide resources study. BRE has concluded that
it may be possible to install a municipal well in an area just south of Horseshoe Pond. Based on existing
information, it appears a well in this area would be on the fringe of the highly productive "Horseshoe
Pond Aguifer", would support a sustainable yield of approximately 250 gpm and would not communicate with
the NHP Site contaminant plume. The MVD would need to collect actual field data to determine accurate
well yields. The property is currently zoned as industrial but is undeveloped.

Based on BRE's report (enclosed), established well siting criteria prohibit installation of a municipal
well in the immediate vicinity of the NHP Site. Therefore, EPA has determined that completion of a more
aggressive groundwater remediation alternative is not necessary. The current passive approach, as
presented in EPA's Proposed Plan, will be protective of public health and the environment. EPA is
planning to include a contingency in the pending Record of Decision (ROD) which would allow for the
installation of physical barriers or other appropriate methods to contain and isolate the plume from a
"newly installed MVD supply well" in the unlikely event that site-related contaminant infiltration
becomes a problem.

EPA has prepared formal written responses to your comments submitted during the public comment period
which will be distributed with the release of the pending ROD. Please review the attached report and call
me at  (617)223-5510 if you have any guestions or would like to schedule a subseguent meeting.



cc:  Tom Andrews, DES
     Liyang Chu, BRE (w/o enclosure)
     Dick Boynton, EPA(w/o enclosure)
     Sean Goodwin, Town (w/o enclosure)
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Brown & Root                                                     Services

55 Jonspin Road / Wilmington, MA 01887-1020 / 978-658-7899 / Fax: 978-658-7870

RAG I-EPA-0659W

Contract No. 68-W6-0045

May 28, 1998

Mr. Jim DiLorenzo  (HBO)
U.S. Environmental Protection Agency
J.F. Kennedy Federal Building
Boston, Massachusetts 02203-2211

Subject:  Evaluation of Potential Supply Well Siting Locations
          New Hampshire Plating Company Site
          Feasibility Study
          RAG I W.A. No. 018-RIFS-01G1

Dear Mr. DiLorenzo:

As reguested, enclosed is the evaluation of potential locations in the vicinity of the New Hampshire
Plating Company (NHPC)  Site located in Merrimack, New Hampshire, that may be suitable for siting a
hypothetical municipal supply well. This evaluation was prepared to address concerns raised by Merrimack
Village. District after the EPA presented its preferred groundwater remediation option for the NHPC Site.
A hydrogeologic evaluation was also prepared that assessed the pumping of a hypothetical well and its
potential influence of the NHPC groundwater plume.

Should you have any guestions or comments on this transmittal, please call me at  (978)658-7899.


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                                         ATTACHMENT
                    EVALUATION OF POTENTIAL SUPPLY WELL SITING LOCATIONS
                NEW HAMPSHIRE PLATING COMPANY SITE, MERRIMACK, NEW HAMPSHIRE
                                  W.A. NO. 018-RIFS-01G1
                                       May 28, 1998
INTRODUCTION

A meeting was held on February 13, 1998 between the U.S. Environmental Protection Agency  (EPA), the
Merrimack Village District  (MVD),  the New Hampshire Department of Environmental Services  (NHDES),  and
Brown & Root Environmental  (B&RE)  to discuss the EPA's preferred alternative to addressing groundwater
contamination associated with the New Hampshire Plating Company  (NHPC) Superfund Site, which is situated
along Wright Avenue near the Horseshoe Pond area, in Merrimack, New Hampshire.

EPA had previously presented Alternative GW2 of the Feasibility Study during the January 1998 public
hearing as its preferred remediation approach. GW2 consists of establishing a Groundwater Management Zone
(GMZ),  performing long-term monitoring of groundwater guality, and allowing the natural attenuation of
metals and volatile organic compounds  (VOCs) to reduce these constituents to the state's Ambient
Groundwater Quality Standards over time. EPA and B&RE explained that GW2 was developed, in part, based on
the current and anticipated future commercial/industrial land use of the NHPC property and adjacent
properties, and the premise that groundwater in this area is not, and would not be used as a potable
water supply because of the industrial activities in the vicinity of NHPC. The entire area is served by
the MVD's distribution system.

During EPA's public comment period, the MVD expressed concerns and dissatisfaction with this approach
because it would not allow groundwater guality to be restored to drinking water standards within a time
frame that would permit the use of the aguifer as a potable water supply. The MVD projects the town will
need additional supply wells within eight years. The MVD wanted EPA to consider an active groundwater
remediation approach that would meet this desired time frame.

