EPA/ROD/RO1-05/007
2005
EPA Superfund
Record of Decision:
DURHAM MEADOWS
EPA ID: CTD001452093
OU01
DURHAM, CT
09/30/2005
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 1
RECORD OF DECISION
SDMS OocID 238284
DURHAM MEADOWS SUPERFUND SITE
DURHAM, CONNECTICUT
SEPTEMBER, 2005
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Record of Decision
Table of Contents
PART 1: THE DECLARATION
A. STATEMENT OF BASIS AND PURPOSE
B. ASSESSMENT OF SITE
C. DESCRIPTION OF SELECTED REMEDY
D. STATUTORY DETERMINATIONS
E. SPECIAL FINDINGS
F. ROD DATA CERTIFICATION CHECKLIST
G. AUTHORIZING SIGNATURES
PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1. History of Site Activities
2. History of Federal and State Investigations and Removal and Remedial Actions
3. History of CERCLA Enforcement Activities
C. COMMUNITY PARTICIPATION
D. SCOPE AND ROLE OF RESPONSE ACTION
E. SITE CHARACTERISTICS
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
G. SUMMARY OF SITE RISKS
1. Human Health Risks
2. Ecological Risks
3. Basis for Response Action
H. REMEDIATION OBJECTIVES
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30,2005
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Table of Contents
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
J. DESCRIPTION OF ALTERNATIVES
K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
L. THE SELECTED REMEDY
M. STATUTORY DETERMINATIONS
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
O. STATE ROLE
APPENDICES
Appendix A: Tables,
Appendix B: Figures.
Appendix C: State of Connecticut Letter of Partial Concurrence
Appendix D: Responsiveness Summary
Appendix E; Glossary of Acronyms
Appendix F: ARARs Tables
Appendix G: Administrative Record Index
Appendix H: References
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Record of Decision
Part 1: The Declaration
DECLARATION FOR THE RECORD OF DECISION
Durham Meadows Superfund Site
Durham, Middlesex County, Connecticut
CTD001452093
A. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Durham Meadows
Superfund Site (Site), in Durham, Connecticut, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA),
42 USC § 9601 etseq as amended by the Superfund Amendments and Reauthorization Act of
1986, and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300 et seq., as amended. The Director of the Office of
Site Remediation and Restoration has been delegated the authority to approve this Record of
Decision (ROD).
This decision was based on the Administrative Record, which has been developed in
accordance with Section 113(k) of CERCLA, and which is available for review at the Site
repository at the Durham Public Library, 7 Maple Avenue in Durham, CT, and at the United
States Environmental Protection Agency (EPA) Region 1 Office of Site Remediation and
Restoration Records Center in Boston, Massachusetts. The Administrative Record Index in
Appendix G identifies each of the items comprising the Administrative Record upon which the
selection of the remedial action is based.
The State of Connecticut partially concurs with the Selected Remedy.
B. ASSESSMENT OF THE SITE
The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the environment.
C. DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the Durham Meadows Superfund Site. The selected
remedy is a comprehensive remedy which addresses principal Site risks by mitigating all current
and potential future human health risks at the Merriam Manufacturing Company (MMC) Study
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Durham Meadows Superfund Site
Durham, Connecticut
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Date; September 30, 2005
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Area, the Durham Manufacturing Company (DMC) Study Area, and the Site-wide Groundwater
Study Area. The MMC Study Area consists of the facility property, and includes the abutting
residential property at 275 Main Street. The DMC Study Area consists of the facility property,
excluding the portion of the property located east of Ball Brook. The Site-wide Groundwater
Study Area consists generally of groundwater in the bedrock aquifer within the limits of the Site,
including the MMC and DMC facilities, as well as residential areas impacted by groundwater
contamination from the source areas.
Soil vapor extraction, and soil excavation and off-site disposal, as well as institutional controls,
shall be implemented at the MMC Study Area such that principal threats in soil and soil vapor
will no longer present an unacceptable risk to current and future residents via ingestion, dermal
contact, or inhalation, and making the MMC Study Area available for reuse as a residential or
industrial/commercial parcel, with certain restrictions to ensure the remedy continues to be
protective of human health and the environment.
Soil excavation and off-site disposal, and institutional controls, shall be implemented at the
DMC Study Area such that principal threats in overburden (shallow) groundwater will no longer
present an unacceptable risk to future construction workers at the DMC Study Area via dermal
contact and inhalation, or to future onsite residents via inhalation. Mass contaminant removal
may also have the additional benefit of reducing overall groundwater contaminant levels over
time; this alternative shall remove source areas to the maximum extent practicable. The DMC
Study Area will be suitable for continued use as an industrial/commercial parcel.
An alternate water supply via connection from the City of Middletown Water Distribution
System, as well as institutional controls, shall be implemented in the Site-wide Groundwater
Study Area such that principal threats in groundwater will no longer present an unacceptable risk
to current and future residents via ingestion, dermal contact, or inhalation. As a contingency
measure, an alternate water supply, via development of and connection to a new groundwater
source, is retained in the event connection to the City of Middletown Water Distribution System
cannot be implemented for administrative or other reasons, or cannot be implemented in a timely
manner. Also included is the interim measure of continued monitoring and filtration, and
provision of bottled water as necessary, of impacted private (mostly residential) wells, and any
other private wells within the Site-wide Groundwater Study Area that come to be impacted by
Site-related contamination, as currently required under state order and state regulations, to ensure
continued protectiveness of human health and the environment until construction of the alternate
water supply portion of the remedy is complete and operational. A technical impracticability
waiver encompasses all areas in the overburden and bedrock aquifers that are currently or
conceivably could be impacted by contamination emanating from the Site, In conjunction with
the alternate water supply, a monitoring network will be implemented to ensure that
contaminated groundwater does not migrate and institutional controls will prevent use of
contaminated groundwater; a contingency remedy of groundwater extraction for hydraulic
containment will be implemented if it is determined that groundwater is migrating beyond the
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Durham, Connecticut
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Date: September 30, 2005
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technical impracticability zone.
Further delineation of areas posing potential unacceptable indoor air risks on and outside of the
MMC and DMC Study Areas will occur, and further actions may be taken to address such risks
(including, without limitation, sub-slab depressurization systems and institutional controls), such
that low level threats detected in shallow groundwater shall not present an unacceptable risk to
current and future residents via inhalation.
The major components of this remedy are:
• Soil excavation and off-site disposal, in conjunction with soil vapor extraction, at the
MMC Study Area to address risks to human health from contamination in soil and soil
vapor. Excavation of a localized area of surface soil contamination on an adjacent
residential parcel will also occur,
• Excavation and off-site disposal of soil hot spot areas at the DMC Study Area in order to
address risks to human health from contamination in overburden (shallow) groundwater
and to address source contamination.
• Connection to the Middletown Water Distribution System to distribute an alternative
source of public water to all residences currently affected by groundwater contamination
and a buffer zone of residences located near the contaminated area. Development of and
connection to a new groundwater source is retained as a contingency measure in the event
that a connection to the City of Middletown Water Distribution System cannot be
implemented for administrative or other reasons, or cannot be implemented in a timely
manner. Also included is the interim measure of continued monitoring and filtration, and
provision of bottled water as necessary, of impacted private (mostly residential) wells,
and any other private wells within the Site-wide Groundwater Study Area that come to be
impacted by Site-related contamination, as currently required under state order and state
regulations, to ensure continued protectiveness of human health and the environment until
construction of the alternate water supply portion of the remedy is complete and
operational. This alternative addresses current and future risk to human health from
ingestion of contaminated groundwater.
• For the overall area of groundwater contamination, implementation of a monitoring
network for the dissolved plume to ensure no migration of groundwater beyond its current
general boundary.
• Contingency to implement a groundwater extraction system for hydraulic containment if
monitoring indicates that the overall plume or source zone is spreading or migrating
beyond its current general boundary.
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Durham, Connecticut
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• Implementation of a technical impracticability waiver of the applicable or relevant and
appropriate requirements that would normally require cleanup of the groundwater, since it
is not technically practicable to clean up the groundwater to drinking water and other
standards in a reasonable amount of time.
• Institutional controls, primarily in the form of Environmental Land Use Restrictions
(ELURs) as defined in the Connecticut Remediation Standard Regulations (CT RSRs),
and/or by local ordinance, in a variety of areas to prevent unrestricted future use of certain
areas of the Site or use of contaminated groundwater.
• Further delineation of areas posing potential indoor air risks on and outside of the MMC
and DMC Study Areas by further characterization, including the collection of shallow
groundwater data. If there are unacceptable risks, then further actions will be taken to
address such risks, including without limitation, sub-slab depressurization systems and
institutional controls on vacant properties or portions of properties, in accordance with
EPA and Connecticut Department of Environmental Protection (CT DEP) requirements.
• Five-year reviews to ensure that the remedy continues to be protective of human health
and the environment.
D. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are applicable or relevant and appropriate to the remedial action with
the exception of chemical-specific requirements for overburden and bedrock groundwater which
are waived, is cost-effective, and utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable.
Based on the technical infeasibility of restoring both the overburden and bedrock aquifers in a
reasonable timeframe, EPA concluded that it was impracticable to clean up all contaminated
overburden and bedrock groundwater throughout the Site and at the DMC Study Area in a cost-
effective manner. Thus, the selected remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy. Only the combination of alternatives at the
MMC Study Area partially satisfy the preference for treatment, by implementing soil vapor
extraction to treat volatile organic compounds prior to excavating contaminated soil and
disposing of it off-site.
Because this remedy will result in hazardous substances remaining on-site above levels that
allow for unlimited use and unrestricted exposure (and groundwater and/or land use restrictions
are necessary), a review will be conducted within five years after initiation of remedial action to
ensure that the remedy continues to provide adequate protection of human health and the
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Durham, Connecticut
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environment. Five-year reviews will continue as long as waste remains at the Site and unlimited
use is restricted.
E. SPECIAL FINDINGS
Issuance of this ROD embodies specific determinations made by the Director of the Office of
Site Remediation and Restoration pursuant to CERCLA. Under section 121 (d)(4)(C) of
CERCLA, the Director of the Office of Site Remediation and Restoration hereby waives
compliance with chemical-specific federal and state applicable or relevant and appropriate
requirements (ARARs) that would normally require restoration of overburden and bedrock
groundwater. Due to the nature of the Durham Meadows Superfund Site, full compliance with
these requirements is not technically feasible in a reasonable timeframe,
A portion of the DMC Study Area contains wetlands. Section 404 of the Clean Water Act and
Executive Order 11990 (Protection of Wetlands) require a determination that federal actions
involving dredging and filling activities or activities in wetlands minimize the destruction, loss or
degradation of wetlands and preserve and enhance the natural and beneficial values of wetlands.
EPA has determined that there is no actionable ecological risk at the Site, therefore none of the
cleanup alternatives specifically involves actions to cleanup wetlands areas. EPA has determined
it is unlikely that any of the remedial alternatives will involve activity that will impact wetlands
areas at or around the Site. If, however, as part of future design activities, EPA determines that
there is no practical alternative to conducting work in wetlands, EPA will then minimize
potential harm or avoid adverse effects to the extent practical. Best management practices will
be used to minimize adverse impacts on the wetlands, wildlife and its habitat. Damage to these
wetlands would be mitigated through erosion control measures and proper re grading and
revegetation of the impacted area with indigenous species. If the loss of wetlands areas occurs,
wetlands would be restored or replicated consistent with the requirements of the federal and state
wetlands protection laws.
Portions of the Site also are located within the 100-year fioodplain. Executive Order 11988
(Protection of Floodplains) requires a determination of whether federal actions will occur in
floodplains. If work will occur in floodplains, the federal agency must consider alternatives that
avoid adverse impacts to the fioodplain. If the only practical alternative requires siting in a
fioodplain, the agency must then minimize potential harm to the fioodplain. EPA has determined
it is unlikely that any of the remedial alternatives will involve activity that will impact fioodplain
areas at or around the Site. If, however, as part of future design activities, EPA determines that
there is no practical alternative to conducting work in floodplains, EPA will then minimize
potential harm and avoid adverse effects to the extent practical. If the loss of fioodplain areas
occurs, compensatory flood storage would be provided consistent with the requirements of the
federal and state wetlands protection laws.
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Durham Meadows Superfund Site
Durham, Connecticut
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Date; September 30, 2005
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F. ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this Record of
Decision. Additional information can be found in the Administrative Record file for this Site.
1. Chemicals of concern (COCs) and their respective concentrations
2. Baseline risk represented by the COCs
3. Cleanup levels established for COCs and the basis for the levels
4. Current and future land and ground-water use assumptions used in the baseline
risk assessment and ROD.
5. Land and groundwater use that will be available at the Site as a result of the
selected remedy
6. Estimated capital, operation and maintenance (O&M), and total present worth
costs; discount rate; and the number of years over which the remedy cost
estimates are projected
7. Decisive factor(s) that led to selecting the remedy
G. AUTHORIZING SIGNATURES
This ROD documents the selected remedy for the Durham Meadows Superfund Site. This
remedy was selected by the EPA with partial concurrence of the Connecticut Department of
Environmental Protection.
Concur and recommended for immediate implementation;
U.S. Environmental Protection Agency
By: I Date: Q^j 1^1
Susan Studlien /
Director
Office of Site Remediation and Restoration
Region 1
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THE DECISION SUMMARY
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
Durham Meadows Superfund Site
Durham, Middlesex County, Connecticut
CERCLIS Identification Number CTD001452093
EPA and PRP Lead
The Durham Meadows Superfund Site (Site) is located in the Town of Durham, Middlesex
County, Connecticut, and includes an area of groundwater contamination generally centered on
Main Street. The Site includes historic Main Street in Durham center, and contains industrial
and residential properties. The Site is generally bounded by Talcott Lane to the north; Brick
Lane, Ball Brook and Allyn Brook to the East; Allyn Brook to the south; and wetlands west of
Maple Avenue to the west.
The Site is centered around the Durham Manufacturing Company (DMC), a currently operating
manufacturing facility located at 201 Main Street, and the former location of Merriam
Manufacturing Company, Inc. (MMC) at 281 Main Street. Both companies manufactured metal
cabinets, boxes and other items. The companies' past disposal of wastewater in lagoons or
sludge drying beds, spills at both facilities, and inadequate drum storage practices at MMC,
among other things, contributed to the contamination at each facility and in the overall area of
groundwater surrounding both facilities. Contamination from volatile organic compounds
(VOCs) has been detected in soil and groundwater on both industrial properties, as well as in
residential drinking water wells surrounding the MMC and DMC facilities.
A more complete description of the Site can be found in Section 1.0 of the Remedial
Investigation Report (Metcalf & Eddy, June 2005),
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1, History of Site Activities
Merriam Manufacturing Company, Inc. (MMC) was established in 1851 at the 281 Main Street
location in Durham, Connecticut, MMC manufactured metal products, including displays, boxes
and cases, by pressing, breaking and welding sheet metal that was then degreased, painted and
assembled. Beginning in 1940, the plant used trichloroethene (also known as trichloroethylene,
or TCE) to clean boxes prior to painting. In 1953, the plant installed new equipment including a
"water-wash degreaser." In 1974, the plant was using TCE, 1,1,1 -trichloroethane (also known as
1,1,1-TCA, or TCA), and methylene chloride in vapor degreasers. A 600-gallon vapor degreaser
was used from 1975 to 1986, and a 2,300-gaIIon vapor degreaser was used from 1978 to 1993.
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Durham, Connecticut
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Floor drains were reportedly located in the vicinity of the degreasers, and various solvents were
stored in above-ground storage tanks near the loading dock area. Additionally, MMC used
tetrachloroethcne (also known as tetrachloroethylene, perchloroethylene, or PCE) as early as the
1940s, and used toluene as a solvent in the painting process.
Beginning in 1953, the wash water from the box cleaning operation drained to an on-site septic
system. From 1973 until at least 1978, this wash water was discharged into two wastewater
lagoons constructed at the facility. This wastewater contained water mixed with oil.
A liquid, enamel-based paint was applied to degreased metals in paint booths, and excess paint
was discharged to on-site lagoons located at the rear of the property. Other solvents were used in
the painting process, including toluene as a paint thinner from 1940-1993. Between 1940 and
1973, wastewater from the painting operations drained to the ground along the north side of the
building. From 1973 to 1982, paint waste was drained into the two wastewater lagoons
constructed at the facility. This wastewater was composed of water and residue from the paint
spray operations. After 1982, wastes generated from Merriam's operations were either eliminated
or collected and stored in drums. These drums were then disposed of off-site.
In addition, a number of leaks and spills occurred during MMC operations, including at the
former drum storage area and the loading dock area. In November of 1981, CT DEP discovered
violations of the Resource Conservation and Recovery Act (RCRA) at the MMC facility,
including mislabeled, leaking waste drums, and storage of drums without proper containment.
One hundred improperly labeled containers were stored on asphalt without a berm or drain. Two
drums were leaking, and there was evidence of prior spills.
In March 1998, the bulk of the factory was destroyed by fire, leaving only a small warehouse
building towards the rear of the property.
After the fire, an old underground storage tank used for heating oil was discovered at the
Merriam property. Merriam hired a contractor to pump out the contents of the tank and, in late
1999 and early 2000, Merriam removed the tank and associated contaminated soil pursuant to a
Connecticut Notice of Violation. This work reportedly resulted in the excavation and off-site
disposal of approximately 120 to 130 tons of soil contaminated with oil.
The Durham Manufacturing Company (DMC) was established in 1922 at 201 and 203R Main
Street in Durham, Connecticut. Three main buildings, including an office building and two
manufacturing buildings, are currently located on the property. DMC also manufactures metal
boxes and displays, and has used various solvents during its operations, including TCE (from the
1940s through the present), 1,1,1-TCA (from 1973-1976), and methylene chloride (used from
1976 through the present).
In 1951, DMC installed a 750-gallon settling tank to receive wastewater and paint sludge from
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Durham, Connecticut
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wet paint spray booths and a caustic stripper tank. Approximately 500 gallons per year of sludge
were pumped from the tank. Supernatant in the tank was discharged into an on-site "ditch."
Approximately 1,200 gallons of water per week moved through the settling tank to the "ditch" as
a result of cleaning operations of the wet paint spray booths. In 1974, DMC replaced the 750-
gallon tank with a 5,000-gallon tank, which continued to receive wastewater and sludge from the
wet paint spray booths and caustic stripper. Water was eventually drained into an on-site
leaching field.
From approximately 1974 through 1978, DMC used unlined sludge drying beds in its wastewater
treatment operations. Accumulated paint sludge from the settling tank was directed into one of
two drying beds approximately twice a year. The sludge was dug out of the drying beds by hand
approximately once a year, drummed, and taken to the Durham/Middlefield landfill for disposal.
An on-site aeration pond was constructed in 1960 to receive non-contact cooling water from the
degreasing and spot-welding operations, and storm water from drains located around the parking
lot and roof. In 1982-1983, an aeration system was installed in the pond.
In 1982, solvent usage was approximately 1,000 gallons per month, and the wastewater stream
was approximately 4,000 gallons per month.
Based on analytical data from an extraction well "EX-6" on the DMC property, it appears that a
methylene chloride spill may have occurred in the area sometime in the mid-1990's. Analytical
data provided in a draft work plan for remedial investigation work by DMC's contractor
Leggette, Brashears & Graham (LB&G) indicates that methylene chloride detections in EX-6
increased from 168 parts per billion (ppb, or ug/L) on May 3, 1995, to 2,977,000 ppb on August
15, 1995.
A more detailed description of the Site history can be found in Section 1.0 of the Remedial
Investigation Report.
2. History of Federal and State Investigations and Removal and Remedial Actions
In 1970, a drinking water sample taken from the Frank W. Strong Middle School (Strong
School), located at 191 Main Street, south of and adjacent to the DMC property, was found to
contain PCE and chloroform. Wastewater located in an "open pit" at DMC was observed
approximately 550 feet north of the school's well location, and samples collected from the DMC
pit and from Ball Brook reportedly contained PCE. Chloroform was also detected in an "open
seepage area of discharge" at the rear of MMC and in a ditch leading from the rear of the
property toward Ball Brook.
In 1982, in response to complaints of possibly contaminated drinking water, the Connecticut
Department of Environmental Protection (CT DEP) began testing drinking water wells of
residences near MMC and DMC along Main Street, CT DEP detected VOCs in a number of
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Durham, Connecticut
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wells, including TCE, 1,1,1-TCA, PCE and methylene chloride. A number of wells had
contaminant levels above the Maximum Contaminant Levels (MCLs) set by the federal Safe
Drinking Water Act.
Under CT DEP Water Supply orders, MMC and DMC installed carbon filters on impacted
residential wells. Since then, the two companies have monitored and maintained up to 38 filtered
wells on at least a quarterly basis. Currently, DMC is responsible for servicing 14 of these wells.
MMC was responsible for servicing 24 of these wells, but the company ceased these activities in
late 2004; CT DEP has taken over monitoring and maintenance of these locations.
Regional School District #13 was maintaining and monitoring filters at the Strong School at 191
Main Street in Durham until August 2004, when it connected to a well system at the Coginchaug
Regional High and Korn Elementary Schools (to the east, and not impacted by the Site). The
well located at 191 Main Street has been sealed and can no longer be used.
EPA discovered 1,4-dioxane in 2003-2004 in wells at MMC, DMC, and at a number of
residences. Because this compound is not effectively captured by the current carbon filters, CT
DEP is supplying bottled water for drinking to several affected homes in the northern portion of
the Site, and requires monitoring for this compound at a number of residences throughout the
Site.
EPA's contractor prepared a Removal Program Site Investigation in September 1989, and EPA's
Removal Program performed assessments in July 1990 and July 1992, however, no removal
actions have been conducted at the Site to date.
A brief summary of the federal and state Site investigations and enforcement actions conducted
to date under CERCLA and other environmental authorities is provided below.
Date
Event
October 24, 1972
CT DEP Pollution Abatement Orders No. 1082 and 1083 to MMC
requiring construction of wastewater lagoons. (Modified on May 22,
1973, and again on August 20,1973.)
June 30, 1980
CT DEP Hazardous Materials Management Unit Inspection at DMC.
November 30, 1981
CT DEP Site Investigation at MMC.
February 11, 1982
CT DEP Pollution Abatement Order No. 3209 to DMC, requiring DMC to
perform investigations and propose remedial action for its own facility.
March 2, 1982
CT DEP Complaint Report received regarding MMC.
Early 1982
CT DEP Groundwater Survey at MMC.
July 12, 1982
CT DEP Pollution Abatement Order No. 3299 to MMC, requiring MMC
to perform investigations and propose remedial action for its own facility.
August 24, 1982
EPA and CT DEP follow-up site inspection at MMC.
October 1982
Leggette, Brashears & Graham Groundwater Quality Investigation for
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Durham Meadows Superfund Site
Durham, Connecticut
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DMC reports groundwater contamination on the property.
December 10,1982
CT DEP Water Supply Order No. 3332 to MMC (modifled on October 19,
1983), requiring provision of potable water and monitoring of residences.
December 10, 1982
CT DEP Water Supply Order No. 3334 to DMC (modified on June 1,
1983, June 28,1983, and April 4,1984), requiring provision of potable
water and monitoring of residences.
January 4, 1983
EPA Administrative Compliance Order and Abatement of Penalties to
MMC, ordering compliance with a number of RCRA provisions.
January 1983
Roux Associates, Groundwater Investigation for MMC reports soil and
groundwater contamination on the property.