During the February 13th meeting,  the MVD informed EPA and the NHDES that information developed in a
town-wide study completed by its consultant, Emery & Garrett Groundwater, Inc. (EGGI), indicated that the
area in the vicinity of the NHPC Site, referred to as the "Horseshoe Pond aguifer", was one of the last
viable locations in the town suitable for siting a municipal water supply well. EPA inguired where the
MVD was considering siting this well, and whether it was practical to install a municipal supply well in
the vicinity of several industrial facilities that have associated groundwater issues  (which are being
addressed or evaluated separately by the NHDES). The MVD indicated that EGGI had determined that the area
underlying the "Horseshoe Pond aguifer" could yield sufficient guantities of water for use, but an actual
location had not yet been identified because of NHPC's Superfund status and the presumption that EPA
would be conducting an active groundwater remediation. EPA felt that it was unreasonable to consider and
implement a costly active aguifer remediation in an industrial area where siting a municipal supply well
would be unlikely. The NHDES indicated that there are state siting regulations for large overburden and
bedrock community wells that would prohibit siting a well near potential contaminant sources.

To resolve this issue, EPA offered, and MVD agreed, that it was necessary to:

    •  identify the closest viable location to situate a hypothetical municipal supply well in the
      vicinity of the NHPC Site and within the "Horseshoe Pond aguifer",

    •  evaluate whether this hypothetical well could yield a desired 300 to 400 gallons per minute rate,

    •  evaluate whether pumping this hypothetical supply well could potentially induce contaminated
      groundwater to flow from the NHPC Site to the well, and

    •  prepare a new groundwater remediation alternative  (with modeling and estimated construction and
      operations costs) that employs active aguifer flushing to accelerate restoration of groundwater
      guality at the NHPC Site.

1.0   Identification of Closest Viable Well Siting Location

To identify the closest viable location to site a hypothetical municipal supply well, B&RE evaluated
several information sources and compiled the findings into several figures enclosed with this evaluation.
By graphically depicting the areas where siting a well is unsuitable because of known or potential
contamination sources, or existing land use, these areas may be eliminated from further consideration and
areas that are viable for installing a supply well can then be identified.
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The following documents or information sources were consulted to determine where well siting could be
restricted or prohibited:

    •  A Guide for New Large Overburden Wells, prepared by the NHDES that explains and defines the State
      of New Hampshire regulation Env-Ws 378, Site Selection

    •  Phase I Groundwater Exploration Report, prepared by Emery & Garrett Groundwater, Inc.  (EGGI) for
      the Merrimack Village District, August 8, 1994.

    •  Town of Merrimack, Community Development Group, re: land use designations for various lots.

    •  Town of Merrimack property maps, Sheet Nos.  3D1, 3D2, 4D, 4D-1, 4D-2, 4D-3, 4D-4,  5D-1, and 5D-2.
      Prepared by James W. Sewall Company, dated April 1, 1979. Revisions: various dates.

Figure 1 depicts the locus map that encompasses the NHPC Site, the Horseshoe Pond area,  the Daniel
Webster Highway area, the F. E. Everett Highway area, property boundaries for various lots adjacent to
the Site, the currently delineated groundwater plume associated with the NHPC Site, and identification of
selected industrial facilities.

Figure 2 depicts the areas that are excluded from consideration as viable well siting locations based on:
presence of potential and known sources of groundwater contamination, other New Hampshire well siting
regulation reguirements, and current land use. B&RE graphically depicted potential contaminant sources
and the necessary protective radii from these potential threats to groundwater guality in Figure 2 to
eliminate from consideration areas in the vicinity of the NHPC Site that would be unsuitable for siting a
potable water supply well. Details on the development of Figure 2 are provided in Section 1.1.

Figure 3 depicts the extent of the 100-year floodplain and the 500-year floodplain, which indicate areas
where if a well is sited, would need to be protected from the effects of the 100-year flood.

Based on the information presented in Figure 2, there appears to be an area situated southeast of
Horseshoe Pond, within the desired "Horseshoe Pond Aguifer", that could be used to site a municipal
supply well because it is currently undeveloped and is sufficiently far from any potential contamination
sources to satisfy the state's siting regulations. However, this area is situated within the 100-year
floodplain, which will reguire that additional measures be taken to ensure that operating a well and a
pump house, if constructed in this area, would not be affected by the effects of a 100-year flood.

1.1  Identification of Potential Contaminant Sources

Two documents were used to develop the protective buffer zones, meaning areas where  siting a municipal
supply well is undesirable or unlikely.

a.   The NHDES document A Guide for New Large Overburden Wells, which summarizes the state regulation
     Env-Ws 378 Site Selection of Wells for Community Water Systems, was used to preliminarily identify
     areas that would not be suitable for siting a municipal supply well. ENV-Ws 378 identifies the
     wellhead protection reguirements to protect the groundwater supply from known or potential
     contaminant sources and incorporates these into the community water systems well siting
     reguirements.