March 16,1983
EPA Perimeter Survey at DMC.
May 12, 1983
CT DEP Water Supply Order No. 3462 to MMC (modified October 19,
1983).
March 8,1984
CT DEP Water Supply Order No. 3680 to MMC.
March 20, 1984
CT DEP Site Inspection at MMC.
March 20, 1984
CT DEP Preliminary Assessment at MMC.
Midyear, 1984
EPA Site Inspection at MMC.
January 30,1985
EPA Notice of Violation of Consent Agreement and Order to MMC for
delays in constructing site security.
September 25, 1985
EPA Final Site Inspection Report at MMC.
November 13, 1985
EPA Hazard Ranking System Document.
August 10, 1987
Stipulated Judgment entered in Hartford Superior Court requiring MMC
to monitor for VOCs and bacteria, and maintain carbon filtration systems
at designated locations. Penalties to be imposed for any non-compliance.
Docket No. CV83-02S5138S.
September 1988
Roux Associates Site Investigation for MMC, includes installation of
monitoring wells, and provides additional information on groundwater
contamination and potential source areas on the MMC facility.
March 28, 1989
CT DEP Pollution Abatement Order No. 4806 and Water Supply Order
No. 4805 to MMC.
October 4,1989
EPA lists Durham Meadows Superfund Site on the National Priorities
List.
November 22, 1989
CT DEP Consent Order No. 4891 with MMC for supply of potable water
and monitoring at residences.
December 27, 1989
CT DEP fines MMC for failure to submit plan for maintenance and
monitoring carbon filtration systems.
January 22,1990
Roux Associates Phase II Site Investigation for MMC, includes pumping
tests.
June 20, 1990
Roux Associates Addendum to Phase II Site Investigation for MMC.
October?, 1991
Amendment to August 10,1987 Stipulated Judgment, Docket No. CV83-
0285138S.
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Durham, Connecticut
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October 7, 1991
Stipulated Judgment entered in Hartford Superior Court requiring MMC
to comply with Pollution Abatement Orders Nos. 3299 and 4806. Allan
Adams fined $150,000 for non-compliance with these Orders, Docket No.
CV87-0334095.
September 1992
Haley & Aldrich Soil Gas Survey for MMC, identifies areas impacted by
VOCs.
July 1993
CPA's contractor Metcalf & Eddy (M&E) performs surface water &
sediment sampling. Under agreement with EPA, U.S. Geological Survey
(USGS) performs borehole geophysics.
January 10, 1994
Leggette, Brashears & Graham completes Summary of Subsurface
Investigations, Durham Manufacturing Company, Durham, Connecticut
for DMC, reports on soil, groundwater, and soil vapor sampling.
April 1994
EPA's contractor M&E completes Data Summary Report for START
Initiative.
April 1995
Agency for Toxic Substances & Disease Registry health consultation
addressing private well monitoring.
1995
USGS completes Geohydrology and Water Quality of the Durham Center
Area, Durham, Connecticut.
July 7, 1997
EPA and DMC enter into an Administrative Order by Consent for a
Remedial Investigation/Feasibility Study and Other Work at the Durham
Meadows Superfund Site.
September 1997
Leggette, Brashears & Graham submits Draft Work Plan for Conducting
the Remedial Investigation and Feasibility Study, Durham Meadows
Superfund Site, Durham, Connecticut for DMC.
March 1998
The bulk of MMC's facility is destroyed in a fire.
April & October
1998
EPA and DMC contractors and personnel conduct two rounds of sampling
of untreated groundwater in a total of approximately 80 private wells.
November 1998
December 1998
EPA's contractor, Lockheed Martin, conducts additional surface water and
sediment sampling, and other field activities to investigate ecological risk
at the Site.
DMC conducts field investigations on its property.
August 1999
Leggette, Brashears & Graham submits Draft Data Report, Durham
Meadows Superfund Site, Durham, Connecticut for DMC.
September 1999
Agency for Toxic Substances & Disease Registry health consultation
regarding 1998 monitoring results.
May- June 2003
EPA's contractor, M&E, conducts field investigations at the MMC
property.
December 2003 -
June 2004
EPA conducts additional residential well sampling to investigate the
presence of a newly identified contaminant, 1,4-dioxane.
2004
CT DEP requires 1,4-dioxane be added to monitoring for certain homes.
Several homes are provided with bottled water for drinking due to 1,4-
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dioxane movement through existing carbon filters.
2004
MMC ceases monitoring and filtration of affected homes surrounding its
property. CT DEP takes over this work.
2005
Leggette, Brashears & Graham submits Draft Remedial Investigation
Report for DMC.
May 2005
EPA conducts soil vapor and indoor air sampling at a limited number of
homes in the area.
June 2005
EPA finalizes Rl, FS, and Technical Impracticability Evaluation Reports.
3. History of CERCLA Enforcement Activities
EPA began conducting search work for responsible parties in 1990. In 1993, this work was
supplemented with a broader effort to determine if there were other sources of groundwater
contamination beyond the MMC and DMC facilities. In December 1993, EPA sent CERCLA
Section 104 Information Request letters to DMC and MMC. Both facilities responded with
separate submissions in January and February 1994. EPA also sent an Information Request letter
to the Town of Durham regarding past activities at the Strong School property at 191 Main
Street. EPA notified three parties of their potential liability with respect to the Site: the Durham
Manufacturing Company (DMC), Merriam Manufacturing Company (MMC), and Allan E.
Adams (Mr. Adams), as president and owner of MMC.
On September 1, 1995, EPA sent Special Notice letters to the three potentially responsible parties
(PRPs) to commence negotiations regarding the performance of a Remedial Investigation and
Feasibility Study (RI/FS) at the Site. Substantial negotiations occurred with all PRPs, including
the development of a specific technical scope of work for the RI/FS for the Site. In October
1996, MMC and Mr. Adams notified EPA of their inability to continue negotiating based on
certain conditions, and EPA formally ceased negotiations with these parties. EPA continued
negotiating with DMC, and in June 1997, EPA and DMC entered into an Administrative Order
by Consent (AOC) for the RI/FS. The AOC became effective on July 7, 1997. Pursuant to the
AOC, DMC agreed to perform RI/FS work on its own facility and in the southern portion of the
groundwater plume. EPA agreed to perform RI/FS work on the MMC facility and in the
northern portion of the groundwater plume.
In February 2005, EPA took over all remaining work to draft the RI/FS for the entire Site, and
issued Draft Final Risk Assessment, RJ, FS and Technical Impracticability Evaluation Reports on
June 30, 2005. During the public comment period, DMC provided comments on the remedy
selection for this Site, The written comments are included in the Administrative Record.
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C. COMMUNITY PARTICIPATION
Throughout the Site's history, CT DEP has continued to require filtering and monitoring of up to
38 impacted private wells. CT DEP serves as the primary point of contact for these efforts.
Until recently, community concern and involvement regarding EPA efforts at the Site has been
relatively low. EPA kept the community and other interested parties apprised of Site activities
through fact sheets and press releases. Below is a brief chronology of the significant public
outreach efforts.
• In March 1994, EPA held an informational meeting with representatives of the Town of
Durham to discuss the Site.
• In June 1994, EPA established a local public information repository at the Durham
Public Library in Durham.
• In January 1998, EPA released a fact sheet describing the Superfund process and plans
for the Durham Meadows Site.
• In May 2003, EPA released a fact sheet describing investigations to be conducted at the
former location of MMC.
• In March 2004, EPA released a fact sheet regarding 1,4-Dioxane, a newly identified
contaminant discovered in groundwater in certain residential drinking water wells.
• In June 2004, EPA released another fact sheet regarding 1,4-Dioxane, and describing
upcoming plans to sample for this contaminant at approximately 80 residential wells in
the area.
• In April 2005, EPA released a fact sheet describing upcoming efforts to evaluate soil
gas and indoor air at a limited number of locations at the Site.
• On July 1, 2005, EPA sent Draft Final versions of the Remedial Investigation Report,
the Feasibility Study Report, and the Technical Impracticability Evaluation Report to
the public information repository at the Durham Public Library.
• On July 7,2005, EPA issued a press release providing a brief analysis of the Proposed
Plan, and outlining the public comment period schedule.
• On July 7,2005, EPA released a one-page mailing inviting the public to attend the
public information meeting and public hearing on the Proposed Plan.
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• On July 9, 2005, EPA published a public notice and brief analysis of the Proposed Plan
in The Middletown Press and announcing the availability of the plan and supporting
documents beginning July 13 at public information repositories at the Durham Public
Library and at EPA's office in Boston, Massachusetts, The public notice stated that the
Proposed Plan included notice of a technical impracticability waiver for federal and
state requirements that would normally require cleanup of groundwater to meet drinking
water standards. The Proposed Plan also included notice of a potential determination,
and solicited comment on the proposed determination, to minimize destruction, loss or
degradation of wetlands pursuant to Section 404 of the Clean Water Act and Executive
Order 11990 (Protection of Wetlands), should work in wetlands areas be required, as
well as the proposed determination to minimize potential harm and avoid adverse
effects to the floodplain pursuant to Executive Order 11988 (Protection of Floodplains)
should work in floodplain areas be required. Additionally, the Proposed Plan notified
the public of the availability of a Draft Reuse Assessment as part of the Site
Administrative Record, and solicited comments on this document,
• On July 12, 2005, EPA made the Proposed Plan and administrative record available for
public review at EPA's office in Boston and at the Durham Public Library, The
Durham Public Library continues to be the primary information repository for local
residents and will be kept up to date by EPA.
• On July 12, 2005, EPA held a public 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 to a broad community. At this meeting,
representatives from EPA and CT DEP answered questions from the public.
• From July 13,2005 to August 12, 2005, the Agency held a 30 day public comment
period to accept public comment on the alternatives presented in the Feasibility Study
and the Proposed Plan and on any other documents previously released to the public.
• On July 15, 2005, EPA mailed copies of the Proposed Plan to the entire mailing list
(approximately 400 local residents).
• On July 26,2005, EPA issued a press release regarding the upcoming public hearing to
discuss the Proposed Plan and accept any oral comments.
• On July 28, 2005, the Agency held a public hearing to discuss the Proposed Plan and to
accept any oral comments. A transcript of this meeting and the comments and the
Agency's response to comments are included in the Responsiveness Summary,
Appendix D of this Record of Decision,
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D. SCOPE AND ROLE OF RESPONSE ACTION
For purposes of remedial investigations arid remedy selection, the Site is divided into three Study
Areas: the MMC Study Area, the DMC Study Area, and the Site-wide Groundwater Study Area.
The selected remedy was developed by combining components of cleanup for each Study Area to
obtain a comprehensive approach for Site remediation.
In summary, for the MMC Study Area, the remedy provides a combination of soil vapor
extraction and soil excavation and off-site disposal to prevent exposure to contaminated soil and
soil vapor, and institutional controls to prevent any future use of the site that may result in
exposure to contaminants. For the DMC Study Area, the remedy provides for soil excavation
and off-site disposal to prevent exposure to contaminated overburden groundwater and for source
reduction, in conjunction with institutional controls to prevent future exposure by construction
workers or future residents. The remedy provides for the provision of an alternate water supply
to area residents in order to prevent exposure to contaminated groundwater.
It is not technically practicable to clean up the groundwater in overburden or bedrock in a
reasonable timeframe, therefore the remedy provides for monitoring only, with a contingency to
implement an alternative of groundwater extraction for hydraulic containment if it is determined
that the overall plume or source zone is spreading or migrating beyond its current general
boundary. The groundwater portions of the remedy are being implemented in conjunction with a
technical impracticability waiver of the applicable or relevant and appropriate environmental
requirements (ARARs) that would normally require cleanup of the groundwater to meet drinking
water and other standards. Institutional controls are also required to prohibit future use of
groundwater in this area.
Based upon the potential future indoor air risks found at both the MMC and DMC Study Areas,
there is a potential, at other locations, for current or future exposures through volatilization of
organic compounds. During remedial design there will be further delineation of the area posing
potential indoor air risks on or outside of the MMC and DMC Study Areas by further
characterization, including the collection of shallow groundwater data. If there are unacceptable
risks, then further actions will be taken to address such risks, including without limitation, sub-
slab depressurization systems and institutional controls on vacant properties or portions of
properties, in accordance with EPA and CT DEP requirements.
The principal and low-level threats that this ROD addresses are summarized in Table 1.
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E. SITE CHARACTERISTICS
Section 1.0 of the Feasibility Study contains an overview of the Remedial Investigation. The
significant findings of the Remedial Investigation are summarized below.
The Conceptual Site Model (CSM) for soil, groundwater, soil vapor, indoor and outdoor air,
surface water, and sediment at the Site is provided in Figure 1. The CSM is a three-dimensional
"picture" of Site conditions that illustrates contaminant sources, release mechanisms, exposure
pathways, migration routes, and potential human and ecological receptors. It documents current
and potential future Site conditions and shows what is known about human and environmental
exposure through contaminant release and migration to potential receptors. The risk assessment
and response actions for soil, groundwater, and indoor air for the Site are based on this CSM.
1. Site Setting, Geology, and Hydrogeology
The Durham Meadows Superfund Site is located in Durham, Middlesex County, Connecticut
(Figure 2), The Site consists of an area of groundwater contamination (approximately 100 acres)
generally centered along Main Street in Durham and encompassing the DMC and MMC
facilities. The companies' past activities contributed to the contamination at each facility and in
the overall area of groundwater surrounding both facilities. Contamination from VOCs has been
detected in soil and groundwater on both industrial properties, as well as in residential drinking
water wells surrounding the MMC and DMC facilities. The Site is located within a Historic
District, established by a Town Ordinance. [Town of Durham, 2003b].
For purposes of remedial investigation and remedy selection, the Site is divided into three Study
Areas: the MMC Study Area, the DMC Study Area, and the Site-wide Groundwater Study Area.
The MMC Study Area consists of the facility property, and includes the abutting residential
property at 275 Main Street. The DMC Study Area consists of the facility property, excluding
the portion of the property located east of Ball Brook. The Site-wide Groundwater Study Area
consists generally of groundwater in the bedrock aquifer within the limits of the Site, including
the MMC and DMC facilities, as well as residential areas impacted by groundwater
contamination from the source areas. The Site-wide Groundwater Study Area also includes the
Strong School, 168 Main Street, and 174 Main Street, where VOC levels in drinking water wells
are generally higher than in other areas.
The Town of Durham, Connecticut lies within the Connecticut Valley Lowland in south central
Connecticut, Two glacial advances deposited and reworked the overburden till and outwash
deposits found in this region. Bedrock underlying the Study Area is the Jurassic age Portland
Formation, which was deposited in a late Triassic, early Jurassic age rift basin [USGS, 1995].
The Portland Formation has a strike slightly west of north and dips gently eastward at
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approximately 3 degrees at the MMC site and approximately 5 degrees at the DMC site. It is
comprised of well-consolidated sandstone, siltstone, shale, and conglomerate with low primary
(intergranular) porosity and hydraulic conductivity. Secondary porosity and hydraulic
conductivity due to fractures, joints, and separations along bedding planes make the bedrock a
viable aquifer.
This ROD is partitioned between the Study Areas. Previous investigations have included
components of one or more Study Areas, resulting in some overlap in the discussion of each
Study Area. The Study Areas are shown in Figure 2.
MMC Study Area Geology and Hvdrogeoloev
The MMC Study Area includes two parcels, where the former MMC plant was located, and a
third parcel on which the residence at 275 Main Street is located. The three parcels measure
approximately 3.86 acres in total. The MMC Study Area is depicted in Figure 3, which shows
the approximate locations of former and current site features. These site features include the
former and remaining portion of the building, former lagoon areas, a former drum storage area,
former underground storage tanks (USTs), current propane aboveground storage tanks, and
current metal scrap and drum storage areas. Also shown are the locations of former degreascrs
and former paint booths within the facility buildings, a former water supply well (present but not
in use), a former drywell, and a former fuel oil tank within the loading dock area.
The MMC Study Area is relatively level, with a slope to the east that starts approximately 100
feet behind the remaining building and east of Main Street, Overland runoff flows generally to
the east off the sloped area at the rear of the property into the floodplain of Ball Brook. Ball
Brook flows across the property along the northeast corner. This is the closest Ball Brook passes
to the Study Area before flowing further east. The MMC Study Area has no ponds situated
within the property boundary, although vernal pools may exist near Ball Brook, There are no
wetlands on the MMC Study Area.
The MMC Study Area is underlain by one to two feet of fill and 10 to 25 feet of glacial till. This
was determined from soil borings drilled in 2003 by M&E and from borings by Roux Associates
from 1988 to 1990. In the area of the building that partially burned down (leaving only the rear
section intact), the depth of fill is several feet deeper. Soil borings drilled during May and June
of 2003 indicated refusal depths between 11 and 24 feet below ground surface (bgs). Refusal
depths were deeper to the west-northwest and shallower to the east-southeast [M&E, 2005a
Draft Final Rl].
During RI activities in May and June 2003 at MMC Study Area, overburden groundwater was
rarely encountered. In several wells, a perched layer of groundwater was observed locally, but a
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laterally extensive perching layer could not be confirmed [M&E, 2005a], A discussion of
bedrock and bedrock groundwater beneath the MMC Study Area is included within the Site-wide
Groundwater Study Area discussion.
PMC Study Area Geology and Hvdrogeology
The DMC Study Area mainly consists of buildings and asphalt, with some grassy areas along the
northern border and the eastern portion of the property. The DMC Study Area measures
approximately 10.5 acres, and is currently occupied by three main buildings, including an office
building and two manufacturing buildings. Current major property features include septic system
leach fields, a propane tank, a cooling tower, a "burn-off oven," materials towers, degreasers and
an associated degreaser tank, paved parking areas, an aeration pond, and wetland areas (Figure
4). For the purposes of remedial investigations, the DMC Study Area does not include a portion
of the DMC property located east of Ball Brook. This area has not historically been used for
operations or disposal. A portion of the DMC Study Area along Ball Brook is located within the
100-year floodplain. Three production wells are currently used by DMC for withdrawal of
bedrock groundwater [USEPA, 2002a; CTDEP, 2001],
The DMC Study Area is underlain by one to two feet of fill and 10 to 20 feet of low permeability
till over bedrock, as determined from multiple soil borings and monitoring well installations
within the till overburden conducted by Leggette, Brashears, & Graham, Inc (LB&G) [LB&G,
1982; LB&G, 1994]. The DMC Study Area topography slopes somewhat steeply to the east.
Surface drainage on the DMC property is from west to east, draining to Ball Brook [LB&G,
1982]. Overall, there appears to be slightly greater saturated thickness on the eastern portion of
the site, which is both lower in elevation and closer to wetlands. Information on bedrock and
bedrock groundwater beneath the DMC Study Area is included within the Site-wide
Groundwater Study Area discussion.
The DMC Study Area contains one man-made surface water pond (referred to as the "aeration
pond" or "cooling water pond"). The pond is located on the eastern portion of the property
(behind the manufacturing facility). The pond was constructed in 1960 to serve as a holding
pond for cooling water. In 1982/1983 an aeration system was added to the pond. The pond may
also be connected to trench drains (also called curtain drains) on the property. The pond is
currently used to aerate groundwater pumped from DMC Well No. 2. Ball Brook, which lies
approximately 60 feet east of the aeration pond, flows south through the Study Area to Hersig
Brook [USGS, 1995; LB&G, 1999],
Site-wide Groundwater Study Area Geology and Hvdrogeology
The Site-wide Groundwater Study Area is comprised of the groundwater found in the fractured
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bedrock aquifer throughout the Durham Meadows Superfund Site. The area included in the Site-
wide Groundwater Study Area is depicted on Figure 5, which shows residential properties that
have historically been sampled as part of investigation efforts by MMC and DMC,
According to Connecticut groundwater classification maps, the Site is located in type GA
aquifer. Designated uses of GA-classified groundwater aquifers include existing private and
potential public or private supplies of water suitable for drinking without treatment and base flow
for hydraulically connected surface water bodies [CTDEP, 2005a]. Residences and commercial
and manufacturing facilities throughout the Site have individual water supply wells for potable
water and septic systems for waste disposal. There is no public water supply or sanitary sewer
system in the Site-wide Groundwater Study Area. Waste fluids disposed to septic systems may
migrate into the overburden till and the bedrock aquifer.
Three hydrogeologic units can be found near the Study Area; stratified drift (sands/gravels/
fines), till, and sedimentary bedrock belonging to the Portland Formation. Stratified drift
deposits are found in the valleys to the west and east of the Site. These deposits are
predominantly fine-grained glaciolacustrine sediments having low permeability. The glacial till
is also a low permeability unit, which is found overlying the bedrock throughout the Study Area.
The bedrock unit that underlies Durham, Connecticut serves as the main source of water for the
Durham area. It has a low primary porosity (approximately 6%) with little or no hydraulic
conductivity in the rock matrix. The hydraulic conductivity of the till is low, but it is an
important hydrologic unit serving as a conduit between the ground surface and the fractured
bedrock aquifer below. Recharge to all three hydrogeologic units is primarily from precipitation,
approximately 52 inches yearly from a thirty year average (1971-2000) [NOAA, 2002], Annual
recharge to the three hydrogeologic units has been estimated at approximately 23 inches for
stratified drift and 8 inches for the till and bedrock units [USGS, 1995].
The dominant fracture trend in the area strikes northeasterly and the fractures dip steeply toward
the northwest and southeast. Less common, secondary fracture sets were identified striking north
and also east-northeast. Fracture densities in the bedrock at the MMC and DMC Study Areas
were approximately two to four fractures per 100 feet, based upon borehole geophysics
conducted by USGS [USGS, 1995]. However, MMC monitoring wells MW-2 and MW-3
averaged approximately eight to ten fractures within the top 100 feet of bedrock.
The Ball Brook fault, a northeast-striking western-dipping normal fault, cuts directly through the
Site near DMC. USGS geophysical logs indicate that the Ball Brook fault intersects DMC Well
No, 2 at approximately 200 feet bgs [USGS, 1995], DMC Well No. 2 is capable of 100 gpm
pumping rates, probably due to the higher hydraulic conductivity in the fracture zone. However,
anecdotal information suggests that nearby wells ran dry when DMC Well No. 2 was pumped at
100 gpm. The well is currently pumped at approximately 20 gpm.
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2. Nature and Distribution of Contamination
This section describes the nature and distribution of contamination in surface soil, subsurface
soil, soil vapor, overburden groundwater, surface water and sediments, and evidence of a source
of Dense Non-aqueous Phase Liquid (DNAPL), as determined by the RI [M&E, 2005a].
Principal threat wastes are those source materials considered to be highly toxic or highly mobile
which generally cannot be contained in a reliable manner or would present a significant risk to
human health or the environment should exposure occur. The manner in which principal threats
are addressed generally will determine whether the statutory preference for treatment as a
principal element is satisfied. Wastes generally considered to be principal threats are liquid,
mobile and/or highly-toxic source material.
Low-level threat wastes are those source materials that generally can be reliably contained and
that would present only a low risk in the event of exposure. Wastes that generally considered to
be low-level threat wastes include non-mobile contaminated source material of low to moderate
toxicity, surface soil containing chemicals of concern that are relatively immobile in air or
groundwater, low teachability contaminants or low toxicity source material.
A summary of contaminants and their distribution at the Site is provided in Table I.
As discussed in Section 4.0 of the RI report [M&E, 2005a], a method based on converging lines
of evidence was used to assess whether DNAPL is likely to be present in the subsurface within
the MMC, DMC, and Site-wide Groundwater Study Areas. The method of assessment is based
primarily upon an approach outlined by Kueper et al. [Kueper et al, 2003], using criteria
established in the industry for evaluating the presence of DNAPL. DNAPL has not been directly
observed within any of the Study Areas. Soil, soil gas, and groundwater contaminant
concentrations generally do not support a conclusive determination that DNAPL may be present,
with the exception of overburden groundwater at the DMC Study Area, where historic
concentrations are well above the 1% aqueous phase solubility for several chlorinated VOCs.
However, given the complex hydrogeologic environment of the site and other factors such as
deep open hole monitoring wells that may dilute groundwater within these wells, this criterion
has limited applicability. History of solvent usage and plume behavior are more accurate
indicators at this site. Past manufacturing activities included the use of chlorinated solvents that
were likely released to the environment. If released in a pure phase, these solvents tend to sink
into the subsurface as a DNAPL where they spread vertically and horizontally. DNAPL will
reside in unsaturated and saturated media as either residual contamination (discontinuous ganglia
blobs in porous or fractured media) or as pooled DNAPL above fine-grained layers or fractured
media where the entry pressure prevents further migration in the subsurface. Both residual and
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pooled DNAPL will slowly dissolve causing a persistent source of dissolved phase
contamination. Chlorinated solvents including methylene chloride, xylene, (1,1,1-TCA),
trichloroethene (TCE), and tctrachloroethene (PCE) were used in the manufacturing processes
occurring in the MMC and DMC Study Areas during different periods of operation, and are
common sources of DNAPL.
In addition to past solvent use, evidence of the presence of DNAPL within each Study Area
includes the detection of dissolved contaminants in bedrock groundwater contamination over
many years (greater than 30) coupled with the plumes extending from source areas near both
MMC and DMC, The persistence of the bedrock contamination, as well as the continued
presence of groundwater contamination at the source areas, is indicative of a stable source of
contamination such as DNAPL. Further evidence of DNAPL is discussed in the R1 [M&E,
2005a].
Nature and Extent of Contamination at MMC Study Area
Based on historical information, the primary source of contamination is believed to be volatile
organic compounds (VOCs) related to chlorinated solvents released or spilled from MMC
operations, VOCs have been encountered in soil samples and soil vapor samples from several
locations within the MMC Study Area. TCE was detected most frequently and at the highest
concentrations. VOCs were not detected in surface soils at the background sampling locations.
Based on soil vapor surveys, the estimated extent of VOC concentrations (particularly TCE,
PCE, and 1,1,1-TCA) in soil vapor includes the area of the former degreaser, the former loading
dock, and the former drum storage area.
Semi-volatile organic compounds (SVOCs) and extractablc petroleum hydrocarbons were
detected in most surface and subsurface soil samples, with the highest concentrations occurring
in the surface soils. SVOCs were also detected in the background surface soil samples. Metal
concentrations above background levels were detected in all soil samples. Several metals were
also detected in the Synthetic Precipitation Leaching Procedure (SPLP) analysis. Vehicle usage
and paving around the former building, including a portion of the adjacent residential property
that was used for parking, may have contributed incidental concentrations of petroleum-related
compounds. Highly cracked and weathered asphalt is found in the former parking areas. Other
sources of petroleum hydrocarbons and metals in soils may include the building fire which
destroyed the original section of the MMC building and topsoil placed to cover the remnants of
the fire. Residual ash and debris likely related to the building fire and non-native soil fill are
located across the surface of the Study Area.
There is no permanent overburden groundwater table in the MMC Study Area. Chlorinated
volatiles were detected in overburden groundwater samples from the wet meadow east of the
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MMC Study Area in 1988 [Roux, 1990] and likely result from bedrock groundwater discharge.
Bedrock groundwater analytical data collected from wells located within the MMC Study Area
are discussed under the Site-wide Groundwater Study Area.
In 1993, M&E sampled surface water and sediment locations in the vicinity of the MMC and
DMC properties for EPA. Based on these results, EPA developed a supplemental sampling
program and collected additional samples during the RI in 1998. Surface water samples
collected in Ball Brook adjacent to the MMC Study Area contained no VOCs, SVOCs,
pesticides, or polychlorinated biphenyls (PCBs). Metals concentrations were fairly consistent
with results for upstream locations in Ball Brook. Also, the upstream locations contained
concentrations of some VOCs and SVOCs that were not detected in surface water adjacent to the
Study Area, Sediment samples collected in Ball Brook adjacent to the Study Area in 1998
contained several VOCs (mainly chlorinated solvents), SVOCs (mainly polycyclic aromatic
hydrocarbons, or PAHs), pesticides, and metals. Sediment samples collected in 1993 showed
similar results except that no chlorinated VOCs were detected.
Nature and Extent of Contamination at DMC Study Area
Organic compounds, including PCE and TCE, have been detected in surface and subsurface soil
samples around the former solvent storage tank. Soil with non-chlorinated VOC contamination
was also discovered to the east of the main building, and these samples are immediately adjacent
to a groundwater monitoring location with similar contamination. A surface soil sample
contained elevated concentrations of ethylbenzene and total xylene. High concentrations of
ethylbenzene, toluene, total xylene, and MTBE were also detected in the subsurface soil at the
same location. The presence of MTBE and the absence of benzene are hypothesized to be the
presence of degraded gasoline [LB&G, 1999J. However, it has been reported that former tanks
that stored ethylbenzene, toluene, and xylene for use as paint solvents may have been maintained
near this sample location [LB&G, 2005]. SVOC concentrations detected at numerous sampling
locations and are likely due to asphalt mixed into the sample as indicated in the boring logs
[LB&G, 1999]. Low concentrations of metals have been measured in soil samples collected
throughout the DMC Study Area, with the exception of one sample containing an elevated
concentration of arsenic (however the field duplicate sample measured below the detection limit
for arsenic). No SPLP laboratory data for metals is available for DMC Study Area soils.
Contaminants of concern in overburden groundwater at the DMC Study Area include chlorinated
VOCs and, to a lesser extent, BTEX. Chlorinated VOCs detected in groundwater include TCE;
PCE; 1,1,1-TCA; 1,1-DCA; 1,1-dichloroethene (1,1-DCE); 1,2-dichloroethene (1,2-DCE);
methylene chloride; and vinyl chloride. The highest single detection of TCE was in the former
leach field adjacent to the former industrial waste gallery (170,000 ug/L in August 1984).
Overburden groundwater samples from the north driveway area indicate that there may be a
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source area in the vicinity of the former solvent storage area. An additional contaminant source
may be located near the former leach field to the northeast of the main (western) manufacturing
building. The extent of groundwater TCE and PCE contamination includes the north driveway
and the property east of the main (western) manufacturing building. During the most recent
groundwater sampling event (December 1998), the highest concentrations of TCE (66,000 ug/L)
were detected at EX-4, near the solvent storage area, and at WS-10 (4,200 ug/L), less than 100
feet northeast of the aeration pond, with concentrations decreasing toward the center of the
property from these two areas. Overburden groundwater collected east of the main building
(WS-20 in December 1998) contained elevated concentrations of non-chlorinated VOCs,
including ethyl benzene, toluene, and total xylenes. Metals and SVOC concentrations in
overburden groundwater from the DMC Study Area have been generally low.
A soil vapor survey was performed by LB&G as reported in its 1994 report. The soil vapor
survey indicated the presence of VOCs in soil vapors on the DMC property and on two nearby
residential properties to the south, 168 and 174 Main Street [LB&G, 1994],
In 1993, M&E sampled surface water and sediment locations in the vicinity of the MMC and
DMC properties for EPA. Cis-l,2-dichloroethene (cis-l,2-DCE) was detected in the surface
water sample collected from SW/SE-9, a site adjacent to the DMC property. SVOCs, pesticides,
and PCBs were not detected above analytical detection limits. Metals detected were comparable
between a location upstream of the DMC property location and the location adjacent to the DMC
property (i.e., no detection downstream was more than three times the concentration upstream)
[M&E, 1994], VOCs were not detected in sediment samples. The SVOC 4-methylphenol and
the pesticide 4,4-DDE were detected in the sediment sample collected from the location adjacent
to the DMC property. The SVOC and the pesticide were not detected in the upstream sample.
Barium and calcium were detected at location adjacent to the DMC property at concentrations
more than three times the concentrations detected in the upstream sample [M&E, 1994],
Based on these results, EPA developed a supplemental sampling program and collected
additional samples during the RI in 1998. Surface water and sediment samples have been
collected from the aeration pond in 1998 (shown on Figure 4). The TCE concentration in the
pond water was 5 ug/L, and low concentrations of VOCs, SVOCs, and metals were detected in a
sediment sample.
Nature and Extent of Contamination in Site-wide Groundwater
The primary sources of groundwater contamination in the Site-wide Groundwater Study Area
include spills, past waste disposal practices, and other Site activities at the MMC and DMC
facilities. The overburden soils impacted by these facilities are another likely source of
groundwater contamination in the bedrock aquifer, with potential DNAPL areas in the glacial till
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overburden at both the MMC and DMC Study Areas.
Two residential properties that may have been former home-based businesses and the Strong
School have VOC levels in drinking water wells that are generally higher than in other areas.
The interpretation of contaminant sources and migration near these residences, 168 and 174 Main
Street, is unclear. There is some information indicating that both sites were used for home-based
businesses, a solvent drum was reportedly discovered with no further supporting information or
details, and wells are located southwest of the DMC site coincident with the primary fracture
trend and the potential preferential pathway created by Ball Brook. No bedrock monitoring wells
currently exist between DMC, these residences, and/or the Strong School. The historical
influence of pumping at the Strong School may potentially have drawn contamination and
possibly mobilized DNAPL from both the DMC site and the residences at 168 and 174 Main
Street, Therefore, it cannot be unequivocally determined whether the historically high levels of
contamination near 168 and 174 Main Street originate from past uses of the properties, the DMC
site, or a combination of these possibilities.
Anecdotal information gathered by EPA during confidential interviews of former teachers and
students regarding the Strong School, located at 191 Main Street, indicates that an industrial arts
shop and an automotive repair shop were once operated on the property. A school bus
maintenance area was also formerly located at the Strong School property. However, no record
of solvent use or spills was found for the Strong School property. Two leaking underground
storage tanks (USTs) were identified at the Strong School, including 1,000-gallon and 4,000-
gallon USTs formerly used to store petroleum (gasoline) products. The USTs were removed in
August 2002, and monitoring wells were installed to assess impacts from the leaking USTs in
April, 2004 [AEI, 2005],
The Strong School stopped using its water supply well in August 2004 in favor of a hookup to
the District 13 Consolidation well system. This well system consists of two wells located at the
Coginchaug High School and one well located at the Korn Elementary School (well system
license No. CT0380472).
Groundwater data indicate that VOCs, primarily chlorinated solvents, were detected in the
bedrock groundwater within the Site-wide Groundwater Study Area. VOCs detected included
solvents used in the industrial processes at the DMC and MMC properties: PCE, TCE, and 1,1,1-
TCA. TCE was the most prevalent compound detected in the bedrock groundwater in the Study
Area. The highest concentrations were detected at MMC, DMC, the Strong School, and the
residences at 168 Main Street and 174 Main Street. Daughter compounds that likely result from
the degradation of the primary chlorinated solvents were also detected in bedrock groundwater,
including cis-l,2-DCE, trans-1,2-dichIoroethene, 1,1-DCE, 1,1,-DCA, and vinyl chloride.
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Similar to the parent compounds, the highest concentrations of chlorinated daughter compounds
were detected at MMC, DMC, the Strong School, and the residences at 168 Main Street and 174
Main Street, The compound 1,4-dioxane was detected in 21 bedrock wells within the Site-wide
Groundwater Study Area. Detections of 1,4-dioxane are generally coincident with detections of
1,1,1-TCA [Zenker et. al. 2003],
Based on Site data, the plumes follow linear distribution trends of a fractured bedrock aquifer
that generally appear to follow the dominant north-northeast to south-southwest trending
fractures and minor north to south fractures [USGS, 1995]. Two separate plumes are observed
in the Site-wide Groundwater Study Area, one extending south-southwest and south from the
MMC Study Area and one extending south and southwest from the DMC Study Area (Figure 6).
This trend is generally observed for PCE, TCE, cis-l,2-DCE, 1,1,1-TCA, and 1,4-dioxane. TCE
was the most widespread contaminant and was detected at the highest concentration levels of the
contaminants mapped. The MMC and DMC TCE plumes appear not to overlap during the spring
of 1998 but appear to merge and overlap near Maiden Lane during the fall of 1998 (Figure 7),
The highest concentrations of 1,1,1-TCA are south of DMC and trend east-northeast to west-
southwest from the Strong School toward the residences at 168 Main Street and 174 Main Street.
Plume contour maps are presented and discussed in Section 4.0 of the RI [M&E, 2005a].
Concentrations of primary contaminant compounds (PCE, TCE, and 1,1,1-TCA) have been
observed to be declining slightly at the three locations downgradient of MMC Study Area [M&E,
2005a], Daughter compounds resulting from biodegradalion of PCE, TCE, and 1,1,1-TCA (cis-
1,2-DCE; vinyl chloride; 1,1-DCA; chloroethane) suggest that natural attenuation may be
progressing. Contaminant concentrations are relatively persistent at 289 Main Street, directly
north of MMC, providing further evidence that a persistent source is located at the MMC Study
Area.
Below the DMC property, PCE and TCE concentrations are persistent. Daughter compounds
were detected at 205 Main Street, near the northwest corner of the DMC property; however, little
historic daughter compound data was available for DMC Well Nos. 1 and 2. Concentrations of
1,1,1 -TCA appear to be declining near the DMC property; however, 1,1,1 -TCA daughter
compound data is sparse for these wells. PCE and TCE concentrations at the Strong School have
been relatively elevated and persistent. Degradation may be indicated by the presence of
daughter compounds cis-l,2-DCE and vinyl chloride. Septic systems in the area provide
baeteria and nutrients that may assist natural attenuation.
SVOC compounds in the bedrock groundwater were generally detected at low concentrations.
Elevated concentrations of benzo(a)pyrene were noted at 176 Main Street and 268 Main Street,
southwest of MMC. An elevated concentration of pentachlorophenol was noted at 176 Main
Street and the Strong School contained bis(2-ethylhexyl)phtha1ate at an elevated concentration.
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Seven metals (aluminum, arsenic, iron, lead, manganese, magnesium and mercury) have been
detected in bedrock groundwater at elevated concentrations in at least one sample. Sampling for
metals was not conducted comprehensively and samples were collected primarily from
residential wells. Metals detected at elevated concentrations in potential source area locations
were aluminum, iron, and lead in DMC Well No. 2; arsenic, lead, iron, and manganese in the
Strong School well; arsenic in the 168 Main Street well; and arsenic, aluminum, lead, and iron in
the 174 Main Street well.
3. Fate and Transport of Contamination
Chemicals released at the MMC and DMC facilities have migrated to some extent into soil,
groundwater, sediment and surface water. There are several transport pathways and processes
that govern the mobility and fate of these chemicals at the MMC and DMC Study Areas.
Potential migration pathways include volatilizing of contaminants into the vapor phase (soil
vapor), transport of contaminants through the unsaturated zone (pure-phase DNAPL or dissolved
phase in percolating groundwater), transport of contaminants through the saturated zone (pure-
phase DNAPL or dissolved phase in groundwater) and surface runoff or discharge of
contaminated groundwater to nearby surface water and sediments. Groundwater contaminants in
the Site-wide Groundwater Study Area migrate through the Site via volatilization and DNAPL
transport through the unsaturated overburden and/or unsaturated bedrock fractures and migration
of DNAPL or groundwater transport of dissolved contaminants in the saturated overburden
(DMC Study Area only) and into fractures of the saturated bedrock aquifer. At the MMC Study
Area, the saturated zone is located primarily within the bedrock.
MMC Fate and Transport of Contamination
Currently, most areas of concern within the MMC Study Area are not covered with impervious
materials. The ground surface is relatively flat at the MMC Study Area but slopes gently
eastward beginning about 100 feet east of the existing building toward a fresh water wetland that
lies between the MMC facility and Ball Brook. Because of the pervious surface and relatively
flat ground surface, precipitation will percolate vertically through these areas. Within the
unsaturated zone, when percolating water comes into contact with contaminated soils, many of
the chemicals will dissolve and migrate with the water in a dissolved phase through the
unsaturated zone to the saturated zone.
Chlorinated solvents presumably entered the soil at the MMC Study Area in the source areas
described above through spills, leaks, industrial processes, and disposal practices. Chlorinated
VOCs are denser than water and can occur as DNAPL. DNAPL released to the ground tends to
penetrate through the unsaturated zone into the groundwater leaving a path of residual DNAPL
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within the fractured till, pooled on top of fine grained till layers, in depressions on the bedrock
surface and/or in the bedrock fractures. DNAPL in the till migrates primarily through the
interconnected network of fractures and joints. It likely spreads horizontally through the
horizontal and near horizontal fractures and vertically downward through the less frequent
vertical joints. Variations in grain-size and porosity of the till matrix can cause additional
horizontal spreading, diffusion, and/or dissolution of the contaminants as water and DNAPL
migrate through the till. Nearly all the wells in the Site-wide Groundwater Study Area, including
the facility production wells and the residential wells, are deep open-hole wells. Downward
vertical flow of DNAPL is caused by the influence of gravity and the density of the pure phase
chlorinated solvents. Downward flow of DNAPL and dissolved phase contaminants into
bedrock may have been induced by historic pumping at various residential wells and industrial
supply wells through the processes of pool mobilization and/or borehole short-circuiting. (Pool
mobilization and borehole short-circuiting are described in Section L3 of this ROD.)
Adsorption will be the dominant fate mechanism for most PAHs and metals at the Study Area.
PAHs have relatively high organic carbon partition coefficient (K^) values and will adsorb to
organic soil particles and organic matter, and therefore will not migrate appreciably as a
dissolved phase in the unsaturated zone. Adsorption of metals through various processes will
also occur in the unsaturated zone.
The results of soil gas surveys at the MMC Study Area indicate that the high vapor pressure of
the chlorinated compounds caused a vapor plume to develop within the till matrix and fractures.
Water migrating through the unsaturated zone can be contaminated by the vapor plume and/or
residual DNAPL in the fractures, thereby spreading the zone of contamination. The till is
generally unsaturated at the MMC Study Area, but contaminants migrating through the till may
diffuse into discontinuous or seasonal water zones providing an ongoing source of
contamination. Seasonal fluctuations in the water table can sometimes saturate the till
immediately above the bedrock surface, thereby providing additional dissolution and dispersion
of residual DNAPL.
Overland flow (runoff) and groundwater from the MMC Study Area likely discharges to the wet
meadow. The wet meadow then drains into Ball Brook. The data collected in 1993 and 1998 do
not indicate that Study Area contaminants have migrated to surface water. Major metal ions and
heavy metals occur naturally in surface water and, as indicated above, metals concentrations were
similar upstream and adjacent to the Study Area.
Sediment samples were collected upstream of and adjacent to the MMC Study Area in 1993 and
1998. Sediment samples collected in 1998 contained several VOCs (mainly chlorinated
solvents), SVOCs (mainly PAHs), pesticides, and metals. The 1993 sediment samples showed
similar results except that no chlorinated VOCs were detected. The two VOCs (2-butanone and
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toluene) that were detected in 1993 were also detected in an upstream sediment sample (SE-1).
SVOCs, pesticides, PCBs, and metals were also detected in the upstream sediment locations.
While it appears that many of the detected contaminants could be attributed to upstream sources,
the presence of several chlorinated solvents in 1998 sediment samples could likely be attributed
to transport from the MMC facility. Sediment transport occurs though overland flow (runoff),
scouring, and re-suspension in flowing surface water bodies.
PMC Fate and Transport of Contamination
The DMC Study Area is largely covered with impervious material (building footprints,
pavement). The unsaturated zone at the DMC Study Area consists of a layer of porous, disturbed
fill that is approximately 3 feet thick. Below the unsaturated zone is a layer of lodgment till that
extends to bedrock surface. The water table is contained within this till layer. Transport through
the saturated till layer is described below.
Chlorinated VOCs and BTEX compounds are the primary contaminants at the DMC Study Area.
Chlorinated VOCs are denser than water and can occur as DNAPL. BTEX compounds are
indicative of petroleum-related contamination. .
Chlorinated solvents likely entered the soil at the DMC Study Area in the source areas described
above through spills, leaks, industrial processes, and disposal practices. The source and extent of
BTEX compounds, identified by LB&G east of the main building (in the vicinity of soil boring
B5), have not been identified to date. Since a large portion of the DMC property is covered with
impervious material, it is likely that the BTEX contamination will infiltrate the porous media and
move downward to the water table with gravity. The contaminants will either dissolve or, if
present as LNAPL, may float and move with the rise and fall of the water table.
Below the unsaturated zone is a layer of lodgment till that extends to bedrock surface. The water
table is found within this layer and can fluctuate several feet due to seasonal wet and dry cycles.
The USGS reports that this till is likely fractured with horizontal to near horizontal fractures
connected by less frequent vertical joints. DNAPL migrating through the unsaturated till enters
the saturated till. Migration into and through the saturated till is affected by gravity, capillary
pressure, interfacial tension, and interconnectivity of the fractures. In order for DNAPL to
migrate into fractures and/or pores within the till, it must overcome the entry pressure in the
saturated medium. Narrow fractures or smaller pores will generally have higher entry pressures
than wide fractures or large pores. DNAPL may pool until the vertical extent exceeds the entry
pressure for the fractures, and then migrate downward, or it can spread horizontally until wider
fractures or pores are encountered before downward migration occurs.
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Dissolution can reduce the volume of the DNAPL as it migrates through the saturated zone.
Pooled or residual DNAPL may settle into dead-end fractures or zones where further migration is
prevented. This DNAPL can provide an ongoing source of dissolved phase contamination via
dissolution which can continue for many years. Dissolved phase contamination can diffuse into
the matrix porosity of the till or rock when contaminant levels in the fractures are relatively high,
then re-diffuse from the matrix back into the saturated fracture at a later time, prolonging natural
attenuation or clean-up attempts.
Downward vertical flow of DNAPL is caused by the influence of gravity and the density of the
pure phase chlorinated solvents. Downward flow of DNAPL and dissolved phase contaminants
may also be induced by pumping in DMC water supply wells located in the vicinity of suspected
source areas through the processes of pool mobilization and/or borehole short-circuiting. Water
withdrawal rates of 50 to 60 gpm were historically reported for cooling water supply from DMC
Well No, 2. DMC Well No. 1, located near the former solvent storage area, is used as the
potable water supply well for the facility. DMC Well No. 3, located near the former waste
disposal areas, is reportedly used for quench water to cool the ovens used for baking paint on the
metal boxes and other products. Drawdown that is induced during pumping creates a downward
hydraulic gradient near these wells and lowers the entry pressure for DNAPL. All three DMC
wells are located near contaminant source areas or where significant contaminant concentrations
were detected in the overburden.
Shallow groundwater in the saturated till at DMC flows eastward toward the wetlands and Ball
Brook. Dissolved phase contaminants are transported downgradient, mainly through the
fractures in the till, and eastward toward Ball Brook. Some eastward groundwater flow exists
within the till matrix but the intergranular hydraulic conductivity is low. Therefore, the majority
of groundwater flow is attributed to near horizontal interconnected fractures. The intergranular
porosity of the till reported by USGS was 21 to 32 percent, indicating that significant
contaminant diffusion into the till matrix is likely.