The review and approval process for the siting of a new large overburden well by the NHDES' Water Supply
Engineering Bureau reguires that the applicant, a water supplier, follow the Env-Ws 378 reguirements
including:

    •  establishing a wellhead protection area  (WHPA), the area under which groundwater will flow toward a
      pumping well, using a default of a 4000-feet radius for the supply well (or determined using
      area-specific hydrogeologic characteristics

    •  preparing an inventory of existing and potential contamination sources

    •  establishing a protective radius area around a proposed supply well location so that the
      groundwater supply may be protected from the effects of known or potential contaminant sources. The
      protective radius area is defined "as an area that must be kept in a natural state and that is
      owned or otherwise controlled by the water supplier".

    •  having a well set back at least 50 feet from perennial water bodies

Following Env-Ws 378 reguirements for a proposed production volume of greater than 144,000 gallons per
day (or 100 gpm), a minimum protective radius of 400 feet is reguired. No underground utilities or
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structures may be installed within the protective radius area except for potable water and electrical or
communication conduits. Appendix II of A Guide for New Large Overburden Wells identifies a number of
potential contaminant sources including (but not limited to):

    •  transportation corridors including,  but not limited to highways and railroads

    •  hazardous waste facilities (as regulated under the Resource Conservation and Recovery Act)

    •  manufacturing facilities (including electronics and chemical manufacturing, wood processing)

    •  a vehicle service and repair shops

    •  general service and repair shops

To eliminate areas to be considered for siting a well, 400-foot buffer zones were depicted around
identified potential contaminant sources.  Because transportation corridors are considered potential
contamination sources and may not be located in the wellhead protection area, a 400-foot buffer zone was
depicted in Figure 2 to the east and west of the Boston & Maine railroad right of way, which traverses
the area in a north-south direction just west of the Merrimack River. A sewer line is also located within
the railroad right of way. 400-foot buffer zones were also established around two transportation
corridors: the Daniel Webster Highway and the F. E. Everett Highway.

Hazardous waste facilities were identified and graphically depicted in Figure 2 of this memorandum, and
are based in part on information listed in Appendix E of the EGGI Phase I report (see discussion in
following paragraph); buffer zones of 1500 feet were depicted around these properties based on EGGI's
approach. To identify land uses that may pose potential contaminant threats, Figure 9 of EGGI's report
was consulted in addition to obtaining information from the Town of Merrimack's Community Development
group.

b.   As part of the Phase I Groundwater Exploration Report preparation, EGGI identified areas within
     Merrimack that would be incompatible with developing groundwater resources for potable water
     supplies. Using the NHDES files, EGGI identified known potential contaminant sources, including five
     hazardous waste sites from the NHDES' Federally Registered Sites List,  with groundwater concerns, in
     a grouping in the vicinity of the New Hampshire Plating Company Site. EGGI also identified a number
     of other potential sources of groundwater contamination throughout the area including gas stations
     and existing industrial, commercial,  and high density residential land uses. For the Phase 1 Report
     (Figures 8, 9, and 11), EGGI graphically depicted buffer zones around each known hazardous waste
     site, and identified land use areas that pose potential contaminant threat to groundwater guality,
     which EGGI considered to be less favorable for groundwater development. EGGI designated 1500 feet
     radii circles around each of the five listed on the NHDES Federally Registered Sites List in the
     report figures. Leaking underground storage tank sites and selected areas of known contamination
     were depicted with a 750 feet radius buffer.

B&RE incorporated the 1500 feet distance as a buffer zone surrounding the perimeter of each of the five
Federally Registered Sites in Figure 2. Current commercial and industrial land use areas were also
integrated into Figure 2. Because there are numerous commercial businesses and industrial facilities in
this area of Merrimack, at least a 400 feet distance should be maintained between the properties of
concern and the hypothetical well location. The area encompassed by buffer zones covers the entire area
from mid-Horseshoe Pond northward to the Souhegan River, westward to the Daniel Webster Highway,  and
eastward to the Merrimack River.  EGGI has also identified current industrial, commercial, and high
density  (development too dense to obtain the reguired 400-foot protective radius) land uses within those
buffer zones.

1.2  Identification of Potential Well Siting Locations

To identify potential well siting locations, areas that are currently undeveloped,  pursuant to the NHDES'
Env-Ws 378 reguirements, and are not located within the buffer zones were considered. The NHPC Site and
adjacent areas are situated in an area EGGI considers geologically favorable for groundwater development.
However, based on the well siting reguirements of the Env-Ws 378 regulation and information presented in
EGGI's Phase I report, B&RE concludes that the areas adjacent to the NHPC Site area would not be a
successful candidate for groundwater development. According to the documents reviewed, existing or
potential contamination threats to groundwater and current land use would preclude siting a municipal
supply well in the immediate vicinity of the NHPC Site, and still maintain an effective protective
radius.