In November 1998, fieldwork was conducted at the Durham Meadows Superfund Site as part of
an EPA Screening-Level Ecological Risk Assessment (SLERA). Soil, surface water, and
sediment samples were collected [USEPA, 2005, Final Screening-Level Ecological Risk
Assessment], Surface water was sampled at four locations in the vicinity of the DMC facility
including PND ("cooling water pond", also known as the aeration pond), BB1 (downstream of
DMC), BB2 (embayment of Ball Brook) and BB3 (upstream of DMC). The only VOCs detected
in sample BB2 consisted of 1,1,1-TCA, 1,2-DCE, and TCE. TCE and 1,2-DCE were also
detected in the sample from the cooling water pond (PND). The SVOCs diethylphthalate and
dimethylphthalate were detected in the cooling water pond sample. No SVOCs were detected at
locations BB1, BB2, or BB3. No pesticides or PCBs were detected in any of the four surface
water sample locations. In general, metal concentrations were similar for samples collected in the
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cooling water pond (PND) and adjacent to the DMC facility (BB2), but noticeably higher than
those measured in the samples upstream and downstream of BB2.
It is likely that VOCs (1,1, MCA, 1,2-DCE, and TCE) are migrating to surface water at location
BB2. This migration could be due either to overland flow (runoff) or from groundwater
discharge to the vicinity of location BB2; however, concentrations of these chemicals in
overburden groundwater in the vicinity of BB2 are also elevated, indicating that surface water
may be impacted by groundwater discharge.
In 1998, sediments were sampled at four locations in the vicinity of the DMC facility including
PND ("cooling water pond", also known as the aeration pond), BB1 (downstream of DMC), BB2
(embayment of Ball Brook) and BB3 (upstream of DMC). Analytical results indicated the
presence of VOCs in the sample collected from the on-site cooling water pond. VOCs detected
in the cooling water pond sample included PCE, TCE, 1,1,1-TCA, 1,1-DCE, and 1,2-DCE.
Methylene chloride and trichlorofluoromethane were detected in upstream sample BB3. Vinyl
chloride and 1,2-DCE were detected in sample BB2, collected adjacent to the DMC facility. No
VOCs were detected in downstream sample BB1 [USEPA, 2005], Numerous SVOCs were
detected in all four samples collected. No pesticides or PCBs were detected in any of the four
sediment samples. Metals concentrations in sediment (barium, copper, nickel, magnesium, zinc)
tended to be higher at location BB2, adjacent to the DMC facility. It is likely that VOCs (1,2-
DCE and vinyl chloride) are migrating to sediments in the vicinity of sample location BB2. It is
unknown if the migration is due to overland flow (runoff) and deposition of contaminants or
from groundwater discharge and deposition of contaminants.
Site-wide Groundwater Fate and Transport of Contamination
Releases of chemicals to the environment have occurred within the Durham Meadows Superfund
Site. These contaminants have migrated into the soil, overburden groundwater, and the bedrock
aquifer. There are several transport pathways and processes that govern the mobility and fate of
chemicals in Site-wide Groundwater Study Area.
Potential migration pathways include volatilization and transport of free-phase contaminants
through the unsaturated overburden and/or unsaturated bedrock fractures and migration of free-
phase or groundwater transport of dissolved contaminants in the fractures of the saturated
bedrock aquifer. Along these migration pathways, several processes may occur that can affect
the extent to which chemicals will migrate. These processes involve physical mechanisms and
chemical reactions between the chemical and environmental media that will act to promote or
attenuate chemical migration.
Bedrock groundwater in the MMC Study Area within the fractured bedrock aquifer flows
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through fracture openings, that are generally small in size (tens of microns); and account for less
than 1% of the bulk volume of rock. Fractures in most natural settings have preferred
orientations. The intersections of the fractures create the geometric network of the fracture
system. The direction of groundwater flow and contaminant transport in fracture systems is
dependent upon the orientation and connectivity of the network.
Contaminants near MMC migrate through the thin mantle of fractured till into the bedrock
fractures. The patterns evident in the contaminant plume maps (Figures 4.3-11 through 4.3-18 in
the RI [M&E, 2005a]) indicate that contamination is migrating toward the south-southwest along
the primary fracture direction reported by USGS, then southward coincident with one of the
minor fracture directions (USGS, 1995].
Concentration versus distance cross-sections and the plume maps indicate that the plume is still
attached to the potential source area (Figures 4.3-19 through 4.3-21 and 4.3-11 through 4.3-18 in
the RI [M&E, 2005a]). The majority of bedrock water supply wells in the MMC area are located
southwest of MMC and there are few wells located toward the east. It appears that dissolved
phase contamination may be influenced by pumping of the numerous water supply wells
southwest of MMC as well as by the direction of fractures and joints. The diffusion or re-
diffusion (called back-diffusion) of dissolved phase contamination into/from the fractures and
micro-fractures is possible where matrix porosity and/or microfractures exist along the fracture
faces. Operation of the on-site water supply wells likely created a downward vertical gradient in
the well's area of influence. This downward gradient could cause the downward migration of
DNAPL and/or dissolved phase contaminants faster and to a greater extent than would normally
be expected under non-pumping conditions.
The long open-hole sections of bedrock water supply wells and the monitoring wells at MMC
may have promoted the vertical migration of contamination in the bedrock aquifer as a result of
borehole short-circuiting. Geophysical data reported by the USGS indicates that both downward
and upward vertical flow exists within the wells tested. Vertical flow may vary in time, rate, and
direction depending upon pumping in nearby water supply wells. This further serves to
complicate the interpretation of contaminant migration, promotes mixing of dissolved phase
contamination between fracture sets, and allows downward migration of DNAPL where DNAPL
is present.
If DNAPL is present above or within fractured bedrock, it has the potential to migrate laterally
from the source area as well as downward. The reason for this migration is that little dilution
will occur within the fractures. The depth of DNAPL penetration within fractured bedrock will
depend upon the fracture aperture width, entry pressure, dip of the fractures, DNAPL volume,
and density. Penetration depth is very difficult to predict even in the most characterized bedrock
settings [Pankow and Cherry, 1996], The steeply dipping fractures in bedrock at the Site can
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serve as migration pathways for DNAPL that enters the bedrock fracture network. Based upon
the connection of fractures with long open-hole bedrock sections in the on-site wells near the
source areas, it appears that on-site monitoring wells and the on-site water supply well may also
provide pathways for the downward migration of DNAPL. Pumping in nearby off-site water
supply wells likely lowers entry pressures in connected fractures thus mobilizing DNAPL and
allowing it to enter on-site wells near the source areas and allowing it to cascade downward to
the bottom of the on-site water supply well and source area monitoring wells. Over time, pooled
DNAPL will reach an equilibrium depth and will not continue to be mobile unless pumping rates
are increased, thus decreasing the entry pressure even further.
The direction and physical processes of contaminant migration near DMC are similar in most
respects to MMC with contaminants migrating through the fractured till into the bedrock fracture
network. Extensive areas of overburden contamination at DMC near the former solvent tanks,
degreasers, and waste disposal areas provide a persistent source for contaminant migration into
the bedrock fractures. Steeply dipping fractures and long open-hole bedrock sections in the local
water supply wells contribute to the vertical migration of contamination and mixing within the
fracture networks intersected by the wells. These wells are likely a critical factor in the spread of
contamination from DMC where DMC Well Nos. 1,2, and 3 are 750, 400, and 340 feet deep
respectively with open-hole sections of 666, 375, and 259 feet. The presence of these open-hole
bedrock wells and the high dip angle of the bedrock fractures likely promote the downward
migration of DNAPL and mixing of dissolved phase contamination throughout the bedrock
aquifer.
The bedrock groundwater plume maps for DMC illustrate south and southwesterly contaminant
migration, coincident with the major and minor fracture orientation. However, additional
analysis indicates the potential for influence due to pumping and/or other possible contaminant
sources that further complicate the interpretation of the data.
The USGS reported that groundwater flow in the DMC Study Area is controlled by bedrock
structural features and affected by groundwater withdrawals from wells. The southwestern and
southern contaminant trends coincide with reported fracture trends, but there are several water
supply wells operating in the DMC area with relatively high capacities compared to the local
residential wells. Two of the DMC supply wells and the Strong School well (when it was
operating) likely pulled DNAPL and dissolved phase contamination through fractures and joints
from different directions than normally would be expected. DMC Well No. 2 operates
continuously at approximately 20 gpm for source control, and DMC Well No. 1 is used as a
drinking water supply well, after the water is treated [LB&G, 2005].
DMC Well Nos. 1 and 2 are located along the Ball Brook fault. The results of the USGS
borehole geophysical program indicate that DMC Well No, 2 intersects the Ball Brook fault at
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approximately 200 feet below ground surface. It is likely that DMC Well No. 1 also intersects
the fault, but the well was not logged or tested. Contaminant levels in DMC Well Nos. 1 and 2
are lower than expected, possibly due to less contaminated groundwater being drawn along the
fault zone and through interconnected fractures toward DMC due to the constant pumping of
DMC Well No. 2. Aquifer test results indicate that DMC Well No. 2 potentially had an area of
influence greater than 700 feet northeast and approximately 500 feet toward the south at pumping
rate of 100 gpm for a period of 5 hours [LB&G, 1982],
The persistence of contamination in groundwater samples collected from the residential water
supply wells indicates that DNAPL may potentially be present nearby. Although these wells
likely pump at low rates (probably 2 gpm or less) drawdown in the wells could be significant,
depending upon the hydraulic conductivity of the interconnected fracture network. This could
lower the entry pressure for fractures intersecting the well and/or affect the hydraulic pressure
gradient thereby mobilizing pooled DNAPL. Mobilized DNAPL could potentially migrate from
the DMC source areas toward these residential wells through dipping or plunging fractures.
Based upon the anecdotal evidence of solvent stored in a dirt-floor basement, and the results of
the soil gas survey conducted by LB&G, it is also possible that chlorinated solvents may have
been released and DNAPL may have entered the bedrock near these sites. Potential dissolution
of residual DNAPL could have resulted in diffusion of contamination into the bedrock matrix.
Contaminant levels at the Strong School are higher relative to the DMC supply wells which is
likely due to dissolved phase contamination being drawn through the north-northeast to south-
southwest and north to south trending fractures from DMC by extended periods of pumping.
Although records were not available for the Strong School well, groundwater withdrawals were
likely more frequent and at a significantly higher pumping rate than nearby residential wells. The
Strong School well is 386 feet deep with 259 feet of bedrock open-hole. Pumping at the Strong
School also potentially lowered the water levels in nearby fractures, likely resulting in significant
drawdown in this fractured bedrock aquifer. Lowering the water levels in fractures could have
potentially changed the hydraulic pressure gradient in the area, allowing pooled DNAPL to
migrate and/or lower entry pressures for DNAPL to enter bedrock fractures. DNAPL could have
migrated along south or southwesterly dipping fractures from DMC toward the Strong School
Potential dissolution of DNAPL and/or residual DNAPL may have resulted in diffusion of
dissolved phase contamination into the bedrock matrix via intergranular porosity and/or
microfractures. Given the available data, it is possible that contamination detected in the Strong
School well is drawn from both the DMC site and the area near 168 and 174 Main Street by
extended and relatively high-rate pumping of the Strong School water supply well.
The Strong School stopped using its water supply well (191 Main Street) in August 2004 in favor
of a hookup to the District 13 Consolidation well system. This well system consists of two wells
located at the Coginchaug High School and one well located at the Kora Elementary School
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(well system license No. CT03S0472).
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
The area surrounding the Site is primarily residential, and includes local businesses, school
buildings, churches and light industry. The area along Main Street, which includes both the
MMC and DMC properties, is zoned for residential use within 150 feet of the street and
residential/farm use beyond 150 feet. Permitted uses within the Main Street Residential and
Farm Residential districts are specified in the Town of Durham, Connecticut Zoning Regulations
(As Amended to June 1, 2003), Section 05,01 [Town of Durham, 2003a]. The schedule shows
uses permitted by right, uses permitted as a special exemption, uses permitted by right subject to
a site plan review, and uses not permitted.
Neither MMC nor DMC conform to the zoning requirements of the district in which they arc
located, but are protected in the zoning regulations as long established businesses. The zoning
regulations also allow for expansion of non-conforming manufacturing establishments to not
over 150% of the area occupied at the time of the enactment of the regulations. The regulations
further specify conditions under which non-conforming use can be changed or terminated.
Termination of a non-conforming use occurs only upon voluntary discontinuance or
abandonment by the property owner as specified in the regulations.
This section focuses mainly on the MMC and DMC Study Areas, where the most significant
cleanup activities will occur. It should be noted that the federal government does not have an
ownership interest in the MMC and DMC parcels,
DMC Study Area
DMC is located at 201 Main Street and 203R Main Street. DMC currently owns three separate
parcels totaling approximately 25 acres. The parcel that fronts on Main Street, which houses the
original building, is 3.6 acres. A larger parcel to the east is 14.5 acres, and is bisected by Ball
Brook; DMC has expanded operations onto the westerly portion of this second parcel. The most
easterly parcel is 7,1 acres and is currently undeveloped. The DMC Study Area, where Superfund
investigations and sampling have occurred, measures approximately 10.5 acres.
The parcels are located in an area of mixed use that includes residential, commercial and
industrial applications. The surrounding parcels on Main Street are mainly residential homes.
The Strong School, at 191 Main Street, and an athletic field are located immediately to the south.
The Coginchaug High School and the Korn Elementary School are located to the east of DMC,
and are not impacted by the Site.
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DMC has been in business at this location since 1922, and has expanded its manufacturing
operations several times in the last decade. On June 27,2003, a newspaper article in the Town
Times, reported that DMC considered expansion into undeveloped portions of land at the rear of
the property (to the east of the site and across Ball Brook) but that expansion considerations are
now on hold. No Superfund sampling or investigations have occurred east of Ball Brook.
Superfund interest is focused mainly on the parcels west of Ball Brook.
The property is currently zoned residential within 150 feet of Main Street, and residential/farm
beyond 150 feet. The original structure was built prior to the implementation of zoning
regulations, and the Town of Durham reports that DMC has maximized all available expansion
potential on the Main Street parcel.
A single, one-story brick manufacturing building and paved parking area occupies the majority of
the parcel. A large steel-sided warehouse-style building was added to the facility in the early
1990's, between the original building and Ball Brook to the east. There is a portion of this parcel
that is subject to wetlands regulation, and identified in the Town of Durham's Plan of
Conservation and Development [Town of Durham, 2003b]. Nearly all of the area on this parcel
has been covered by the DMC building and associated parking areas. The parking lot ends at a
steep slope leading to a small, unlined cooling pond, which is separated from Ball Brook by a
low earthen ridge. Access is available from Main Street.
The parcel across Ball Brook was previously used as a tree farm. This parcel is owned by DMC
and may be available for expansion.
No significant soil cleanup has occurred yet under the Superfund program or state order. Most
areas of soil contamination are located towards the front (western end) of the parcel. Overburden
(shallow) groundwater on this parcel is contaminated, and there are a number of monitoring wells
on this property. A multiphase extraction system was reported to have been operated in the mid-
1990's however, data on the effectiveness of the system was not provided to EPA.
Current Uses; The parcels west of Ball Brook are actively used by DMC for its production
operations.
Potential Future Uses: It is expected that the property associated with the Superfund Site will
continue being used for its current purpose. Since the company has reportedly maximized its
expansion potential on such property, it is reasonable to assume that no further expansion or
construction (industrial, commercial, or residential) will occur west of Ball Brook.
It is also assumed that DMC will continue to operate its business at this location. The owner has
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not indicated any plans to sell or relocate, and the Town has not expressed any interest in
acquiring the property. The Town has not reported any delinquency on DMC's property taxes.
Further, the current use appears to be compatible with the Town's Master Plan and no zoning
changes involving this area are currently anticipated.
Potential Use/Reuse Considerations: DMC is likely to continue its manufacturing use for the
foreseeable future. The parcel is zoned in such a way that it could, however, revert back to
residential use. Potential future residential use of this property was therefore considered in the
RI/FS and the human health risk assessment as a conservative, worst-case scenario with respect
to exposure,
MMC Study Area
MMC was located at 281 Main Street until most of the building burned down in 1998. MMC
and affiliated businesses have relocated to and continue manufacturing operations at another
facility located outside of the Site boundaries in Middletown, Connecticut. A small warehouse-
style portion of the original building still stands at the rear of the property, east of Main Street.
This building is in fair condition and has been leased to Continental Fabrication, a small-sized
manufacturer of metal parts. Most debris from the original building foundation was cleared,
although pavement debris was found during soil sampling activities in 2003. Most debris was
located in the former loading dock area and near the driveway.
The property is currently zoned residential within 150 feet of Main Street, and residential/farm
beyond 150 feet. The original structure was built prior to the implementation of zoning
regulations, and the Town of Durham reports that, before the 1998 fire, MMC had maximized all
available expansion potential.
The parcels on which MMC were located are owned by the Estate of Mr. Allan Adams, the
former owner and president of MMC. The surrounding parcels on Main Street, including
immediate neighbors, are residential homes. The residence at 289 Main Street, just to the north
of the Merriam property, is located extremely close to the property line and former location of the
factory building. The residence at 275 Main Street is located on a separate parcel, also owned by
the Estate of Mr. Adams. Throughout its historical operations, the demarcation between the 275
Main Street and 281 Main Street parcels has not always been clear; it appears from historical
photos that limited site operations and/or employee parking at MMC may have occurred on the
rear portion of the 275 Main Street parcel, behind the existing residential home.
MMC was located on and conducted most operations on two parcels, measuring 1.03 acres and
2.37 acres. The residence at 275 Main Street is located on a parcel measuring 0.46 acres. The
MMC Study Area includes all three parcels, measuring approximately 3,86 acres.
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East of the remaining building is a downward drop in elevation to a fairly extensive wet meadow
that leads to Ball Brook, A drainage swale begins on the southern edge of the property, and turns
to the north behind the former lagoon, eventually widening at, and discharging to, the wet
meadow. This area appears to be a seasonally saturated wet meadow; standing water has been
observed in the wet meadow during the spring.
EPA installed a six-foot high chain-link fence around the front portion of the property in May
2003, The fence is likely to remain in place for the foreseeable future, probably until most
cleanup activities have been completed. Continental Fabrication keeps a gate open to the
property during business hours.
While MMC has conducted a number of onsite investigations under state order, no significant
soil cleanup has occurred under the Superfund program or state order, other than the removal of
an underground storage tank for fuel oil and associated contaminated soil in 1999. The tank was
discovered during debris removal after the bulk of the building burned in 1998.
Most areas of documented soil contamination are in the former locations of the loading dock,
drum storage area, and lagoons. An additional area of soil and soil gas contamination is located
centrally on the property, within the former building footprint, on or around the former location
of degreasers. Other small areas of soil and/or soil gas contamination are located throughout the
front portion of the property, in and around the former building footprint, and at the rear of the
275 Main Street parcel
Groundwater beneath the parcel is contaminated with VOCs. There are currently five bedrock
monitoring wells onsite. MW-4, located east of the private residence at 275 Main Street, was
converted to a supply well after the 1998 fire destroyed the original MMC supply well.
Underground piping runs between MW-4 and the 275 Main Street residence. Piping also runs
between MW-4 and the existing onsite building. Existing monitoring wells must remain in place
for ongoing collection of data.
Current Uses: Continental Fabrication is the only active use of the MMC property; the 275
Main Street residence is rented out as two separate apartments, and both apartments have tenants.
Potential Future Uses: There is considerable uncertainty regarding the future reuse of this parcel.
With the exception of the Continental Fabrication facility, the remainder of the property has been
unused since the main building was destroyed by fire in 199S. In the past, the parcel was
privately owned, and the owner did not develop any plans to reuse the property. Town Officials
had expressed interest in the past for using this property for potential municipal-related uses,
including the possibility of elderly housing or a community/senior center, or maintaining the tax
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base by allowing rebuilding of another light industry or office/commercial building. While the
community had not been extensively surveyed regarding its opinion on these matters, some local
residents expressed a preference that the property not be reused for industrial purposes.
Under the existing zoning, residential homes could also be built on the property. If this were to
occur, future use of the property would then default to the area's residential and residential/farm
existing zoning, and industrial/commercial use would be prohibited.
Given this uncertainty, there was a range of reasonably anticipated future land uses due to current
zoning regulations. The Feasibility Study considered this range during the development of
remedial action cleanup objectives for the MMC Study Area [M&E, 2005b, Draft Final FS].
Potential future residential use of this property was considered in the FS and the human health
risk assessment as the most conservative assumption with respect to exposure, however, and the
remedy is tailored for potential future residential use.
Resolution of Site liabilities, and the recent death of the property owner, are major complications
for reuse of this property, as described below.
Potential Use/Reuse Considerations: The most significant complicating factor in potential reuse
of this parcel comes with the passing of Mr. Allan Adams in October 2004. The Town of
Durham received notice from the Probate Court in early July 2005 of a hearing date for the
reading of Mr. Adams' will. The will states that Mr. Adams bequeathed the 281 Main Street
parcel to the Town of Durham for use as elderly housing. The Town was reportedly required to
officially accept the gift or disclaim it by July 19, 2005, nine months from the date of death.
Given the late notice, and the Town's resulting inability to fully investigate the property and
satisfy the Town Charter requirements for town meeting approval of land acquisitions to be used
for town purposes, the Town of Durham elected to disclaim the property.
As of September 2005, the property remains in Probate Court and its disposition is unclear.
In early 2005, EPA noticed the Estate of Mr. Allan Adams of its potential liability at the Site.
EPA filed a lien against the MMC factory property at 281 Main Street, Durham, on August 27,
1997; the lien was filed with the Town of Durham at Volume 154, Page 784.
While EPA did file a lien against the MMC property, the federal government does not have an
ownership interest in this parcel.
Numerous other factors that may affect potential reuse of the site are related to the need for
cleanup of the parcel and the timeframe for any such cleanup activity. The cleanup remedy will
include restrictions on groundwater use, and potentially land use. There may be restrictions on
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areas of the site that could be graded to accommodate reuse. Reuse must accommodate existing
and any future monitoring wells, as well as any remaining longer-term cleanup structures (e.g.,
soil vapor extraction system). The impacts of ongoing cleanup activities (such as truck traffic,
noise, dust, etc.) may also affect the timing of reuse, although the legal disposition of the
property is likely to play a larger part in determining when this property can be reused. Town
Officials had also noted that another limiting factor may be the need to construct a new septic
system on the property; the wetland area behind the remaining building onsite may also be a
limiting factor in this regard.
Site-wide Groundwater Study Area
The aquifer is currently used as a source of drinking water. In 1982, after contamination was
discovered in private drinking water wells, under a CT DEP order, MMC and DMC installed
carbon filters on impacted residential wells. Since then, the two companies have monitored and
maintained up to 38 filtered wells on at least a quarterly basis. DMC is responsible for servicing
14 of these wells. MMC is responsible for servicing 24 of these wells, but ceased these activities
in late 2004; CT DEP has taken over monitoring and maintenance of these locations.
Regional School District #13 was maintaining and monitoring filters at the Strong School at 191
Main Street in Durham until August 2004, when it connected to a well system at the Coginchaug
Regional High and Korn Elementary Schools (to the east, and not impacted by the Site), The
well located at 191 Main Street has been sealed and can no longer be used.