One area considered consists of the undeveloped property situated within the "Horseshoe Pond Aguifer
area" and in the vicinity of the NHPC Site is currently zoned for industrial land use, but is not
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actively used. Lot No. 92 of Sheet No. 4D-3, located directly across Wright Avenue from the NHPC Site,  is
currently owned by the YMCA. However, most of this property is within 400 feet of the Daniel Webster
Highway and the B&M Railroad right of way, within 400 feet of commercial properties,  and is within the
1500 feet buffer zones for several of the NHDES'  Federally Registered Sites. This property appears not to
be suitable for siting a municipal supply well.

Another area, comprising several other undeveloped properties situated southeast of Horseshoe Pond area,
was also identified as a possible field location. These properties consist of Lot No. 4 of Sheet No. D4-1
(owned by the New England Pole Co.)  and Lot No. 3 of Sheet No. 3D-1. A small portion of triangularly
shaped area, bounded approximately by the Merrimack River, a tributary of Horseshoe Pond,  and by the
southern property boundary of Lot No. 7 of Sheet 4D-2. While the area is currently zoned for industrial
land use, it is currently unused and undeveloped. There are no abutting active residential, commercial,
or industrial activities. This area is also outside of the 1500 feet buffer zone of any of the NHDES'
Federally Registered Sites. This area appears to be a viable location for siting a hypothetical municipal
well.

This evaluation of potentially suitable locations was prepared only to assess the viability of siting a
hypothetical supply well in the vicinity of the NHPC. The evaluation did not research the ownership of
the properties considered, whether the properties are for sale, or whether it is viable for the MVD to
acguire and use the properties. The evaluation was completed to assess whether there are viable locations
within the "Horseshoe Pond Aquifer" and to support the hydrogeologic evaluation presented in Section 2.0
of this memorandum.

2.0   Hydrogeologic Evaluation

The hydrogeologic evaluation considered two issues:

    •  whether a hypothetical well situated in the vicinity of the NHPC Site, in the"Horseshoe Pond
      Aquifer", could yield the desired 300 to 400 gallons per minute rate  (as discussed with the MVD),
      and

    •  whether pumping this hypothetical supply well could potentially induce contaminated groundwater to
      flow from the NHPC Site and vicinity to the supply well.

B&RE reviewed information presented in EGGI's Phase I Groundwater Exploration Report and in the United
States Geological Survey  (USGS) report titled: Hydrogeology of Stratified-Drift Aquifers and Water
Quality in the Nashua Regional Planning Commission Area South-Central New Hampshire  (Toppin, 1987) .

The Phase I Report presents the results of a geologic and hydrogeologic literature search, which compiled
information from reports prepared by other investigators during water supply investigations and
installation of water supply wells.  The Phase I Report also relies heavily on information and
interpretations presented in the USGS report  (cited above).  The Phase I report presents the sand and
gravel deposits field mapping results, which supplement the USGS surficial geology maps. Bedrock outcrops
were also mapped.

2 .1  Well Yield Evaluation

The Phase I Report was reviewed to determine whether the geologic and hydrogeologic conditions presented
in the report are reasonable, and to evaluate viability of siting a municipal water supply in the
vicinity of the Horseshoe Pond area that would yield a sufficient quantity of water.

Review of the data presented in the USGS report indicates that a bedrock trough is present in the
vicinity of the NHPC Site, as depicted in the various Figures of the Phase I Report.  This bedrock trough
is filled with glacially derived material that have a high transmissivity, as evidenced by the well
yields. The evidence for the trough is corroborated through information provided by water supply wells
and exploration wells that were advanced to refusal. In these reports, refusal is interpreted to be the
top of bedrock. In addition, there are some wells advanced into bedrock within the trough and south of
Horseshoe Pond. These well data, along with field mapping of the till and bedrock outcrops, support the
interpretation of a bedrock trough.

The potential yield of a municipal supply well situated to the southeast of the Horseshoe Pond area was
evaluated using the data presented in the USGS report. Estimation of the well yield used an approach
similar to the one employed by the USGS, which used the Theis equation to predict the drawdown caused by
pumping a water supply well. The input values used in the Theis equation are:
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    •  Transmissivity - 2,000 and 4,000 feet squared per day  (ft 2/day) (from the USGS report)

    •  Storativity - 15 percent (assumed, typical of sand and gravel)

    •  Elapsed time - 180 days (consistent with regulatory requirements, assuming no recharge)

    •  Saturated thickness - approximately 60 feet  (based on USGS report)

    •  Pumping rate - rate that would result in a drawdown that does not exceed 30 percent of the
      saturated thickness of the aquifer (approx. 18 feet)

    •  Image well methods - used to evaluate the impact of the Merrimack River

The first set of estimates assumed that no greater than 30 percent drawdown in the saturated thickness
would be induced by the hypothetical pumping well to minimize exposure of the well screen to prevent
carbon dioxide-carbonate fouling [Driscoll, 1986] .  By limiting the drawdown, the cost for pumping water
out of the well can also be minimized. Assuming that the hypothetical pumping well has a screen length of
20 feet and 18 feet of drawdown,  there would be 22 feet of saturated aquifer available for drawdown. It
is estimated that pumping rates of 125 and 250 gallons per minute  (gpm) could be sustained by the
hypothetical pumping well based on the USGS' estimated transmissivity values (2,000 and 4,000 ft 2/day,
respectively). While these estimated rates  (see Tables 1 and 2) are lower than the 300 to 400 gpm desired
by the MVD, they do represent the potential sustainable yields.

A second set of estimates were prepared to evaluate the effect of pumping the hypothetical well at higher
sustained rates where drawdown would be approximately 66 percent of the saturated thickness  (or 40 feet).
Under these conditions, more of the well screen could be exposed during pumping and result in fouling. A
greater unsaturated thickness would also result in higher pumping costs because more energy would be
required to lift water to the ground surface. Using the estimated transmittivity values of 2,000 and
4,000 ft 2/day, sustained pumping rates of 325 and 600 gpm, respectively, could be attained  (as presented
in Tables 3 and 4).

These estimates indicate that sustainable yield between 125 to 250 gpm are viable, under conservative
conditions that are protective of the well and having adequate saturated thickness for dry periods.
Higher yields are possible, but there would much greater potential for fouling the well screen and for
having inadequate reserve saturated aquifer

2.2  Estimated Pumping Well Influence

To address whether a hypothetical pumping well in the vicinity of the Horseshoe Pond area could draw
contaminants from the plume in the NHPC Site's vicinity, the drawdown induced by pumping at various rates
and at various distances from the pumping well were estimated and are presented in Tables 1 through 4.

A review of the Table 2  (250 gpm rate) indicates that a well pumping, at a sustainable yield, in the
vicinity of Horseshoe Pond would not create a significant predicted drawdown (0.17 feet)  at a distance of
approximately 1,800 feet from the pumping well. The predicted drawdowns represent maximum values because,
at this distance from the pumping well, the cone of depression induced by the pumping well would
intersect Horseshoe Pond. Surface water from the pond would be drawn into the cone of depression, which
would then stop increasing in size. Therefore, this analysis indicates that it is highly unlikely that
contaminants from the NHPC site would be drawn into a water supply well pumping at between 125 to 250 gpm
in the vicinity of the Horseshoe Pond area.

3.0  New Groundwater Remediation Alternative

A new groundwater remediation alternative to include active flushing of the portion of the aquifer
underlying the Site was not developed. As described in Section 1.0 above, installation of a hypothetical
municipal well in the immediate vicinity of the NHPC area is not viable.  This determination is based on
required well siting criteria and is not influenced by the existing groundwater contaminant plume
emanating from the NHPC site. Since installation of a hypothetical well in the immediate vicinity of the
NHPC site is not be possible, even after the contaminant plume is fully remediated, a more active
groundwater remediation alternative would not facilitate the MVD's need to access the aquifer beneath the
site.

Additionally, the hydrogeologic evaluation determined that it is unlikely a hypothetical well in this
area would communicate with the NHPC plume. Therefore, a physical barrier or other form of plume
contaminant does not appear to be necessary at this time.
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4.0   Summary

Based on the review of available information,  B&RE concluded that it would be highly infeasible to site a
hypothetical municipal supply well in the NHPC Site's immediate vicinity,  and have an adequate wellhead
protection area, and a protective radius of at least 400 feet.  There are five know hazardous waste sites
with groundwater concerns surrounding the NHPC Site. In addition, land use in the NHPC vicinity is either
commercial or industrial, and siting a water supply well in this area would be infeasible because of
inadequate wellhead protection.

However, there is a parcel piece of undeveloped land situated to the southeast of Horseshoe Pond that
could be a viable water supply well siting location, which is adequately far from identified potential
contaminant sources, but within the desirable "Horseshoe Pond Aquifer".

B&RE's hydrogeologic evaluation concluded that sustained pumping rates of between 125 to 250 gpm are
likely. While higher pumping rates are possible,  they will increase the likelihood of fouling the well
screen because of excessive drawdown and exposure of the well screen to ambient air,  have much less
saturated aquifer thickness, and would result in higher operational costs .  The hydrogeologic evaluation
also determined that pumping of the hypothetical supply well would not likely draw contaminated
groundwater from the NHPC vicinity to the supply well because of the limited influence over a long
distance and that Horseshoe Pond would recharge the supply well under sustained pumping conditions.