EPA discovered 1,4-dioxane in 2003-2004 in wells at MMC, DMC, and at a number of
residences. Because this compound is not effectively captured by the current carbon filters, CT
DEP is supplying bottled water for drinking to several affected homes in the northern portion of
the Site, and requires monitoring for this compound at a number of residences throughout the
Site.
The groundwater at the Site is currently classified by the State of Connecticut as "GA" (suitable
for drinking without treatment) or "GA*" (not currently drinkable without treatment but targeted
to be restored to GA standards in the future). The overburden and bedrock aquifers in the study
area, however, have limited productivity and are not expected to yield sustainable, significant
quantities of water for use as a public drinking water resource.
There is currently no source of public water in the area of the Site. The Durham Center Division
of the Durham Public Water System is located to the south of the Site, and serves approximately
35 locations along Cherry Lane, Fowler Avenue and Main Street. The system uses two wells,
with a combined estimated yield of 15 gallons per minute. This system was previously owned
and operated by the Eastern Connecticut Regional Water Company; the Town of Durham
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obtained the exclusive water service area and purchased this system in 2002, The Town of
Durham is currently making repairs and improvements to the system. As of September 2005, the
Town of Durham, in conjunction with the Connecticut Department of Public Health, is
investigating the potential use of the Durham Fairgrounds Wells for a future source of water to
the Durham Center System, These wells are located southwest of the Site, and have been
suggested as another potential source of water to serve affected private wells at the Site.
Preliminary results of a recent 72 hour pump test for simultaneous operation of the two
Fairgrounds wells exhibited a capacity of approximately 170 gallons per minute (verbal
communication between Martin Beskind of CT DEP and William Milardo, Local Health Officer,
Town of Durham, September 8,2005). The test was conducted for the Town of Durham in July
2005; results are to be confirmed in a report to be provided to the Town of Durham.
There are several other areas surrounding the Superfund Site where chemical contaminants
render the groundwater unsuitable for drinking without treatment. To the north of the Site is a
smaller area of contaminated groundwater in the vicinity of Main Street and Marina Place where
several private wells are contaminated with gasoline constituents released by former service
stations located on Main Street. Another area of gasoline-related contamination exists north of
the Site on Main Street near the former Dairy Mart. Solvent contamination has impacted
approximately six private wells near the intersection of Maple Avenue and Middlefield Road, the
source of which is not currently known. An area of groundwater contamination exists near the
former landfill that straddles the border of the Towns of Durham and Middlefield. Last, one well
along Maiden Lane, east of the Site, is contaminated with gasoline-related substances from a spill
on a nearby farm.
No public sewers are located near the Site; area homes and businesses use septic systems.
The current use of surface water at the Site is for recreation only (e.g., wading), although Ball
Brook is not of a size to support recreational uses such as boating, or sustenance fishing.
Stakeholder input on current and potential future Site and resource uses were obtained through
meetings with representatives of the Town of Durham and the Mid-State Regional Planning
Agency. CT DEP issued the Ground Water Use and Value Determination for the Site on July 5,
2005 [CTDEP, 2005b]. CT DEP has classified the aquifer for drinking water purposes; however,
the overburden and bedrock aquifers in the study area are not expected to yield sustainable,
significant quantities of water for use as a public drinking water resource,
Regarding community input on future land use, EPA published a public notice and brief analysis
of the Proposed Plan in The Middletown Press on July 9, 2005, and announced the availability of
the plan and supporting documents beginning July 13 at public information repositories at the
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Durham Public Library and at EPA's office in Boston, Massachusetts. The Proposed Plan was
subsequently mailed to over 400 local residents. The Proposed Plan included a notice to the
public of the availability of a Draft Reuse Assessment as part of the Site Administrative Record,
and solicited comments on this document. No specific comments on the Reuse Assessment were
submitted during the public comment period, although the draft document did not include
developments in 2005 regarding the ownership of the Merriam Manufacturing Company parcel.
G. SUMMARY OF SITE RISKS
EPA performed a baseline human health risk assessment and a screening-level ecological risk
assessment to estimate the probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with the Site assuming no
remedial action was taken. The assessments provide the basis for taking action and identify the
contaminants and exposure pathways that need to be addressed by the remedial action.
The baseline human health risk assessment followed a four step process: 1) hazard 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 and
uncertainty analysis, which integrated the three earlier steps to summarize the potential and
actual risks posed by hazardous substances at the Site, including carcinogenic and non-
carcinogenic risks and a discussion of the uncertainty in the risk estimates.
A summary of those aspects of the human health risk assessment which support the need for
remedial action is discussed below followed by a summary of the environmental risk assessment.
1. Human Health Risk Assessment
Hazard Identification
Forty-five of the more than 100 chemicals detected at the Site were selected for evaluation in the
human health risk assessment as chemicals of potential concern. The chemicals of potential
concern were selected to represent potential Site related hazards based on toxicity, concentration,
frequency of detection, and mobility and persistence in the environment and can be found in
Tables 2.1 through 2.11 of the risk assessment [M&E, 2005d, Draft Final Baseline Human
Health Risk Assessment]. From this, a subset of the chemicals were identified in the Feasibility
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Study as presenting a significant current or future risk (cancer risk exceeding one in a million or
hazard quotient exceeding the threshold level of 1) and are referred to as the chemicals of
concern in this ROD and summarized in ROD Tables 2 through 9 for surface soil, indoor air,
shallow groundwater, and bedrock groundwater. These tables contain the exposure point
concentrations used to evaluate the reasonable maximum exposure (RME) scenario in the
baseline risk assessment for the chemicals of concern. Exposure point concentrations for both
RME and central tendency exposure scenarios for all chemicals of potential concern can be found
in Tables 3.1 through 3.11 of the risk assessment [M&E, 2005d].
Exposure Assessment
Current and potential future Site-specific pathways for exposure to chemicals were determined.
The extent, frequency, and duration of current or potential future exposure were estimated for
each pathway. From these exposure parameters, a daily intake level of each Site-related chemical
was estimated.
The following is a brief summary of just the exposure pathways that were found to present a
significant risk. A more thorough description of all exposure pathways evaluated in the risk
assessment including estimates for an average exposure scenario, can be found in Section 3.0 and
on Tables 4.1 through 4.12 of the risk assessment [M&E, 2005dJ.
The following current exposure pathways were found to present a significant risk:
• Adjacent resident (adult and young child) with exposure to surface soil (by ingestion and
dermal contact) and indoor air (by inhalation) at the MMC Study Area;1
• Commercial worker exposure to untreated groundwater (by ingestion and dermal contact)
from the DMC Study Area supply well (DMC #1);2
• Residential household water exposure to untreated groundwater (by ingestion, dermal
contact, and inhalation) from private bedrock wells.3
1 For current residential soil exposures, ingestion of 100 mg/day for 24 years was presumed for an adult. For a young child (age
1 to 6), ingestion of 200 mg/day for 6 years was presumed. Body weights of 70 kg and 15 kg were used for the adult and child,
respectively. Dermal contact was assumed with 5,700 cm2 of surface area for the adult and 2,800 cm2 for the child. Soil
exposures were assumed to occur 150 days/year. The Johnson & Ettinger Model was used to estimate indoor air concentrations
from measured soil gas concentrations. Inhalation of indoor air was assumed to occur 24 hr/day, 350 days/yr, for a combined
exposure duration of 30 years.
3 For current untreated contaminated groundwater, a drinking water ingestion rate of 1 L/day was assumed for commercial
workers. An exposure frequency of 250 days/year was used for an exposure duration of 25 years. A body weight of 70 kg was
used, Dermal contact was assumed with 2,479 cm2 of surface area. Washing was assumed to occur 250 days/year for 0.5 hr/day,
3 For current exposures to untreated groundwater from private wells, drinking water ingestion rates of 2 L/day and 1.5 L/day for
the adult and child, respectively, were assumed. An exposure frequency of 350 days/year was used for a combined exposure
duration of 30 years. Dermal contact was assumed with 18,000 cm2 of surface area for the adult, and 6,600 cm1 for the child.
Showers/baths were assumed to occur 350 days/year for 0.58 hr/day for the adult and 1 hr/day for the child. Airborne
concentrations of volatile compounds released during showering/bathing were estimated using the Foster and Chrostowski
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The following future exposure pathways were found to present a significant risk;
• Resident (adult and young child) with exposure to surface soil (by ingestion and dermal
contact) and indoor air (by inhalation) at the MMC Study Area;4
• Resident (adult and young child) with exposure to indoor air (by inhalation) at the DMC
Study Area;5
• Construction worker exposure to shallow groundwater (by dermal contact and inhalation
of vapors) at the DMC Study Area;6 and
• Residential household water exposure to untreated groundwater (by ingestion, dermal
contact, and inhalation) from the Site-wide Groundwater Study Area.7
Toxicity Assessment
EPA assessed the potential for cancer risk and noncancer health effects.
The potential for carcinogenic effects is evaluated with chemical-specific cancer slope factors
(CSFs) and inhalation unit risk values, for oral and inhalation exposures. A weight of evidence
classification is available for each chemical. CSFs 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 calculated using the CSFs is unlikely
to be greater than the risk predicted. A summary of the cancer toxicity data relevant to the
chemicals of concern is presented in ROD Table 10.
The potential for noncancer health effects is quantified by using reference doses (RfDs) for oral
exposures and reference concentrations (RfCs) for inhalation exposures. RfDs and RfCs have
been developed by EPA and they represent an estimate (with uncertainty spanning perhaps an
order of magnitude) of a daily exposure that is likely to be without an appreciable risk of
deleterious effects during a lifetime. RfDs and RfCs are derived from epidemiological or animal
studies and incorporate uncertainty factors to help ensure that adverse health effects will not
shower model.
4 For future residential soil and indoor air exposures, the same exposure assumptions and methods described for the current
exposure scenario were used.
5 For future residential indoor air exposures, the same exposure assumptions and methods described for the current exposure
scenario were used
6 For future worker exposures to shallow groundwater, an exposure frequency of 66 days/year was used with an exposure
duration of 1 year. Dermal contact was assumed with 3,300 cm2 of surface area. Dermal contact was assumed to occur 1 hr/day.
The Johnson & Ettinger Model was used to estimate outdoor air concentrations from measured shallow groundwater
concentrations. Inhalation exposures were assumed to occur 8 hrs/day.
7 For future residential exposures to untreated groundwater, the same assumptions used for the current household water use
pathways were used.
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occur. A summary of the non-carcinogenic toxicity data relevant to the chemicals of concern is
presented in ROD Table 11.
Risk Characterization
This section combines estimates of exposure with toxicity to estimate potential health effects that
might occur if no action were taken.
Excess lifetime cancer risks were determined for each exposure pathway by multiplying the daily
intake level (see Exposure Assessment) by the CSF or by comparison to the unit risk value.
These toxicity values are conservative upper bound estimates, approximating a 95% confidence
limit, on the increased cancer risk from a lifetime exposure to an agent. Therefore, the true risks
are unlikely to be greater than the risks predicted. Cancer risk estimates are expressed as a
probability, e.g., one in a million. Scientific notation is used to express probability: one in a
million risk (1 in 1,000,000) is indicated by 1 x 10"6 or 1E-06. In this example, an individual is
not likely to have greater than a one in a million chance of developing cancer over a lifetime as a
result of exposure to the concentrations of chemicals at a site. All risks estimated represent an
"excess lifetime cancer risk" in addition to the background cancer risk experienced by all
individuals over a lifetime. The chance of an individual developing cancer from all other (non-
site-related) causes has been estimated to be as high as one in three. EPA's generally acceptable
risk range for site-related exposure is 10^ to 10"6 Current EPA's practice considers carcinogenic
risks to be additive when assessing exposure to a mixture of hazardous substances.
In assessing the potential for adverse effects other than cancer, a hazard quotient (HQ) is
calculated by dividing the daily intake level by the RID or RfC. A HQ < 1 indicates that an
exposed individual's dose of a single contaminant is less than the RfD or RfC and that a toxic
effect is unlikely. The Hazard Index (HI) is generated by adding the HQs for all chemical(s) of
concern that affect the same target organ (e.g. liver) within or across those media to which the
same individual may reasonably be exposed. A HI < 1 indicates that toxic non-carcinogenic
effects are unlikely.
The following is a summary of the media and exposure pathways that were found to present a
significant risk exceeding EPA's cancer risk range and noncancer threshold. Only those exposure
pathways deemed relevant to the remedy being proposed are presented in this ROD. Readers are
referred to Section 5 and Tables 9.1 through 9.77 of the risk assessment [M&E, 2005d] for a
more comprehensive risk summary of all exposure pathways evaluated for all chemicals of
potential concern and for estimates of the central tendency risk.
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Resident
ROD Tables 12 through 14 depict the carcinogenic and non-carcinogenic risk summary for the
chemicals of concern in surface soil and indoor air evaluated to reflect potential current and
future residential exposure corresponding to the RME scenario. For the current young child and
adult resident at the MMC Study Area, carcinogenic risks exceeded the EPA acceptable risk
range of 10"4 to 10"6. The cumulative carcinogenic risk was 5 x 10"4. The exceedance was due
primarily to the presence of carcinogenic PAHs and arsenic in surface soil and trichloroethene in
indoor air. For the future young child and adult resident at the MMC and DMC Study Areas,
carcinogenic and non-carcinogenic risks exceeded the EPA acceptable risk range of 10"4 to 10"6
and a target organ HI of 1, For the MMC Study Area, the cumulative carcinogenic risk was 2 x
10^ and the target organ HI was 5. The exceedances were due primarily to the presence of
trichloroethene, carcinogenic PAHs, arsenic, and chromium in surface soil and trichloroethene in
indoor air at the MMC Study Area. For the DMC Study Area, the cumulative carcinogenic risk
was 8 x 10'3 and the target organ HI was 4, The exceedances were due primarily to the presence
of trichloroethene in indoor air at the DMC Study Area.
Commercial Worker
ROD Tables 15 and 16 depict the carcinogenic and non-carcinogenic risk summary for the
chemicals of concern in bedrock groundwater evaluated to reflect potential current/future
commercial exposure at the DMC Study Area (well DMC#1) corresponding to the RME
scenario. For the current/future commercial worker, carcinogenic and non-carcinogenic risks
exceeded the EPA acceptable risk range of 10"4 to 10"6 and a target organ HI of 1. The
cumulative carcinogenic risk was 2 x 10"4 and the target organ HI was 5. The exceedances were
due primarily to the presence of tetrachloroethene and trichloroethene in bedrock groundwater.
Construction Worker
ROD Table 17 depicts the non-carcinogenic risk summary for the chemicals of concern in
shallow groundwater evaluated to reflect potential future construction worker exposure at the
DMC Study Area corresponding to the RME scenario. For the future construction worker, non-
carcinogenic risks exceeded the EPA acceptable target organ HI of 1. The target organ HI was
30. The exceedance was due primarily to the presence of trichloroethene in shallow
groundwater.
Residential Groundwater Use (Site-wide)
ROD Tables 18 through 21 depict the carcinogenic and non-carcinogenic risk summary for the
chemicals of concern in private bedrock groundwater wells and Site-wide bedrock groundwater
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evaluated to reflect potential current and future potable water exposure corresponding to the
RME scenario.
For the current resident using untreated groundwater as household water, carcinogenic and non-
carcinogenic risks exceeded the EPA acceptable risk range of I04 to I0"6 and/or a target organ HI
of 1 for 35 of the private wells. The cumulative carcinogenic risks range from 2 x 10"4 to 3 x 10"2
and the target organ His range from 2 to 900. The exceedances were due primarily to the
presence of benzene, 1,2-dichloroethene, cis-1,2-dichloroethene, 1,2-dichloroethane, 1,4-
dioxane, methylene chloride, tetrachloroethene, trichloroethene, vinyl chloride,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, bis(2-ethylhexyl)phthalate,
dibenz(a,h)anthracene, indeno( 1,2,3-cd)pyrene, pentachlorophenol, arsenic, and vanadium in
bedrock groundwater used for potable purposes.
For the future resident using untreated groundwater as household water, carcinogenic and non-
carcinogenic risks exceeded the EPA acceptable risk range of 10"4 to 10"6 and/or a target organ HI
of 1 for Site-wide bedrock groundwater, The cumulative carcinogenic risk was 4 x 10"2 and the
target organ HI was 900, The exceedances were due primarily to the presence of benzene, 1,2-
dichloroethene, cis-1,2-dichloroethene, 1,2-dichloroethane, 1,4-dioxane, methylene chloride,
tetrachloroethene, trichloroethene, vinyl chloride, benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, bis(2-ethylhexyl)phthalate, dibenz(a,h)anthracene, indeno(l,2,3-cd)pyrene,
pentachlorophenol, arsenic, mercury, and vanadium in bedrock groundwater used for potable
purposes.
Uncertainties
Shallow groundwater data for the DMC Study Area were not validated. This shallow
groundwater data was used in the risk assessment as reported because no other data of higher
quality were available. The data were used to estimate risk for the future construction worker
and future resident. Because the quality and, therefore, reliability of these data are unknown, the
use of the unvalidated shallow groundwater data results in uncertainty of unknown bias regarding
the risk estimates for these media.
Trichloroethene is being re-evaluated for carcinogenic potency by EPA, The high-end of the
range of oral slope factors and unit risk values was used for risk estimation. This approach may
have resulted in an overestimate of the risk associated with trichloroethene in groundwater and
air. This uncertainty will be periodically reviewed to address changes in the toxicity values for
this compound.
For the groundwater dermal contact pathway, risk associated with dermal absorption of
chlorinated organic compounds may be underestimated. Permeability constants for the
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chlorinated organic compounds such as 1,1 -dichloroethene, 1,2-dichloroethane, 1,2-
dichloroethene, methylene chloride, tetrachloroethene, trichloroethene, and vinyl chloride tend to
be underestimated by the correlation modeling. This uncertainty may result in an
underestimation of risk. In addition, risk associated with dermal absorption could not be
quantified for all contaminants. Data needed to predict dermal absorption is insufficient for
some compounds including pentachlorophenol and carcinogenic PAHs. This uncertainty may
also result in an underestimation of risk. These uncertainties will be periodically reviewed to
address changes in the toxicity values and dermal absorption values.
Airborne concentrations of volatile compounds for the indoor air, outdoor air, and
showering/bathing scenarios were estimated using accepted EPA exposure models. The use of
modeling to estimate airborne concentrations of volatile compounds likely result in an over-
estimate of risk since conservative assumptions were employed in the exposure modeling.
2. Ecological Risk Assessment
EPA's Screening-Level Ecological Risk Assessment (SLERA) concluded that no ecological
receptors are expected to experience significant, long-term risk from Site-related contaminants
present in surface water or sediment, therefore there is no actionable ecological risk associated
with the Site.
Section 1.* Identifying contaminants of potential concern (COPCs),
EPA performed a SLERA to estimate the probability and magnitude of potential adverse
environmental effects from exposure to contaminants associated with the Site assuming no
remedial action was taken [USEPA, 2005].
In 1993, M&E sampled surface water and sediment locations in the vicinity of the MMC and
DMC properties for EPA. Based on these results, EPA developed a supplemental sampling
program and collected additional samples during the RI in 1998. These analytical data were
compiled and sorted by environmental medium. The media of concern were surface water,
sediment, and wetland soil collected in and around Ball Brook, both across from and upstream of
the Site. Further details are available in the SLERA [USEPA, 2005].
Metals in surface water collected from Ball Brook were analyzed in both unfiKered and filtered
samples. The analytical results from the unfiltered samples represent total metals, which include
both the fraction associated with particulate matter and the fraction which is freely dissolved in
the water column. The filtered samples represent only the dissolved metals fraction. It is the
latter which is responsible for any aquatic toxicity that may be associated with this group of
compounds in surface water.
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Following EPA Region I practices, COPCs were not selected by comparing Site data to
background data. However, background data were used during risk characterization to separate
COPCs present in Ball Brook due to natural or upstream anthropogenic sources from those that
may have been released from the Site at levels exceeding background.
An arithmetic mean was calculated for each analyte present above its detection limit in at least
one surface water, sediment, or wetland soil sample. The maximum concentration was also
retained for each of those analytes. A chemical was eliminated from further consideration if it
was not present above its detection limit in any of the surface water, sediment, or wetland soil
samples.
A chemical was retained as a COPC if its maximum concentration in surface water, sediment, or
soil exceeded a conservative ecological benchmark, A chemical was automatically retained as a
COPC if no benchmark was available. Calcium, magnesium, potassium, and sodium were
removed from further consideration because these compounds are physiological electrolytes.
ROD Table 22, Table 23, and Table 24 provide, for each COPC in surface water, sediment, and
wetland soil, respectively, the (a) frequency of detection, (b) minimum detected concentration
onsite, (c) arithmetic mean concentration (detects only and detects plus one half the detection
limit for non-detects), (d) maximum detected concentration onsite, (e) maximum detected
background concentration (if available), (0 benchmark, (g) ecological hazard quotient (HQ), (h)
COPC flag, and (i) reason codes.
One SVOC and three metals were retained as surface water COPCs, either because their
maximum concentrations exceeded their benchmarks or because no benchmarks were available
(see Table 22).
Two VOCs, seventeen SVOCs, two pesticides, and ten metals were retained as sediment COPCs,
either because their maximum concentrations exceeded their benchmarks or because no
benchmarks were available (see Table 23).
One VOC, seventeen SVOCs, two pesticides, and 12 metals were retained as wetland soil
COPCs, either because their maximum concentrations exceeded their benchmarks or because no
benchmarks were available (see Table 24),
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Section 2; Exposure assessment.
2.1 Ecological setting
Merriaro Manufacturing Company fMMC):
The MMC facility operated from a single-story building that was largely destroyed by a fire in
1998. A drainage swale begins on the southern edge of the property, and turns to the north
behind a former waste lagoon, eventually widening, and draining into a forested area adjacent to
a seasonally-saturated wet meadow, which extends to Ball Brook, The wet meadow has some
standing water, but both the wet meadow and Ball Brook may become nearly dry during the
summer.
The wet meadow extends for about 150 feet from the base of the slope east of the facility to Ball
Brook. It does not appear on the U.S. Fish and Wildlife Service National Wetland Inventory
Map, most likely due to its small size. Ball Brook flows from north to south through the wet
meadow before passing through a culvert beneath Brick Lane, joining a tributary which flows
from the northeast, and flowing south toward the Durham Manufacturing facility. Upstream
from MMC, Ball Brook begins at a small pond in a residential area, passes through a mowed
field, then flows adjacent to an outfall pipe that appears to be broken and out of service. The
brook then flows through a series of meanders before entering the wet meadow. The stream
channel becomes poorly defined in the downstream (southern) end of the wet meadow. It is
likely that during periods of high water, the brook spreads over the adjacent areas of cattails and
sedges.
Durham Manufacturing Company (DMO:
The area behind the DMC facility parking lot is primarily riparian (Ball Brook). A small pond
(described as a cooling water basin) is located close to the factory (western) side of the stream,
and is bordered to the north by a small wetland dominated by common reed (Phragmiies
australis) and reed canary grass (Phalaris arundinacea).
Ball Brook is about eight feet wide and fairly shallow at the DMC facility. The stream bottom
contains a mixture of debris (e.g., concrete blocks, bricks, etc.) in the vicinity of the cooling
pond, but is sand/silt just upstream, and a rocky/gravelly/sandy substrate downstream from the
pond.
2.2 Key species
Given the limited terrestrial habitat on the DMC portion of Ball Brook, the principal ecological
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receptors of concern would be aquatic organisms inhabiting the brook and terrestrial organisms
found in and around the wet meadow.