Therefore, based on the above assessments, remediating the groundwater plume at the NHPC Site would not
allow for a successful siting of a high yield water supply well in the Site's immediate vicinity because
of the need to meet Env-Ws 378 siting requirements, proximity to four NHDES Federally Registered Sites,
and proximity to commercially and industrially zoned lands and properties.
-------
                                             TABLE  1
                    ESTIMATED DISTANCE/DRAWDOWN CALCULATIONS AT 125 GEM
                          PUMPING AND  IMAGE  WELL SUPERPOSITION
                       MEW HAMPSHIRE PLATING CO. SITE,  MERRIMACK,  NH
Monitoring
  Point
Distance from
  well
r = 0.5 ft
 Pumping/
Image Wells
 ft 2/day

  PW-1
Transmissivity
      (T)
                                2.00E+03
Storativity
    (S)
                                                  1.50E-01
               Time Since
 Radial         Pumping
Distance  (r)  Started  (t)
  feet           days
                                                                     0.5
                                                                                     180
                                                                                                     Flow  (Q)      Flow  (Q)       u         W(u)
                                                                                                      GPM           ft 3/day

                                                                                                       125           2.41E+04   2.60E-08    16.89
Drawdown
   (s)
  feet

  16.17
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
400 ft
600 ft
400 ft
800 ft
800 ft
1000 ft
800 ft
1200 ft
1200 ft
1400 ft
1200 ft
1600 ft
1800 ft
2000 ft
1800 ft
2200 ft
PW-1
IW-1
PW-1
IW-1
IW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
2.00E+03
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
1.50E-01
400
600
400
800
800
1000
800
1200
1200
1400
1200
1600
1800
2000
1800
2200
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
Eguations used:
1) u=r 2 S/4Tt

PW = Pumping Well
IW = Image Well
                2)s=(Q4 T)W(u)
125
-125
2
-2
.41E+04
.41E+04
1.67E-02
3.75E-02
3
2
.51
.73
Predicted Drawdown
125
-125
2
-2
.41E+04
.41E+04
1.67E-02
6.67E-02
3
2
.51
.19
Predicted Drawdown
125
-125
2
-2
.41E+04
.41E+04
6.67E-02
1.04E-01
2
1
.19
.82
Predicted Drawdown
125
-125
2
-2
.41E+04
.41E+04
6.67E-02
1.50E-01
2.
1.
19
46
Predicted Drawdown
125
-125
2
-2
.41E+04
.41E+04
1.50E-01
2.04E-01
1.
1.
46
22
Predicted Drawdown
125
-125
2
2
.41E+04
.41E+04
1.50E-01
2.67E-01
1.
0.
46
98
Predicted Drawdown
125
-125
2
-2
.41E+04
.41E+04
3.38E-01
4.17E-01
0.
0.
81
67
Predicted Drawdown
125
-125
2
2
.41E+04
.41E+04
3.38E-01
5.04E-01
0.
0.
81
56
Predicted Drawdown
3,
-2,
0,
3,
-2,
1,
-2,
-1,
0,
2,
-1,
0,
1,
-1,
0,
1,
-0,
0,
0,
-0,
0,
0,
-0,
0,
.36
.61
.75
.36
.10
.26
.10
.74
.35
.10
.40
.70
.40
.17
.23
.40
.94
.46
.78
.64
.13
.78
.54
.24
-------
                                           TABIiE 2
                      ESTIMATED DISTANCE/DRAWDOWN CALCULATIONS AT 250 GPM
                           PUMPING AND IMAGE WELL SUPERPOSITION
                      MEW HAMPSHIRE PLATING CO. SITE, MERRIMACK, NH
Monitoring
Point
Distance from
well
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
0.5 ft
400 ft
600 ft
400 ft
800 ft
800 ft
1000 ft
800 ft
1200 ft
1200 ft
1400 ft
1200 ft
1600 ft
1800 ft
2000 ft
1800 ft
2200 ft
Pumping/
Image Wells
ft 2 /day
PW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
Eguations used:
1)  u=r 2 S/4Tt

PW = Pumping Well
IW = Image Well
                             Transmissivity
                                    (T)
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03
2)s=(Q4 T)W(u)
                Storativity
                    (S)
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01
               Time Since
 Radial         Pumping
Distance (r)  Started (t)
  feet           days
   0.5

   400
   600

   400
   800

   800
   1000

   800
  1200

  1200
  1400

  1200
  1600

  1800
  2000

  1800
  2200
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180
Flow (Q)
 GPM

 250

 250
-250

 250
-250

 250
-250

 250
-250

 250
-250

 250
-250

 250
-250

 250
-250
                               Flow (Q)
                               ft 3/day

                                4.81E+04
                         W(u)
                                                                                                                               1.30E-08
                                                                                                                                            17.58
 4.81E+04    8.33E-03
-4.81E+04    1.88E-02
      Predicted Drawdown
 4.81E+04    8.33E-03
-4.81E+04    3.33E-02
      Predicted Drawdown
 4.81E+04    3.33E-02
-4.81E+04    5.21E-02
      Predicted Drawdown
 4.81E+04    3.33E-02
 4.81E+04    7.50E-02
      Predicted Drawdown
 4.81E+04    7.50E-02
 4.81E+04    1.02E-01
      Predicted Drawdown
 4.81E+04    7.50E-02
-4.81E+04    1.33E-01
      Predicted Drawdown
 4.81E+04    1.69E-01
-4.81E+04    2.08E-01
      Predicted Drawdown
 4.81E+04    1.69E-01
-4.81E+04    2.52E-01
      Predicted Drawdown
Drawdown
   (s)
 feet