The benthic invertebrate community was not characterized for this SLERA. However, Ball
Brook sediment should support a diverse assemblage of benthic invertebrates. Numerous
caddisfly and stonefly larvae were observed in the substrate of Ball Brook during past Site visits.
The local fish community in Ball brook was not characterized for this SLERA, Small fish have
been observed in portions of Ball Brook upstream and downstream from the MMC facility.
However, the section that passes through the wet meadow has a maximum depth of only a few
inches, and is less than one inch deep in portions of the southern end of the wet meadow. This
area is unlikely to support fish. Dace and fmgerling-sized trout have been observed along the
reach of Ball Brook downstream from the DMC site up to its confluence with Hersig Brook.
The local amphibian community in and around Ball Brook, the wet meadow, and the adjoining
riparian areas was not characterized for this SLERA. It is expected to include several species of
frogs (e.g., green frog, spring peeper, northern leopard frog, and tree frog) and salamanders (e.g.,
northern two-lined salamander and northern dusky salamander).
The local reptile community in and around Ball Brook, the wet meadow, and the adjoining
riparian areas also was not characterized for this SLERA. It is expected to include several
species of snakes (e.g., eastern ribbon snake, eastern garter snake, northern water snake, and
northern brown snake) and aquatic turtles (e.g., eastern painted turtle and spotted turtle).
The following bird species were observed directly or indirectly during past Site visits: song
sparrows, a mallard with a brood, northern cardinal, American robin, red-winged blackbird, red-
tailed hawk, blue jay, gray catbird, common graekle, and common yellow throat.
The following mammal species were observed directly or indirectly during past Site visits: the
hairytail mole, whitetail deer, muskrat, raccoon and domestic cattle. Additional mammals
expected to frequent the riparian areas at the Site may include the short-tailed shrew, mink,
cottontail rabbit, muskrat, white-footed mouse, eastern gray squirrel, meadow vole, eastern
chipmunk, and woodchuck.
Table 25 summarizes the ecological exposure pathways of concern and the various endpoints
evaluated in the SLERA.
For non-wildlife receptors (i.e., fish, benthic invertebrates, soil invertebrates, and terrestrial
2.3 Calculating exposures
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plants), the arithmetic mean {calculated as the average of the detects and 14 the detection limit for
non-detects) of each COPC identified in surface water, sediment, and soil were used as exposure
point concentrations.
For the target wildlife receptor (i.e., the short-tailed shrew feeding in the wet meadow), food
chain modeling was used to calculate mean and maximum COPC-specific estimated daily intakes
(EDIs). The generic equation used in these calculations was as follows:
EDItotai - EDIsoil + EDI food
Where: EDItoUi = the total estimated daily intake (mean and maximum) of a COPC from
all applicable exposure routes
EDISOii = the estimated daily intake (mean and maximum) of a COPC from the
incidental ingestion of soil during foraging activity
EDIfood = the estimated daily intake (mean and maximum) of a COPC via food
ingestion
A food chain model was developed to calculate a mean and maximum EDI for the short-tailed
shrew, assuming that this receptor obtained all of its food from the wet meadow entirely in the
form of earthworms. The tissue residue levels in earthworms were estimated based on measured
concentrations in the soil samples from the wet meadow and using (1) an equilibrium
partitioning model for organic COPCs, and (2) regression equations and uptake factors (UFs) for
metal COPCs. It was assumed that the daily intake of COPCs from drinking Ball Brook surface
water was negligible.
Section 3; Ecological effects assessment.
3.1 Measures of ecological effect for non-wildlife receptors
Aquatic receptors
The chronic surface water benchmarks used to select COPCs were retained as measures of
ecological effects for use in risk characterization. Those values were (in order of preference): (1)
the chronic national ambient water quality criteria [USEPA, 2002b]; (2) the secondary chronic
values [Suter and Tsao, 1996]; or (3) the lowest chronic value for fish, aquatic invertebrates, or
aquatic plants [Suter and Tsao, 1996].
The "no effect" sediment benchmarks used for selecting COPCs were also retained as measures
of ecological effects for use in risk characterization. Those values were (in order of preference):
(1) the threshold effects concentrations [Ingersoll et al., 2000]; (2) the sediment ecotox
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thresholds [USEPA, 1996]; (3) the lowest effect levels [Jaagumagi et al., 1995]; (4,a) for organic
compounds, the Equilibrium Partitioning-derived secondary chronic value or lowest chronic
value sediment quality benchmarks [Jones et al., 1997]; and (4,b) for metals, the EPA Region IV
sediment benchmarks [Jones et al., 1997].
In addition, "effects" sediment benchmarks were included as measures of ecological effect to
better characterize risk. Those values were (in order of preference): (1) the probable effects
concentrations [MacDonald et al., 2000], the effects range - medians [Long et al., 1995], and the
severe effect levels [Persaud et al, 1993],
Terrestrial receptors
The conservative soil benchmarks used to select COPCs in the wet meadow were retained as
measures of ecological effects to evaluate risk to terrestrial non-wildlife receptors. Those values
were (in order of preference): the U.S. EPA ecological soil screening levels [USEPA, 2003], (2)
the Oak Ridge National Laboratory (ORNL) wildlife benchmarks [Sample et al., 1996]; (3) the
ORNL terrestrial plants benchmarks [Efroymson et al., 1997], and (4) the ORNL soil, litter
invertebrates and heterotrophic processes benchmarks [Efroymson et al., 1997b],
3.2 Measures of effect for wildlife reeeptors
Wildlife receptor exposures were estimated using food chain modeling to calculate an EDI for
each COPC. The EDIs were then compared to published no effect toxicity reference values
(TRVs) for mammals, which represent daily contaminant intakes not believed to result in
harmful impacts under long-term exposures.
Section 4: Ecological risk characterization.
The hazard quotient method (HQ = mean exposure concentration * toxicity value) was used to
identify the potential for ecological risk in the medium of concern. If a HQ was below 1.0, then it
was assumed unlikely that the COPC would result in an adverse effect to a target receptor group.
Conversely, a HQ above 1.0 indicated the possibility of risk to the target receptor group.
The risk calculated for onsite samples was compared with risk in upstream reference samples. Also,
the mean concentrations for surface water, sediment, and soil were used instead of the maximum
concentrations in order to provide a more realistic evaluation of risk. This refinement of the SLERA
focused the assessment on those contaminants more likely to be associated with past Site discharges.
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4,1 Risk estimates
4.1.1 Potential risk to surface water receptors
ROD Table 26 summarizes the surface water risk for those contaminants identified as COPCs in
ROD Table 22, and compares concentrations in Site samples to upstream reference samples.
Chronic risk based on mean Site concentrations was present for aluminum and barium in
unfiltered surface water, but only for barium in filtered surface water. The ratio of the Site
maximum over the reference maximum concentrations indicates that there is some incremental
exposure onsite for barium and copper. However, the concentrations of these metals were
noticeably higher than background in only one station on Ball Brook (BB2). Immediately
downstream of this sampling location, in station BB1, concentrations were similar to
background. This pattern suggested that the contamination was localized to the immediate
vicinity of the cooling water pond outfall, and would be unlikely to have a noticeable effect on
surface water receptors in Ball Brook downstream of the Site.
Taken together, this information suggested that aquatic receptors were not expected to experience
significant, long-term risk from Site-related contaminants present in the surface water from Ball
Brook.
4.1.2 Potential risk to sediment receptors
ROD Table 27 summarizes the sediment risk for those contaminants identified as COPCs in
ROD Table 23 , and compares concentrations in Site samples to upstream reference samples.
The assessment indicated that 14 PAHs and three metals exceeded a HQ of 1.0 when their mean
concentrations were compared to their corresponding "no effect" benchmarks. Only five of those
PAHs, but no metals, exceeded a HQ of 1.0 when their mean concentrations were compared to
their corresponding "effect" benchmarks. However, none of the five PAHs exceeded the
concentrations found at the upstream reference location, suggesting that the source of PAH
contamination was located upgradient from the MMC facility. It was concluded that any risk to
the benthic invertebrate community that might be associated with PAHs would not be due to past
Site releases.
4.1.3 Potential risk to soil receptors
No additional soil benchmarks were available to further refine the soil assessment. The available
evidence indicated that the VOCs identified as COPCs were unlikely to present risk to soil
receptors (see ROD Table 24). Not enough benchmarks were available to further evaluate the
potential risk of PAHs to soil receptors. Twelve metals did exceed their conservative soil
benchmarks but no additional information was available to determine if those exceedances had
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the potential to result in significant risk to soil receptors. Five-year reviews will be conducted at
this Site to ensure that the remedy continues to be protective of human health and the
environment. Such reviews consider newly developed risk information, such as new or revised
ecological benchmarks.
ROD Tables 28 and 29 show the HQs for the short-tailed shrew under maximum and mean
exposure scenarios, respectively.
Under the maximum exposure scenario, six PAHs and seven metals had HQs above 1.0. Under
the mean exposure scenario, five PAH and four metals showed HQs exceeding 1.0. The HQs
decreased on average by a factor of two between the two exposure scenarios.
The maximum exposure scenario provided a "worst-case" risk estimate which is unlikely to
occur in the field. Under mean exposure, benzo(b)fluoranthene and indeno(l,2,3-cd)pyrene had
HQs equal to 3.4 and 2.3, respectively. The HQs of the remaining PAHs fell between 1.0 and
2.0. Given the conservative assumptions built into the exposure assessment and the fact that the
TRVs represented daily intakes not expected to result in long-term toxicity response, it was
considered highly unlikely that actual risk to the shrew would be associated with the levels of
PAHs measured in the wet meadow.
The aluminum concentrations in wetland soil are difficult to interpret using the available
information. The U.S. EPA Ecological Soil Screening Level for Aluminum directive, dated
2003, notes the difficulty of modeling risk from aluminum in soil based on total aluminum
analysis, and suggests using a generic rule that aluminum is seldom a problem for terrestrial
receptors in soils above pH 5.5. In this instance the soil pH is not known, so this rule cannot be
applied.
A review of the aluminum concentrations across the two transects suggested that aluminum was
not associated with any known point source on the MMC property, because concentrations did
not appear to decrease with greater distance from the site. On the basis of distribution, it did not
appear that aluminum had moved from the MMC property into the wet meadow through the flow
paths evaluated in this SLERA. It was therefore concluded that aluminum did not represent a
Site-related risk to wildlife receptors.
Conservative exposure and toxicity assumptions were used in this SLERA to ensure that risk was
not missed if it was in fact present and to serve as substitutes for the lack of Site-specific data.
4.1.4 Potential risk to terrestrial wildlife receptors
4.2 Uncertainty analysis
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The major uncertainties of the SLERA and their potential impacts on the results of the SLERA
are summarized below.
Non-wildlife aquatic and soil receptors
The risk analysis indicated the presence of potential risk to benthic invertebrates and soil
receptors in some areas of Ball Brook and the wet meadow. The biggest impact on the overall
risk to those two receptor groups was that some of the metal COPCs in sediment and the majority
of soil COPCs lacked benchmarks. Hence, the potential impact of these chemicals could not be
fully assessed using the HQ methodology. Five-year reviews will be conducted at this Site to
ensure that the remedy continues to be protective of human health and the environment. Such
reviews consider newly developed risk information, such as new or revised ecological
benchmarks.
Terrestrial wildlife receptors
Several conservative assumptions were required to calculate daily exposures to the short-tailed
shrew using simplified food chain modeling. The major assumptions are discussed below:
(1) Soil-to-biota Uptake Factors (UFs) represent crude estimates of contaminant transfers
through the food chain. Even though several metal UFs were based on empirical data,
most UFs in the literature were derived using simple assumptions and calculations. Also,
conservative UFs of 1.0 were used if published UFs were unavailable.
(2) For a SLERA, EPA guidelines recommend assuming that COPCs in food, soil, and
sediment are 100% bioavailable and thus become part of the daily dose. Also, no
provision was made for detoxification by metabolism and excretion in the wildlife
receptors. This represents a conservative assumption.
(3) For a SLERA, EPA guidelines recommend assuming that the diet is composed of the
most contaminated food. For this study, the shrew was assumed to consume earthworms
for 100% of its daily food intake. This was quite conservative, because shrews in the
field would consume only around half of their food in the form of earthworms.
(4) Conservative "no effect" toxicity reference values (TRVs) were used in the risk
characterization.
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(5) The health effects of benzo(a)pyrene on mammals are well documented due to the
high toxicity of this chemical. Wildlife TRVs were unavailable for most of the other, but
less toxic, PAHs. It was assumed conservatively that their toxicities were equal to that of
benzo(a)pyrene.
(6) Finally, COPCs without TRVs were excluded from the HQs, even though their
concentrations were modeled into prey items. It is reasonable to assume that some of
those COPCs could be present in prey items at concentrations harmful to one or more of
the wildlife receptors. The risk associated with those COPCs cannot be quantified.
3. Basis for Response Action
Because the baseline human health risk assessment revealed that current and future residents,
commercial workers and construction workers potentially exposed to compounds of concern
in various media by a variety of exposure pathways may present an unacceptable human health
risk, actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
• For current and future residents potentially exposed to compounds of concern in untreated
groundwater via ingestion, dermal contact, and inhalation, carcinogenic and non-
carcinogenic risks exceeded the EPA acceptable risk range of 10"4 to 1CT6 and/or a target
organ HI of 1. A similar unacceptable risk is posed by ingestion and dermal contact from
the DMC supply well (DMC #1) to current and future commercial workers.
• For current and future residents adjacent to the MMC Study Area potentially exposed to
compounds of concern in surface soil and soil vapor via ingestion, dermal contact, and
inhalation, carcinogenic risks exceeded the EPA acceptable risk range of 1CT1 to 10"6.
• For future residents that may come to be located at the MMC Study Area and potentially
exposed to compounds of concern in surface soil and soil vapor via ingestion, dermal
contact and inhalation, carcinogenic and non-carcinogenic risks exceeded the EPA
acceptable risk range of 10"4 to 10"6 and a target organ HI of 1.
• For future residents that may come to be located at the DMC Study Area and potentially
exposed to compounds of concern in indoor air via inhalation following vapor migration
from overburden (shallow) groundwater, carcinogenic risks exceeded the EPA acceptable
risk range of 104 to 10"6 and a target organ HI of 1.
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• For future construction workers at the DMC Study Area potentially exposed to
contaminants of concern in overburden (shallow) groundwater by dermal contact, non-
carcinogenic risks exceeded the EPA acceptable target organ HI of 1,
Media which are to be the focus of remedial actions based on the human health risk assessment
therefore include groundwater at the Site-wide Groundwater Study Area, overburden (shallow)
groundwater at the DMC Study Area, and surface soil and soil vapor at the MMC Study Area.
EPA's new Cancer Guidelines and Supplemental Guidance (March 2005) will be used as the
basis for EPA's analysis of all new carcinogenicity risk assessments. If updated carcinogenicity
risk assessments become available, EPA will determine whether an evaluation should be
conducted as part of the remedial design to assess whether adjustments to the target cleanup
levels for this remedial action are needed in order for this remedy to remain protective of human
health.
Because the Screening-Level Ecological Risk Assessment concluded that no ecological receptors
are expected to experience significant, long-term risk from Site-related contaminants present in
surface water or sediment, there is no actionable ecological risk associated with the Site, and
there are no cleanup alternatives specifically tailored to ecological risk mitigation.
H. REMEDIATION OBJECTIVES
Based on preliminary information relating to types of contaminants, environmental media of
concern, and potential exposure pathways, response action objectives (RAOs) were developed to
aid in the development and screening of alternatives. These RAOs were developed to mitigate,
restore and/or prevent existing and future potential threats to human health and the environment.
RAOs are based on numeric cleanup goals and regulatory requirements called Applicable or
Relevant and Appropriate Requirements (ARARs). ARARs include federal and state
environmental statutes, regulations and requirements, such as federal drinking water quality
standards (Maximum Contaminant Levels, or MCLs), state drinking water quality standards, and
Connecticut Remediation Standard Regulations (CT RSRs). Risk-based goals (RBGs) are
identified by EPA where no ARARs for particular contaminants exist.
Chemical-specific, location-specific, and action-specific ARARs are included in Tables F-l, F-2,
and F-3 in Appendix F.
The RAOs for the Site are listed below. For informational purposes, RAOs are included for
media where cleanup goals will be waived.
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The RAOs for the MMC Study Area are:
• To reduce the potential exposure of current adjacent residents at the MMC Study Area
to benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene,
indeno(l,2,3-cd)pyrene, and arsenic in surface soil via ingestion and dermal contact
that may present a human health risk in excess of 10"4 such that the cancer risk
attributable to this medium is within the range of lO^to 10"6 and complies with CT
RSR residential direct exposure criteria (DECs) for the protection of human health.
• To reduce the potential exposure of future residents at the MMC Study Area to
trichloroethene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,
dibenz(a,h)anthracene, indeno(l»2,3-cd)pyrene, arsenic and chromium in surface soil
via ingestion and dermal contact that may present a human health risk in excess of 10"4
and target organ HI>1 such that the cancer and non-cancer risk attributable to this
medium is within the range of 10"4 to 10"6 and a HI which does not exceed one and
complies with CT RSR residential DECs for the protection of human health.
• To reduce direct contact exposures to Extractable Total Petroleum Hydrocarbons
(ETPH), chromium, lead, and mercury in surface soil at the MMC Study Area by
complying with the CT RSR residential DECs.
• To limit migration of tetrachloroethene, trichloroethene, acenaphthylene,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g»h,i)perylene,
benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, fluoranthene, indeno( 1,2,3-
cd)pyrene, phenanthrene, pyrene, ETPH, arsenic, cadmium, chromium, copper, and
lead in surface soil and 1,2,4-trimethylbenzene, trichloroethene, xylene, and lead in
subsurface soil at the MMC Study Area to groundwater by complying with the CT
RSR GA/GAA pollutant mobility criteria (PMC).
• To reduce the potential exposure of current adjacent residents at the MMC Study Area
to trichloroethene in soil gas via inhalation that may present a human health risk in
excess of 10"4 such that the cancer risk attributable to this medium is within the range
of 10" to 10"6 and complies with proposed CT RSR residential volatilization criteria
(VC) for the protection of human health.
• To reduce the potential exposure of future residents at the MMC Study Area to
trichloroethene in soil gas via inhalation that may present a human health risk in excess
of 10"4 and target organ HI>1 such that the cancer and non-cancer risk attributable to
this medium is within the range of lO^to 1 (F6 and a HI which does not exceed one and
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complies with proposed CT RSR residential VC for the protection of human health.
The RAOs for the DMC Study Area are:
• To reduce the potential exposure of future construction workers at the DMC Study
Area to trichloroethene in shallow (overburden) groundwater via dermal contact that
may present a human health target organ HI>1 such that the non-cancer risk attributable
to this medium is a HI which does not exceed one for the protection of human health.
• To reduce direct contact and inhalation exposures to 1,1,1 -trichloroethane,
tetrachloroethene, and toluene in overburden groundwater at the DMC Study Area by
complying with the ARARs (MCLs and CT RSR GWPC and GWVC). (These
groundwater ARARs are waived pursuant to the technical impracticability discussion
in Section I of this ROD).
• If it is determined, after further investigation, there are areas posing an unacceptable
risk, actions will be taken to reduce the potential for ethylbenzene, trichloroethene,
vinyl chloride, and xylene present in shallow groundwater at the DMC Study Area to
volatilize into buildings.
The RAOs that apply Site-wide are:
• To protect surface water quality by complying with the CT RSR surface water
protection criteria (SWPC) for the protection of the environment for groundwater
contaminants that discharge to surface water. (These criteria are waived pursuant to
the technical impracticability discussion in Section I of this ROD.)
• To remove or contain DNAPL present in subsurface soil at the MMC Study Area, soil
and overburden groundwater at the DMC Study Area, and bedrock groundwater at the
Site-wide Groundwater Study Area to the extent practicable.
• To reduce the potential exposure of residents and DMC commercial workers at the Site-
wide Groundwater Study Area to 1,2-dichloroethane, 1,2-dichloroethene, 1,4-dioxane,
benzene, methylene chloride, tetrachloroethene, trichloroethene, vinyl chloride,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, bis(2-ethylhexyl)phthalate,
dibenz(a,h)anthracene, indeno(l ,2,3-cd)pyrene, pentachlorophenol, arsenic, mercury,
and vanadium in bedrock groundwater via ingestion, dermal contact, and inhalation
that may present a human health risk in excess of 10"4 and target organ HI> 1 such that
the cancer and non-cancer risk attributable to this medium is within the range of 10"4 to
10"6 and a HI which does not exceed one and complies with ARARs (MCLs and CT
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RSR GWPC and GWVC) for the protection of human health. (These groundwater
ARARs and risk-based goals are waived pursuant to the technical impracticability
discussion in Section I of this ROD.)
• To reduce 1,1 -dichloroethane, 1,1-dichloroethene, benzo(k)flouranthene, phenanthrene,
copper, lead, and zinc in bedrock groundwater by complying with the ARARs {MCLs
and CT RSR GWPC and GWVC). {These groundwater ARARs are waived pursuant
to the technical impracticability discussion in Section I of this ROD.)
• If it is determined, after further investigation, there are areas posing an unacceptable
risk for the vapor intrusion pathway, actions will be taken to reduce potential indoor air
inhalation exposures to volatile compounds in groundwater at the Site-wide
Groundwater Study Area.
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
1. 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 and facility siting 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.
2. Technology and Alternative Development and Screening
CERCLA and the National Contingency Plan (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 at the MMC Study Area and the DMC Study Area, the RI/FS
developed a range of alternatives in which hazardous substances are treated or removed to the
maximum extent feasible, minimizing to the degree possible the need for long term management.
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This range also included alternatives that treat certain of 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; altemative(s) that involve little or
no treatment but provide protection through engineering or institutional controls; and a no action
alternative for each Study Area.
With respect to the Site-wide Groundwater Study Area, the RI/FS developed two sets of remedial
alternatives, one set that addresses potential response to the source zone and dissolved plume
portions of contaminated groundwater, and another set that specifically addresses the provision
of an alternate water supply.
Remedial alternatives related to provision of an alternate water supply focused only on the range
of options available to ensure provision of potable water to area residents and businesses; a no
action alternative is also provided.
With respect to the source zone and dissolved plume portions of contaminated groundwater, a
limited number of remedial alternatives are presented that attain Site specific remediation levels
for the dissolved plume within different timeframes; a no action alternative is also provided. The
RI/FS determined that no remedial alternative was available to achieve cleanup of the source
zone within a reasonable timeframe, and therefore the only alternatives presented are for
containment and for no action.
As discussed in Section 3.0 of the FS, soil and groundwater treatment technology options were
identified, assessed and screened based on implementability, effectiveness, and general cost.
Section 4.0 of the FS presented the remedial alternatives developed by combining the
technologies identified in the previous screening process in the categories identified in Section
300.430(e)(3) of the NCP. The purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while preserving a range of options. Each
alternative was then evaluated in detail in Section 6.0 of the FS.
3. Technical Impracticability Evaluation
Restoration of contaminated groundwater, especially in a designated drinking water aquifer, is
one of the primary objectives of the Superfund program. The National Contingency Plan, which
provides the regulatory framework for the Superfund program, states that: "EPA expects to return
usable ground waters to their beneficial uses wherever practicable, within a timeframe that is
reasonable given the particular circumstances of the site" (NCP section 300.430(a)(l)(iii)(F)).
Generally, restoration cleanup levels are established by applicable or relevant and appropriate
requirements (ARARs), such as the use of federal or state standards for drinking water quality
[USEPA, 1993].
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ARARs may be waived for six reasons, including where compliance with the requirements is
technically impracticable from an engineering perspective. Where groundwater ARARs are
waived at a Superfund site due to technical impracticability, EPA's general expectations are to
prevent further migration of the contaminated groundwater plume, prevent exposure to the
contaminated groundwater, and evaluate further risk reduction measures as appropriate. (NCP
section 300.430(a)(l)(iii)(F)).
Experience has shown, however, that restoration to drinking water quality may not always be
achievable due to the limitations of available remediation technologies, EPA, therefore, must
evaluate whether groundwater restoration at Superfund sites is attainable from an engineering
perspective. Factors that can inhibit groundwater restoration include hydrogeologic factors and
contaminant-related factors, such as the presence of dissolved non-aqueous phase liquids
(DNAPL),
EPA conducted an evaluation to determine whether it was technically practicable to clean up the
groundwater in the area of the Site within a reasonable timeframe. This evaluation is further
discussed in the Technical Impracticability Evaluation Report [M&E, 2005c Draft Final
Technical Impracticability Evaluation]. The evaluation concluded that restoration of both the
overburden and bedrock aquifers in a reasonable timeframe is not practical for the following
reasons:
• The presence of contaminants in residential wells demonstrates that there was a pathway
of chlorinated solvent contamination from MMC and DMC and potentially other source
areas to the bedrock aquifer.
• Historically, deep, open-hole production wells within the potential DNAPL source area
likely mobilized and spread aqueous phase contamination and DNAPL laterally and
vertically, effectively expanding the size of the source area and aqueous plume. The
mechanisms that cause this contamination are borehole short-circuiting and pool
mobilization through change in DNAPL entry pressures caused by pumping in the
vicinity of release areas. Borehole short-circuiting can occur when DNAPL that is pooled
at shallower locations in bedrock enters a borehole (e.g., bedrock supply or drinking
water well), and cascades down to the bottom of wells and potentially invades deeper
fractures. Pool mobilization can occur when pumping near solvent release locations
causes DNAPL pools to mobilize and spread vertically and laterally over a larger area
than would have occurred under natural gradients and entry pressures. These
mechanisms are described conceptually in Figures 3,2-1 and 3.2-2 of the Technical
Impracticability Evaluation Report [M&E, 2005c].
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• The presence of chlorinated solvent contamination in residential areas located several
hundred feet from the release areas demonstrates widespread bedrock contamination,
• Most of the residential wells are deep, open-hole bedrock wells. Although contaminants
may originally have migrated in discrete fractures, significant cross-contamination
through borehole short-circuiting and mixing has likely occurred as a result of pumping
these wells over time.
• Little is known regarding the depth of contamination. A significant and costly
investigation would be required to characterize the vertical extent of contamination.
Even with installation of several monitoring wells, the characterization of the source zone
and extent of dissolved-phase contamination would likely not be conclusive due to the
heterogeneous nature of fractured bedrock. Therefore, it would be difficult to design an
optimal remediation system to restore bedrock groundwater.
• The bedrock is sedimentary in nature and is known to be fractured. Once DNAPL
reaches the bedrock, it will migrate downward until it cannot overcome the entry pressure
of the fracture due either to the small aperture width or decrease in pool height. The
DNAPL may also enter dead-end fractures and cause diffusion of aqueous contaminants
into the rock matrix. Removal of DNAPL from fractured bedrock and restoration of
groundwater to background concentrations in DNAPL zones within a reasonable time-
frame is extremely difficult, if not impossible, due to limited natural or induced flushing
within bedrock fractures, particularly dead-end fractures. Also, back diffusion from the
matrix could cause concentrations to persist above groundwater standards for years.
Current remedial technologies are not effective in restoring DNAPL zones in porous and
fractured media, particularly in complex settings.
• The overburden aquifer is a low permeability, porous, fractured glacial till formation. It
is likely that DNAPL exists in the till at MMC and DMC based on current data. DNAPL
may be pooled in dead-end fractures or remain as residual in the till fractures where
diffusive losses to the porous matrix may dissipate DNAPL over time. These
characteristics limit the hydraulic accessibility of DNAPL and, coupled with the low
permeability of the till, make removal of DNAPL and restoration of groundwater to
background levels within a reasonable timeframe unlikely.
• There are currently no available technologies that are known to be effective in restoring
DNAPL zones in complex heterogeneous geologic environments to drinking water
quality in a reasonable timeframe.
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• Restoration of the dissolved-phase plume in a reasonable timeframe is unlikely due to the
complex and heterogeneous nature of fractured bedrock.
For these reasons, a technical impracticability waiver of ARARs is warranted under NCP Section
300,430(f)(l)(ii)(C)(3) and EPA's Technical Impracticability Guidance for groundwater. The
groundwater zone over which the technical impracticability zone applies encompasses all areas in
the overburden and bedrock aquifers that are currently or conceivably could be impacted by
contamination emanating from the Site, as outlined on ROD Figure 8, The lateral boundaries of
the TI waiver zone extend to groundwater discharge areas to the east, south, and west of the
contaminant plumes, including Ball Brook and Hersig Brook to the east of the Site, and Allyn
Brook to the south of the Site. To the west of the Site, the TI waiver boundary coincides with the
wetland area in the vicinity of the ground elevation contour of 150 feet. This is a potential
groundwater discharge area to the west of the estimated western extent of contamination and
Maple Avenue. To the north, the TI boundary extends to encompass all residential wells that are
in the vicinity of the Superfund Site. The depth of the technical impracticability waiver zone is
considered to be at least the depth of the conceptual maximum extent of DNAPL, as depicted on
Figures 3.3-15 through 3.3-18 and on Figure 3.6-2 in the Technical Impracticability Evaluation
Report, or the depth of the deepest impacted well within the TI waiver zone.
Chemical-specific ARARs for groundwater at the Site include Connecticut Remediation
Standard Regulation (CT RSR) standards, including the Groundwater Protection Criteria
applicable to the GA groundwater underlying the Site, Surface Water Protection Criteria, and the
current and proposed Residential and Industrial/Commercial Volatilization Criteria (which have
not yet been promulgated and are "to be considered"). These criteria establish remediation
standards for groundwater, include numeric criteria for many contaminants, and provide separate
criteria for threats to human health and environmental receptors based on direct contact, as well
as migration via groundwater or volatilization. Chemical-specific ARARs also include federal
Maximum Contaminant Levels (MCLs) which govern the quality of drinking water provided by a
public water supply, and are relevant and appropriate requirements in establishing groundwater
remediation goals for private wells.
The compounds and their respective ARARs for which a technical impracticability waiver will
apply are presented in ROD Table 30. For compounds where no ARARs exist, risk-based goals
are presented. Human health risk-based goals are presented in Section 2 of the FS [M&E,
2005b], The compounds include all chlorinated solvents released at the Site and related
compounds, such as breakdown products and additives (i.e., 1,4-dioxane) as well as other co-
located compounds dissolved in groundwater such as PAHs, BTEX compounds, and several
metals (arsenic, copper, lead, mercury, vanadium, and zinc). The chlorinated compounds are the
most widespread and recalcitrant, the most likely to restrict the ability to restore groundwater,
and the primary risk drivers. There is little benefit to attempting to remediate co-located
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compounds, therefore the TI waiver will apply to all dissolved contaminants found at the Site.
No waiver of location-specific or action-specific ARARs is required for the Site.
J. DESCRIPTION OF ALTERNATIVES
This Section provides a narrative summary of each remedial alternative evaluated for the Site.
Alternatives were evaluated to address each contaminated medium or potential migration
pathway at each Study Area, A more complete, detailed presentation of each alternative is found
in Section 6.0 of the FS.
EPA evaluated remedial alternatives separately for the soil and soil vapor at the MMC Study
Area.
MMC Study Area - Soil
Alternative MMC S-l: No Action. The No Action alternative is developed as a baseline to which
other alternatives can be compared. No remedial action would be performed at the MMC Study
Area under the No Action Alternative, and only naturally occurring processes would be acting to
reduce contamination. This alternative is not protective of human health or the environment and
does not reduce on-site risk or contaminant mobility. The time to achieve response action
objectives (RAOs) for MMC Study Area soil under the No Action alternative would likely
exceed 100 years since some of the contaminants do not degrade and are not very mobile in soil
(PAHs and metals).
Estimated Period of Operation: None
Estimated Total Present Worth: None
Alternative MMC S-2: Containment. The major components of this alternative include:
* Pre-remedial study;
* Soil excavation and consolidation (scenario S-2B);
• Construction of a geomembrane cap;
• Environmental monitoring;
• Institutional controls; and
* Five-year reviews.
This alternative was developed as a containment alternative (contain waste on site while reducing
exposure) consisting of covering contaminated areas with a low permeability, geomembrane cap
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to limit water infiltration and subsequent migration of contaminants above the water table and
eliminate the direct exposure pathway to soil. Environmental monitoring would be included to
assess the impact on contaminant migration in groundwater and five-year Site reviews would be
conducted to evaluate the remedy per EPA guidance. Institutional controls would be
implemented to avoid site uses that would obstruct the usefulness of the cap. Under this scenario,
institutional controls would include obtaining an Environmental Land Use Restriction (ELUR) as
defined in the CT RSRs, to restrict activities that may disturb the engineered control.
Two scenarios for the containment option were considered for the detailed evaluation: capping
the entire Study Area assuming that most of the area contains soil with cxccedances of the PMC
(Scenario S-2A, approximately 3.3 acres) and capping the soil exceeding RBGs and direct
exposure criteria (Scenario S-2B, approximately 1 acre).
Estimated Period of Operation; Containment activities, <1 year; monitoring, 50 years
Estimated Total Present Worth; $1.3 million to $2.7 million
Alternative MMC S-3: Excavation and Off-site Disposal. The major components of this
alternative include:
• Pre-remedial study;
• Excavation support activities;
• Soil excavation and off-site disposal;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
Under this alternative, designated soil would be excavated and transported for off-site disposal.
Four variations of this alternative were evaluated in order to provide a range of cleanup levels for
comparison purposes:
* Scenario S-3A: Address current residential risk by excavating and removing soil from
the back of the adjacent residential property at 275 Main Street only (approximately 0.1
acres). No excavation would be performed on the MMC facility property.
* Scenario S-3B: Address current and future residential risk by excavating all areas of
concern with exeeedances of RBGs and those that also exceed CT RSR direct exposure
criteria (residential and industrial/commercial) (approximately 0.50 acres).
* Scenario S-3C: Address all risk, direct exposure concerns, and PMC by excavating all
areas of concern and sample locations indicating an exceedance of pollutant mobility
criteria in addition to areas described in S-3 A and S-3B above (approximately 0.75 acres).
* Scenario S-3D: Excavate the entire Study Area to address the possibility that all surface
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soils across the Study Area exceed one or more of the RAOs (RBGs and CT RSRs).
(approximately 3.3 acres)
Due to the uncertainty of depth of contamination in soils, cost for these options included intervals
of 0 to 2 feet and 2 to 4 feet deep. Depending on the depth to which excavation occurs,
institutional controls would include obtaining an ELUR as defined in the CT RSRs, to restrict
future activities that may result in exposure to Site-related contaminants. Environmental
monitoring may also be required for the implementation of each of these variations.
Estimated Period of Operation: Excavation and disposal, <1 year; monitoring, 50 years
Estimated Total Present Worth: $332,000 (S-3A 2' deep) to $7,6 million (S-3D to 4' deep)
Alternative MMC S-4; Soil Vapor Extraction. The major components of this alternative include:
• Pre-remedial study;
• Site preparation;
• Installation and operation of the SVE system;
• Treatment of off-gas;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a treatment option for soils containing VOCs and possibly
DNAPL. Under this soil vapor extraction (SVE) alternative, a vapor extraction system would be
installed to increase volatilization of VOCs from the soil, reducing the concentrations of VOCs
in soils and potentially reducing the mass of DNAPL over time. This alternative is also proposed
for addressing soil vapor. The SVE system would consist of a network of extraction wells
connected to aboveground piping and a vacuum blower with an appropriate technology for the
treatment of collected VOCs. It should be noted that surface soils with metals and PAHs
requiring remediation cannot be addressed by SVE alone, and may require excavation and
disposal or capping to achieve all RAOs. Environmental monitoring and five-year Site reviews
would be required to evaluate the progress of this remedy.
Estimated Period of Operation: SVE, 7 years; monitoring, 50 years
Estimated Total Present Worth: $505,000
MMC Study Area - Soil Vapor
Alternative MMC SV-1: Mo Action. The No Action alternative is developed as a baseline to
which other alternatives can be compared. No remedial action would be performed at the MMC
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Study Area under the No Action Alternative, and only naturally occurring processes would be
acting to reduce contamination. This alternative is not protective of human health or the
environment and does not reduce on-site risk or contaminant mobility. The time to achieve
RAOs for MMC Study Area soil under the No Action alternative would likely exceed 100 years.
Estimated Period of Operation: None
Estimated Total Present Worth: None
Alternative MMC SV-2: Excavation and Off-site Disposal. The major components of this
alternative include:
• Pre-remedial study;
• Excavation support activities;
• Soil excavation and off-site disposal;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a source control remedy. Under this alternative, all accessible
VOC-impacted source area materials (soil exceeding PRGs) will be excavated to a depth of four
or eight feet and transported for off-site disposal, thereby eliminating the source of the soil vapor
concerns. The soil vapor source is likely from VOCs and potential DNAPL located in soils
below the former loading dock and degreasers. Institutional controls and environmental
monitoring may be required for the implementation of each of these variations.
Estimated Period of Operation: Excavation and disposal, <1 year; monitoring, 50 years
Estimated Total Present Worth: $2,1 million to $3.8 million
Alternative MMC SV-3: Soil Vapor Extraction. The major components of this alternative
include:
• Pre-remedial study;
• Site preparation;
• Installation and operation of the SVE system;
• Treatment of off-gas;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
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This alternative was developed as a treatment option for soil vapor that reduces concentrations of
VOCs in soil over time. SVE technology can also reduce the mass of DNAPL residing in
subsurface soils, as described under MMC Alternative S-4.
Estimated Period of Operation: 7 years
Estimated Total Present Worth; $494,000
DMC Study Area - Overburden Groundwater
Alternative PMC GW-1: No Action, The No Action alternative is developed as a baseline to
which other alternatives can be compared. No remedial action would be performed at the DMC
Study Area under the No Action Alternative, and only naturally occurring processes would be
acting to reduce contamination. This alternative is not protective of human health or the
environment and does not reduce on-site risk or contaminant mobility. The time to achieve
RAOs for DMC Study Area groundwater under natural conditions would likely exceed 100
years.
Estimated Period of Operation; None
Estimated Total Present Worth: None
Alternative DMC GW-2: Groundwater Extraction - Hydraulic Containment. The major
components of this alternative include:
• Pre-remedial study and treatability test;
• Groundwater extraction;
• Ex-situ groundwater treatment;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews,
This alternative consists of extracting groundwater within or just downgradient from the hot spot
areas (high concentrations of VOCs, and possible DNAPL areas) by utilizing pumping methods
from extraction wells and/or a collection trench. Such action will manage the migration of
contaminated groundwater from the overburden laterally and vertically to the bedrock. Collected
groundwater would be treated in an on-site treatment system. Environmental monitoring would
be included to assess contaminant migration and five-year Site reviews would be conducted to
evaluate the remedy per EPA guidance. Institutional controls, in the form of ELURs, would
prevent the use of overburden groundwater as drinking water or for other domestic purposes,
prevent construction of buildings without the necessary controls to minimize potential inhalation
risks, prohibit residential activities, and prohibit soil disturbance and exposure to groundwater
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via intrusive activities without a plan to protect against groundwater contact in uncontrolled
conditions. As a hydraulic containment alternative, it is anticipated that this alternative would
take at least 100 years to meet all RAOs, including the restoration of overburden groundwater to
background concentrations based on Natural Attenuation Modeling.
Estimated Period of Operation: 100 years
Estimated Total Present Worth: $4.9 million
Alternative PMC GW-3: Multi-Phase Extraction, The major components of this alternative
include:
• Pre-remedial study and treatability test;
• Multi-phase extraction;
• Ex-situ groundwater treatment;
• Collection and treatment of off-gas;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a more aggressive treatment option for the groundwater plume
containing VOCs than hydraulic containment. Under this alternative, an extraction system would
be installed (or the existing system modified) to increase volatilization of VOCs from the
saturated and unsaturated zone, and extract groundwater for treatment. Collected groundwater
and vapor released from the groundwater (and soils) would be collected and treated, thus
managing the migration of contaminants and improving the time for restoration. Environmental
monitoring would be implemented to assess the progress and success of this remedy. Five-year
reviews would be required to assess the remedy in accordance with EPA guidance. Institutional
controls, in the form of ELURs, would prevent the use of overburden groundwater as drinking
water or for other domestic purposes, prevent construction of buildings without the necessary
controls to minimize potential inhalation risks, prohibit residential activities, and prohibit soil
disturbance and exposure to groundwater via intrusive activities without a plan to protect against
groundwater contact in uncontrolled conditions. This alternative uses a more aggressive
extraction strategy than Alternative GW-2, and it is assumed that the time to meet all RAOs will
be shorter than that anticipated for the hydraulic containment alternative. A relative period of
time for treatment was assumed to be 50 years.
Estimated Period of Operation: 50 years
Estimated Total Present Worth: $4.9 million
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Alternative PMC GW-4: Irt-situ Chemical Oxidation, The major components of this alternative
include:
• Pre-remedial study and treatability test;
• Installation of injection wells;
• Injection of oxidant;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as an in-situ treatment option for groundwater containing VOCs
and possibly DNAPL. Multiple injections of oxidation chemicals into the VOC hot spots would
be conducted, using materials that break down contaminants to nonhazardous byproducts such as
salt, water, and carbon dioxide and deplete the source zone mass. Environmental monitoring
would be implemented to assess the progress and success of this remedy, including the
restoration of the groundwater plume. Five-year reviews would be required to assess the remedy
in accordance with EPA guidance. Institutional controls, in the form of ELURs, would prevent
the use of overburden groundwater as drinking water or for other domestic purposes, prevent
construction of buildings without the necessary controls to minimize potential inhalation risks,
prohibit residential activities, and prohibit soil disturbance and exposure to groundwater via
intrusive activities without a plan to protect against groundwater contact in uncontrolled
conditions. This alternative uses a more aggressive remediation strategy than Alternative GW-2,
and it is assumed that the time to meet all RAOs will be shorter than that anticipated for the
hydraulic containment alternative. A relative period of time for treatment was assumed to be 50
years.
Estimated Period of Operation: Oxidant injection, 5 years; monitoring 50 years
Estimated Total Present Worth: $1.8 million
Alternative PMC GW-5: Soil Excavation. The major components of this alternative include:
» Pre-remedial study;
• Excavation support activities;
• Soil excavation and off-site disposal;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a source control, or removal, remedy. The removal of sources
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of contamination will likely reduce the concentrations in groundwater, as well as significantly
reduce the risk posed to construction workers through direct contact of contaminants in
groundwater. Under this alternative, all accessible hot spot areas (including DNAPL if
encountered) will be excavated and transported for off-site disposal. A particular challenge to
excavating soil from this Study Area is that it is likely that contamination (DNAPL) has
penetrated the unsaturated soil (vadose zone), thus, a deep excavation would be required to
remove all possible source materials (up to 20 feet deep in some locations with an area of
between 0.10 - 0.20 acres for hot spot excavation, with a worst-case estimate of 0.55 acres to
excavate all contaminated soils within the 1,000 ppb TCE contour). The presence of buildings
and utilities present challenges as well, and it is possible that contaminated soils exist under the
buildings.
The elimination of hot spot areas through excavation and off-site disposal of contaminated soils
is the alternative that provides the greatest degree of overall protection of human health that is
technically practicable at this study area. This alternative is the most reliable option if all
contaminated soils are removed, and provides for a shorter timeframe for remedial action, which
is desired to reduce the potential for human exposure. Excavation is expected to significantly
reduce the risk posed to construction workers through direct contact of contaminated
groundwater immediately upon completion. Long-term monitoring of groundwater would be
implemented upon removal of source materials to demonstrate the effectiveness and
protectiveness of the remedy; complete reduction of contaminants in overburden groundwater is
expected to take up to 50 years. Five-year reviews would be required to assess the remedy in
accordance with EPA guidance. Institutional controls, in the form of ELURs, would prevent the
use of overburden groundwater as drinking water or for other domestic purposes, prevent
construction of buildings without the necessary controls to minimize potential inhalation risks,
prohibit residential activities, and prohibit soil disturbance and exposure to groundwater via
intrusive activities without a plan to protect against groundwater contact in uncontrolled
conditions.
Estimated Period of Operation: Excavation and disposal, <1 year; monitoring, 50 years
Estimated Total Present Worth: $1.9 - $3.2 million for hot spot; $8.1 million worst case
Site-wide Groundwater Study Area - Source Zone
Alternative SZ-1: No Action. The No Action alternative is developed as a baseline to which
other alternatives can be compared. Under this alternative, no remedial action is taken, and as a
result only naturally occurring processes would act to reduce contamination. The time to achieve
RAOs for groundwater under the No Action alternative is equivalent to projected attenuation of
contamination under natural conditions, which is likely to be much greater than 100 years.
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Estimated Period of Operation; None
Estimated Total Present Worth: None
Alternative SZ-2: Groundwater Extraction - Hydraulic Containment, The major components of
this alternative include:
• Groundwater extraction;
• Ex-situ groundwater treatment;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a containment alternative to manage the migration of
contaminated groundwater. The alternative consists of extracting groundwater from the source
zones (high concentrations of VOCs and possibly DNAPL, if encountered) using new or existing
extraction wells. Such action will limit the migration of contaminated bedrock groundwater.
Extracted groundwater would be piped to a centralized treatment system. Groundwater would be
treated and discharged to surface waters. Five-year Site reviews would be conducted to evaluate
the remedy per EPA guidance. Institutional controls would also be implemented to avoid Site
uses of contaminated groundwater until all RAOs are met. Under this scenario, institutional
controls would include obtaining an ELUR, as defined in the CT RSRs, to restrict use of
groundwater for drinking or domestic purposes.
Estimated Period of Operation: 100 years
Estimated Total Present Worth: $8.7 million
Site-wide Groiindwater Study Area - Dissolved Plume
Alternative DP-1: No Action. The No Action alternative is developed as a baseline to which
other alternatives can be compared. Under this alternative, no remedial action is taken. The time
to achieve RAOs for groundwater under the No Action alternative is equivalent to projected
attenuation of contamination under natural conditions, which is likely to be greater than 100
years.
Estimated Period of Operation: None
Estimated Total Present Worth: None
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Alternative DP-2: Monitored Natural Attenuation. The major components of this alternative
include:
• Installation of bedrock groundwater monitoring wells;
• Environmental monitoring;
• Institutional controls;
• Five-year reviews.
This alternative was developed as a treatment option for dissolved phase contaminated
groundwater, It includes monitoring the dissolved phase groundwater plumes for attenuation and
five-year Site reviews to evaluate the effectiveness of the remedy. Institutional controls in the
form of ELURs or a local ordinance would be implemented to avoid Site uses of contaminated
groundwater.