  16.83
4,
3,

4,
2,

2,
2,

2,
2,

2,
1,

2,
1,

1,
1,

1,
1,
.22
.40

.22
.87

.87
.43

.87
.09

.09
.82

.09
.59

.36
.18

.36
.04
4,
-3,
0,
4,
-2,
1,
2,
-2,
0,
2,
-2,
0,
2,
-1,
0,
2,
-1,
0,
1,
-1,
0,
1,
-1,
.04
.26
.79
.04
.75
.29
.75
.33
.42
.75
.00
.75
.00
.74
.26
.00
.52
.48
.30
.13
.17
.30
.00
                                                                                                                                                       0.31
-------
                                                TABIiE 3
                            ESTIMATED DISTANCE/DRAWDOWN CALCULATIONS AT 300 GEM
                                 PUMPING AND IMAGE WELL SUPERPOSITION
                             MEW HAMPSHIRE PLATING CO. SITE, MERRIMACK, NH
Monitoring
Point
Distance from
well
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
0.5 ft
400 ft
600 ft
400 ft
800 ft
800 ft
1000 ft
800 ft
1200 ft
1200 ft
1400 ft
1200 ft
1600 ft
1800 ft
2000 ft
1800 ft
2200 ft
Pumping/
Image Wells
ft 2 /day
PW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
PW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
                             Transmissivity
                                   (T)
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03

                                 2.00E+03
                                 2.00E+03
                Storativity
                    (S)
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01
               Time Since
 Radial         Pumping
Distance (r)   Started (t)
  feet           days
   0.5

   400
   600

   400
   800

   800
   1000

   800
   1200

   1200
   1400

   1200
   1600

   1800
   2000

   1800
   2200
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180
Flow (Q)
 GPM

 325

 325
-325

 325
-325

 325
-325

 325
-325

 325
-325

 325
-325
 325
-325
Flow (Q)        u         W(u)
ft 3/day

 6.26E+04   2.60E-08     16.89

 6.26E+04   1.67E-02      3.51
-6.26E+04   3.75E-02      2.73
      Predicted Drawdown
 6.26E+04   1.67E-02      3.51
-6.26E+04   6.67E-02      2.19
      Predicted Drawdown
 6.26E+04   6.67E-02      2.19
-6.26E+04   1.04E-01      1.82
      Predicted Drawdown
 6.26E+04   6.67E-02      2.19
-6.26E+04   1.50E-01      1.46
      Predicted Drawdown
 6.26E+04   1.50E-01      1.46
-6.26E+04   2.04E-01      1.22
      Predicted Drawdown
 6.26E+04   1.50E-01      1.46
-6.26E+04   2.67E-01      0.98
      Predicted Drawdown
 6.26E+04   3.38E-01      0.81
 6.26E+04   4.17E-01      0.67
      Predicted Drawdown
 6.26E+04   3.38E-01      0.81
 6.26E+04   5.04E-01      0.56
      Predicted Drawdown
Drawdown
(s)
feet
42.
8.
-6.
1.
8.
-5.
3.
5.
-4.
0.
5.
-3.
1.
3.
-3.
0.
3.
-2.
1.
2.
-1.
0.
2.

04
74
80
94
74
45
29
45
53
92
45
63
82
63
04
60
63
44
19
02
67
35
02
                                                                                                                                                      -1.39
                                                                                                                                                       0.62
 Eguations used:
1)  u=r 2 S/4Tt

PW = Pumping Well
IW = Image Well
2)s=(Q4 T)W(u)
-------
                                             TABIiE 4
                          ESTIMATED DISTANCE/DRAWDOWN CALCULATIONS AT 300 GPM
                               PUMPING AND IMAGE WELL SUPERPOSITION
                           MEW HAMPSHIRE PLATING CO. SITE, MERRIMACK, NH
Monitoring
Point
Distance from
well
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
r =
0.5 ft
400 ft
600 ft
400 ft
800 ft
800 ft
1000 ft
800 ft
1200 ft
1200 ft
1400 ft
1200 ft
1600 ft
1800 ft
2000 ft
1800 ft
2200 ft
Pumping/
Image Wells
ft 2 /day
PW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
PW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
PW-1
IW-1
                             Transmissivity
                                    (T)
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03

                                 4.00E+03
                                 4.00E+03
Storativity
(S)
Radial
Distance (r)
feet
Time Since
Pumping
Started (t)
days
Flow (Q)
GPM
Flow (Q)
ft 3/day
                                                                                                                W(u)
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01

                  1.50E-01
                  1.50E-01
0.5

400
600

400
800

800
1000

800
1200

1200
1400

1200
1600

1800
2000

1800
2200
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180

180
180
 600

 600
-600

 600
-600

 600
-600

 600
-600

 600
-600

 600
-600

 600
-600

 600
-600
                                                                                                                    1.16E+04
                                                                                                                               1.30E-08
                                                                                                                                            17.58
 1.16E+04    8.33E-02
-1.16E+04    1.88E-02
      Predicted Drawdown
 1.16E+04    8.33E-02
-1.16E+04    3.33E-02
      Predicted Drawdown
 1.16E+04    3.33E-02
-1.16E+04    5.21E-01
      Predicted Drawdown
 1.16E+04    3.33E-02
-1.16E+04    7.50E-01
      Predicted Drawdown
 1.16E+04    7.50E-01
-1.16E+04    1.02E-01
      Predicted Drawdown
 1.16E+04    7.50E-01
-1.16E+04    1.33E-01
      Predicted Drawdown
 1.16E+04    1.69E-01
 1.16E+04    2.08E-01
      Predicted Drawdown
 1.16E+04    1.69E-01
 1.16E+04    2.52E-01
      Predicted Drawdown
                                                                                    Drawdown
                                                                                       (s)
                                                                                     feet
                                                                                                                                                      40.40
4,
3,

4,
2,

2,
2,

2,
2,

2,
1,

2,
1,

1,
1,

1,
1,

.22
.40

.22
.87

.87
.43

.87
.09

.09
.82

.09
.59

.36
.18

.36
.04

9,
-7,
1,
9,
-6,
3,
6,
-5,
1,
6,
-4,
1,
4,
-4,
0,
4,
-3,
1,
3,
-2,
0,
3,
-2,
0,
.70
.81
.88
.70
.59
.10
.59
.58
.01
.59
.80
.79
.80
.18
.62
.80
.65
.15
.13
.71
.41
.13
.39
.74
 Eguations used:
1)  u=r 2 S/4Tt

PW = Pumping Well
IW = Image Well
2)s=(Q4 T)W(u)
-------
                               APPENDIX F
                         CORRESPONDENCE FROM THE
                           TOWN OF MERRIMACK



June 3, 1997

Mr. Carl Baxter
6 Hazen Drive
Concord, NH 03301

Dear Mr. Baxter:

A study performed by MVD's hydrogeologists in 1994-1995 showed that the Horseshoe Pond area near New
Hampshire Plating may be one of the only significant aguifers left in Merrimack.

As you know, Merrimack recently put a well on line in the Town of Hollis, and we have one additional well
site yet to tap, also in Hollis. However, these are small wells and Merrimack is still growing. We expect
to have that last source of water on line by the year 2004, after restoring a well contaminated by
Merrimack Industrial Metals in South Merrimack.

Depending on Merrimack's growth rate and the amount of water we're able to pump from well 6, we will need
additional water sources as early as 2008, about 10-11 years from now. Therefore, it is critical that the
Horseshoe Pond aguifer not be abandoned or downgraded from the high value aguifer it represents.


-------
                              Emery & Garrett Groundwater, Inc.
                               56 Main Street • P.O. Box 1578
                                Meredith, New Hampshire 03253

     (603) 279-4425                                                 Fax (603) 279-8717

                                                 June 26, 1997

Mr. Carl Baxter
Administrator
New Hampshire Department of Environmental Services
Waste Management Division
Hazardous Waste Remediation Bureau                                       JUN 30
6 Hazen Drive
P.O. Box 95
Concord, NH 03301

Dear Mr. Baxter,

    The  Merrimack Village District  (MVD)  Board  of Commissioners has reguested  that  I write  you  this brief
letter regarding the potential to protect/remediate groundwater resources proximal to the Horseshoe Pond
region in Merrimack, New Hampshire. As I understand it, you are considering which aguifers in the State
will receive priority for future protection/cleanup. Groundwater resources in Merrimack, for the most
part, have been developed to nearly their fullest extent. Merrimack currently uses seven sand and gravel
wells spread throughout the district to meet their daily and peak water supply demands. According to the
Water Supply Master Plan,  the MVD will need to secure additional groundwater resources in the future.

    Emery &  Garrett  Groundwater,  Inc.  (EGGI)  conducted  a  groundwater investigation  in  1994  for  the entire
Merrimack Village District with the objective of assessing potential groundwater resources that could be
developed to meet future water supply needs of the MVD. Based on our investigation, we believe that the
geological environment proximal to the Horseshoe Pond  (Figure 1)  is favorable for the development of
groundwater resources from unconsolidated sand and gravel materials.  Unfortunately, we were not able to
recommend that this aguifer be pursued for development in its present state due to existing contaminant
threats to groundwater guality. On behalf of the MVD, we ask that this aguifer surrounding the Horseshoe
Pond area be given a high priority for remediation and protection efforts so that it could potentially be
used in future years.



cc:  Eileen Pannetier - MVD Commissioner


-------