Estimated Period of Operation: >100 years
Estimated Total Present Worth: $1.9 million
Alternative DP-3: Groundwater Extraction - Restoration. The major components of this
alternative include:
• Groundwater extraction;
• Ex-situ groundwater treatment;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a pump and treat option. Extracted groundwater would be
piped to a centralized treatment system. Groundwater would be treated and discharged to surface
waters. Five-year Site reviews would be required to evaluate the remedy in accordance with EPA
guidance. Institutional controls in the form of ELURs or a local ordinance would also be
implemented to avoid Site uses of contaminated groundwater.
Estimated Period of Operation: 50 years
Estimated Total Present Worth: $8.5 million
Alternative DP-6: Monitoring. The major components of this alternative include:
• Installation of bedrock groundwater monitoring wells;
• Environmental monitoring;
• Institutional controls;
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• Five-year reviews.
This alternative was developed as a limited action alternative. No remedial actions are proposed.
It consists of monitoring the Site-wide Groundwater Study Area for a period of up to ten years,
including source zone and dissolved plume groundwater to determine whether the plume is
migrating or attenuating. Institutional controls in the form of ELURs or a local ordinance would
be implemented to avoid Site uses of contaminated groundwater. It is also assumed that an
alternate water supply alternative would be implemented in conjunction with this action.
Estimated Period of Operation: 10 years
Estimated Total Present Worth: $434,000
Site-wide Groundwater Study Area - Alternate Water Supply
Alternative AWS-1: No Action. The No Action alternative is developed as a baseline to which
other alternatives can be compared. Under this alternative, no alternate water supply is provided.
The time to achieve RAOs for groundwater under the No Action alternative is equivalent to
projected attenuation of contamination under natural conditions, which is likely to be greater than
100 years.
Estimated Period of Operation: None
Estimated Total Present Worth: None
Alternative AWS-2: Connection to Middletown Water Distribution System. The major
components of this alternative include:
• Extend the existing Middletown water system;
• Construct water distribution system within Study Area;
• Connect residences to new distribution system;
• Institutional controls; and
• Five-year reviews.
Under this alternative, the existing Middletown Water Distribution System would be extended
along Route 17 south to residences within the Study Area providing potable water to all impacted
constituents. It is assumed 85 service connections would be made to the water mains. The
proposed distribution system is looped within the Study Area in order to service all impacted
constituents as well as to address water quality and pressure considerations. This alternative,
combined with institutional controls on existing groundwater use, will prevent exposure to
contaminated groundwater. Five-year Site reviews would be required to evaluate the remedy in
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accordance with EPA guidance. Implementation of this alternative will require the development
of administrative and operation and maintenance functions. Administrative responsibilities will
include billing, customer service, and regulatory compliance. Operation and maintenance of the
water supply and distribution components, including regulatory compliance, will be necessary.
Estimated Period of Operation: Construction <1 year; operation and maintenance, 50 years
Estimated Total Present Worth: $7.0 million
Alternative AWS-3: Development of New Groundwater Source and Water Distribution System.
The major components of this alternative include:
• Develop new potable groundwater source;
• Construct water distribution system within Study Area;
• Connect residences to new distribution system;
• Institutional controls; and
• Five-year reviews.
A new groundwater source would be developed in close proximity to the Study Area and a
distribution system would be installed within the Study Area under this alternative. This new
source and distribution system would provide potable water to all impacted constituents. It is
assumed 85 service connections would be made to the water mains. This alternative, combined
with institutional controls on existing groundwater use, will prevent exposure to contaminated
groundwater. Five-year Site reviews would be required to evaluate the remedy in accordance
with EPA guidance. Implementation of this alternative will also require the development of
administrative and operation and maintenance functions. Administrative responsibilities will
include billing, customer service, and regulatory compliance. Operation and maintenance of the
water supply and distribution components, including regulatory compliance, will also be
necessary.
When EPA evaluated this alternative in the Feasibility Study, adequate data was not available to
determine a definitive well source in proximity to the Study Area, therefore the Feasibility Study
presents this alternative to include installation and development of a new groundwater supply,
assumed to be upgradient to the north and east of the Study Area, although a specific supply
location was not investigated. As outlined in the Proposed Plan, there are a variety of existing
well locations that could possibly be further investigated as potential sources, including but not
limited to the Durham Fairgrounds wells, the DMC cooling water well, a well at the Parsons
Manufacturing Company, or other potential well locations within the Town of Durham. The
Durham Fairgrounds wells to the south west of the Study Area are currently being investigated
by the Town of Durham as a potential source for the Durham Center water system. Preliminary
results of a 72-hour pump test conducted in July 2005 indicated a maximum capacity of 170
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gallons per minute for simultaneous pumping of the two Fairgrounds wells. The DMC cooling
water well (well #2) may have capacity to provide an adequate source of water for the Study
Area, although there is no information available to confirm this. A well located at the Parsons
Manufacturing Company may reportedly have enough capacity as well. The Parsons and DMC
wells are both currently contaminated, however, and would require treatment prior to distribution
for drinking water purposes. The need for treatment would increase the cost estimate for this
alternative. Federal and state agencies may also prefer clean water supply options over
contaminated sources.
Estimated Period of Operation: Construction <1 year; operation and maintenance, 50 years
Estimated Total Present Worth: $6.6 million
Alternative AWS-4: Point of Use Treatment. The major components of this alternative include:
• Continued operation of residential groundwater pumps
• Ex-situ treatment at each impacted residence;
• Long-term monitoring;
• Five-year reviews.
Under this alternative, ex-situ point of use treatment systems would be installed at each impacted
location. Systems would be designed to address specific contaminants of concern at each
location. Treatment of the dissolved phase contaminated groundwater at each impacted location
would provide some level of restoration of the groundwater as well as provide an alternate water
supply. Long-term groundwater monitoring would be required to both evaluate the effectiveness
of groundwater restoration as well as ensure the federal and state regulatory requirements related
to drinking water supply are met. Five-year Site reviews would be required to evaluate the
remedy in accordance with EPA guidance.
Estimated Period of Operation: Implementation <1 year; operation & maintenance, 50 years
Estimated Total Present Worth: $7.2 million
K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that at a minimum EPA is required to
consider in its assessment of alternatives. Building upon these specific statutory mandates, the
NCP articulates nine evaluation criteria to be used in assessing the individual remedial
alternatives.
A detailed analysis was performed on the alternatives using the nine evaluation criteria in order
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to select a Site remedy. The following is a summary of the comparison of each alternative's
strength and weakness 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 adequate protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering controls, or
institutional controls,
2. Compliance with applicable or relevant and appropriate requirements f ARARs) addresses
whether or not a remedy will meet all federal environmental and more stringent state
environmental and facility siting standards, requirements, criteria or limitations, unless a
waiver is invoked.
Primary Balancing Criteria. The following five criteria are utilized to compare and evaluate the
elements of one alternative to another that meet the threshold criteria:
3. Long-term effectiveness and permanence addresses the criteria that are utilized to assess
alternatives for the long-term effectiveness and permanence they afford, along with the
degree of certainty that they will prove successful.
4. Reduction of toxicity, mobility, or volume through treatment addresses the degree to
which alternatives employ recycling or treatment that reduces toxicity, mobility, or
volume, including how treatment is used to address the principal threats posed by the
Site.
5. Short term effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed during the
construction and implementation period, until cleanup goals are achieved.
6. Implementabilitv addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
7. Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as
present-worth costs.
option.
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Modifying Criteria. The modifying criteria are used as the final evaluation of remedial
alternatives, generally after EPA has received public comment on the RI/FS and Proposed Plan:
8. State acceptance addresses the state's position and key concerns related to the preferred
alternative and other alternatives, and the state's comments on ARARs or the proposed
use of waivers.
9. Community acceptance addresses the public's general response to the alternatives
described in the Proposed Plan and RI/FS report.
Following the detailed analysis of each individual alternative, a comparative analysis, focusing
on the relative performance of each alternative against the nine criteria, was conducted. This
comparative analysis can be found in Tables 7,1-1 through 7.6-1 of the FS.
The section below presents the nine criteria and a brief narrative summary of the alternatives and
the strengths and weaknesses according to the detailed and comparative analysis. Evaluation for
each criteria is done by Study Area. Only those alternatives which satisfied the first two
threshold criteria were balanced and modified using the remaining seven criteria.
1. Overall Protection of Human Health and the Environment.
Overall protection of human health and the environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment, engineering controls, or institutional
controls.
MMC Study Area: The no action alternatives for soil and soil vapor (S-l and SV-1) would be
the least protective of human health and the environment because there would be no cleanup of
the site and unacceptable risks to human health would remain.
The Containment Alternative (S-2), would provide overall protection of human health and the
environment by preventing direct exposure to materials that present an unacceptable risk with the
use of an impermeable cap and institutional controls; ongoing maintenance of the cap would be
required to ensure continued protectiveness. The Excavation and Off-site Disposal Alternative
for soil (S-3), would also provide overall protection of human health risks by preventing direct
exposure to materials by removing contaminated soil. Both of these alternatives would provide
some measure of protection, but may not fully address inhalation risks from soil vapor
contamination. Institutional controls would be required to restrict use. The Excavation
Alternative for soil vapor (SV-2), provides for deeper excavation, just in the areas with soil vapor
contamination, to specifically address this issue. The Soil Vapor Extraction Alternatives for soil
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and soil vapor respectively (S-4 and SV-3), would effectively eliminate risks to human health
from direct contact with TCE in soil and inhalation of TCE in soil vapor. SVE alone, however,
cannot address current and future risks due to PAHs and metals in soil.
Combinations of the above alternatives were contemplated to address unacceptable risks from
contaminants in both soil and soil vapor. Combining the Containment (S-2) and Soil Vapor
Extraction (SV-3) alternatives would prevent direct exposure to human health and address
inhalation risk, although the cap would require ongoing maintenance to ensure continued
protectiveness. Combining Excavation alternatives for both soil and soil vapor (S-3 and SV-2),
would address all contaminants. By combining Excavation for soil (S-3) and Soil Vapor
Extraction (SV-3), SVE would be implemented prior to excavation to reduce the volume and
depth of VOC contamination requiring excavation. The latter two combinations (S-3 with SV-2,
and S-3 with SV-3) provide the greatest degree of overall protection.
DMC Study Area: The No Action Alternative (GW-1) would be the least protective of human
health and the environment because there would be no cleanup of the site and unacceptable risks
to human health would remain.
For all of the other alternatives contemplated for this Study Area, the possible presence of
DNAPL and possible contamination under buildings and utilities increases the expected
timeframe for reduction in concentrations. All alternatives are expected to leave some residual
DNAPL in overburden, as it is not technically practicable to clean up this DNAPL. Institutional
controls are required in conjunction with these alternatives to prevent construction workers from
coming into contact with contaminated groundwater, and to prevent future site uses that do not
address volatilization issues.
The Hydraulic Containment Alternative (GW-2) would protect human health by extracting and
treating overburden groundwater to mitigate the risk posed to construction workers through
direct contact and to a future resident through volatilization of contaminants from groundwater.
However, reduction of contaminants is expected to occur over a long period of time (at least 100
years). The Multi Phase Extraction Alternative (GW-3) is expected to have similar results as
GW-2, except that with the addition of a vapor extraction component, potential contaminant
sources in the saturated zone are also reduced, and the timeframe for reduction of contaminants
may be reduced to 50 years. The In-situ Chemical Oxidation Alternative (GW-4) is expected to
reduce contaminant mass, volume and concentration through injection of an oxidizing agent into
wells to treat overburden groundwater; however, the timeframe for reduction of contaminants is
assumed to be 50 years due to low permeability of overburden.
The Excavation and Off-site Disposal Alternative (GW-5) would protect human health by
excavating contaminated soil in hot spot areas to significantly reduce the risk posed to
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construction workers through direct contact to contaminants from groundwater. Elimination of
hot spot areas provides the greatest degree of overall protection that is technically practicable at
this study area, and provides for a shorter timeframe for remedial action, which is desired to
reduce the potential for human exposure. Excavation is expected to significantly reduce the risk
posed to construction workers through direct contact of trichloroethcne in overburden
groundwater immediately upon completion, although long-term monitoring is still required as
reduction of contaminants in overburden groundwater is expected to take up to 50 years. As
stated above, the excavation of hot spot areas will also remove a source of contamination to
groundwater.
Site-wide Groundwater Study Area - Alternate Water Supply: The No Action Alternative
(AWS-1) would be the least protective of human health and the environment because
unacceptable risks to human health would not be addressed. The Connection to Middletown
Water Distribution System Alternative (AWS-2), and Development of New Groundwater Source
and Water Distribution System Alternative (AWS-3), would both protect human health by
providing an alternate water supply for all impacted constituents. These alternatives provide the
greatest protection of human health by eliminating all current and future risk. The Point of Use
Treatment Alternative (AWS-4), protects human health by filtering and/or otherwise treating well
water prior to use, and providing contingencies for bottled water should point of use treatment
fail. Institutional controls are required for alternatives AWS-2, AWS-3 and AWS-4 to ensure
continued protectiveness by preventing use of contaminated groundwater.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP); No Action
Alternatives (SZ-1 and DP-1), implemented on their own, would be the least protective of human
health and the environment because unacceptable risks to human health would not be addressed.
For the source zone, Groundwater Extraction - Hydraulic Containment Alternative (SZ-2), would
increase human health protection by reducing the concentration of contaminants in the associated
plume area, although no active cleanup of groundwater is contemplated (containment is the only
goal). There is no alternative that can fully achieve cleanup goals in the source zone in a
reasonable timeframe.
For the dissolved plume, Monitored Natural Attenuation Alternative (DP-2), no reduction in risk
occurs if implemented on its own. Implemented in conjunction with provision of an alternate
water supply and institutional controls, human health protection is increased. Groundwater
Extraction - Restoration Alternative (DP-3), would increase human health protection, but is not
likely to achieve cleanup goals for 50 years. This alternative is not protective if implemented
alone, but increases human health protection if implemented in conjunction with provision of an
alternate water supply and institutional controls. Monitoring of the Dissolved Plume Alternative
(DP-6) uses a monitoring network to ensure that the plume does not migrate to areas not affected
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by groundwater contamination. Again, implemented alone, no reduction of risk occurs.
Alternatives were combined to include Monitoring of the Dissolved Plume (DP-6), No Action for
the Source Zone (SZ-l), and Groundwater Extraction for Hydraulic Containment Alternative
(SZ-2) specifically provided as a contingency, in the event that groundwater plume migration
does occur. In conjunction with the provision of an alternative water supply as described in
alternatives AWS-2 or AWS-3, this combination is protective of human health.
2. Compliance with Applicable or Relevant and Appropriate Requirements.
Section 121(d) of CERCLA requires that remedial actions at CERCLA sites at least attain legally
applicable or relevant and appropriate federal and state requirements, standards, criteria and
limitations which are collectively referred to as ARARs, unless such ARARs are waived under
CERCLA 121(d)(4).
Applicable requirements are those substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law that specifically address hazardous substances,
the remedial action to be implemented at the Site, the location of the Site or other circumstances
present at the Site. Relevant and appropriate requirements are those substantive environmental
protection requirements, criteria, or limitations promulgated under federal or state law which,
while not applicable to the hazardous materials found at the Site, the remedial action itself, the
Site location or other circumstances at the Site, nevertheless address problems or situations
sufficiently similar to those encountered at the Site that their use is well-suited to the Site.
MMC Study Area: Alternatives S-l and SV-1, No Action for soil and soil vapor, would not
comply with chemical-specific ARARs applicable to the Site. Soil vapor extraction alternatives
alone, S-4 and SV-3, would not meet all chemical-specific ARARs. The excavation alternatives,
S-3 for soil and SV-2 for soil vapor, if implemented separately, may not meet all chemical
specific ARARs for the entire depth of soil.
Alternatives S-2, Containment, and all three combinations of alternatives (S-3 and SV-2,
Excavation for both Soil and Soil Vapor; S-3 Soil Excavation and SV-3 Soil Vapor Extraction;
S-2 Containment and SV-3 Soil Vapor Extraction) would meet all chemical, location, and action-
specific ARARs if properly implemented.
DMC Study Area: Alternative GW-1, No Action, would not comply with chemical-specific
ARARs applicable to the Site, Ail other alternatives, GW-2, GW-3, GW-4 and GW-5, will all
meet RAOs over time, ranging from up to 50 years for GW-3, GW-4, and GW-5, to 100 years for
GW-2. Excavation pursuant to alternative GW-5 is expected to significantly reduce the risk
posed to construction workers through direct contact of contaminated groundwater immediately
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upon completion, although long-term monitoring is still required as reduction of contaminants in
overburden groundwater is expected to take up to 50 years. None of the alternatives for the
DMC Study Area are expected to meet chemical-specific ARARs relating to groundwater
restoration, A technical impracticability waiver is proposed for ARARs that would normally
require cleanup of the groundwater, These alternatives will all meet location and action-specific
ARARs if properly implemented.
Site-wide Groundwater Study Area - Alternate Water Supply: Alternative AWS 1, No
Action, would not comply with chemical-specific ARARs. Alternatives AWS-2, AWS-3 and
AWS-4 will all achieve RAOs and chemical-specific ARARs as they relate to water supply only
(no actual cleanup of Site-wide groundwater occurs with any of these alternatives). These
alternatives will comply with location and action-specific ARARs if properly implemented.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP); No action
alternatives SZ-1 and DP-1 do not comply with chemical-specific ARARs. Alternative SZ-2
would comply with chemical-specific ARARs, but only as they relate to treatment of extracted
groundwater and not for groundwater restoration; this alternative does not meet RAOs or
chemical-specific ARARs within the source zone. Alternative DP-2 may achieve chemical-
specific ARARs in the dissolved plume, but likely in a timeframe greater than 100 years; this
alternative would not achieve RAOs or chemical-specific ARARs within the source zone.
Alternative DP-3 may achieve chemical-specific ARARs in a timeframe greater than 50 years in
the dissolved plume, however, this alternative would not achieve RAOs or chemical-specific
ARARs within the source zone. Alternative DP-6, implemented alone, does not comply with
chemical-specific ARARs.
Alternatives were combined to include DP-6, Monitoring of the Dissolved Plume, Alternative
SZ-1, No Action for the Source Zone, and Alternative SZ-2, Groundwater Extraction for
Hydraulic Containment (SZ-2 is specifically provided as a contingency, in the event that
groundwater plume migration does occur), In conjunction with the provision of an alternative
water supply as described in alternatives AWS-2 or AWS-3, this combination achieves RAOs
and chemical-specific ARARs as they apply to water supply only. A technical impracticability
waiver is proposed for ARARs that would normally require cleanup of the groundwater.
3. Long-Term Effectiveness and Permanence
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.
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MMC Study Area: Alternatives S-l and SV-1, No Action for soil and soil vapor, do not
provide any long-term effectiveness or permanence. Soil vapor extraction alternatives alone, S-4
and SV-3, would not remove risks posed by chemicals other than VOCs, and would not address
all human health risks. The excavation alternatives, S-3 for soil and SV-2 for soil vapor, if
implemented separately, would provide long-term effectiveness and permanence, but only for
specific contaminants; residual risks for other contaminants may remain. Alternative S-2
Containment would provide long-term effectiveness and permanence, provided the cap was
regularly maintained.
Combining S-2 Containment and SV-3 Soil Vapor Extraction would provide long-term
effectiveness and permanence, provided the cap was regularly maintained. The remaining
combinations of alternatives (S-3 and SV-2, Excavation for both Soil and Soil Vapor, and S-3
Soil Excavation and SV-3 Soil Vapor Extraction) would provide the most permanence and long-
term effectiveness.
DMC Study Area: Alternative GW-1, No Action, does not provide any long-term effectiveness
or permanence. Alternatives GW-2, GW-3, GW-4 and GW-5, will all provide some measure of
long-term effectiveness by reducing concentrations of VOCs in both the hot spot areas and the
associated plume. However, the likely presence of DNAPL, including residual DNAPL within
till fractures, creates the possibility of residual contamination being available for dissolution
many years into the future. The alternatives are expected to provide adequate and reliable
controls. The possible exception is alternative GW-4, in-situ chemical oxidation, due to the
potential for mobilization of metals with certain oxidant and soil types. Alternative GW-5 is the
most reliable option if all contaminated soils are removed.
Site-wide Groundwater Study Area - Alternate Water Supply: Alternative AWS-1, No
Action, does not provide any long-term effectiveness or permanence. Under alternatives AWS-2,
AWS-3 and AWS-4, residual risks will remain at the Site due to contaminated groundwater.
AWS-2 and AWS-3 provide a permanent hookup to an alternate water supply, which would
remove the risk to human health from contaminated groundwater.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP): No action
alternatives SZ-1 and DP-1 do not provide any long-term effectiveness or permanence.
Alternative SZ-2 would reduce concentrations of VOCs in both the source zone and indirectly in
the dissolved plume, but residual risk from DNAPL will remain at the Site for many years into
the future. This alternative may effectively manage migration and would require a long term
monitoring program, regular maintenance, and institutional controls. Under alternative DP-2,
residual risk remains due to contaminated groundwater for a timeframe likely greater than 100
years. Alternative DP-3 may minimize migration of contaminated water and reduce the size of
the dissolved plume, but residual risk remains for a timeframe likely greater than 50 years.
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Alternative DP-6, implemented alone, includes no controls to reduce contaminant levels.
Alternatives were combined to include DP-6, Monitoring of the Dissolved Plume, Alternative
SZ-1, No Action for the Source Zone, and Alternative SZ-2, Groundwater Extraction for
Hydraulic Containment, specifically provided as a contingency, in the event that groundwater
plume migration does occur. In conjunction with the provision of an alternative water supply as
described in alternatives AWS-2 or AWS-3, as well as a technical impracticability waiver for
both the source zone and dissolved plume areas, this combination achieves long-term
effectiveness and permanence for protection of human health and the environment.
4. Reduction of Toxicity. Mobility, or Volume Through Treatment
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.
MMC Study Area: The no action alternatives, S-l and SV-1, do not reduce toxicity, mobility,
or volume through treatment. Containment alternative S-2 may reduce mobility, although not
through treatment. This alternative would reduce the mobility of the chemical contaminants that
are placed beneath the cap by preventing water from coming into contact with contaminants.
Excavation alternatives S-3 and SV-2 will reduce toxicity, as contaminants above cleanup levels
will be removed from the site; this will greatly reduce mobility and volume, but not through
treatment (although some materials shipped off-site may require treatment prior to disposal).
Soil vapor extraction alternatives, S-4 and SV-3, will reduce toxicity and the overall mass of
VOCs in soil through treatment. SVE is an irreversible treatment process for VOCs, by which
extracted VOCs are collected on carbon and destroyed during carbon regeneration. Similarly,
any alternative combination that includes SVE will satisfy this criteria.
DMC Study Area; Alternative GW-1, No Action, does not reduce toxicity, mobility, or volume
through treatment. Alternatives GW-2, GW-3, and GW-4, will all provide some reduction of
toxicity, mobility and volume through treatment, however, residual contamination in
groundwater will likely be available as DNAPL. Alternative GW-2 will treat extracted
groundwater to remove potential DNAPL in a separation process, remove VOCs with air
stripping and adsorption, and remove metals by precipitation. For Alternative GW-2, a
treatability study would determine if advanced oxidation would be necessary for treatment of 1,4-
dioxane or other contaminants that are resistant to stripping. Alternative GW-3 is similar to GW-
2, but adds vapor phase extraction. Alternative GW-4 would involve installation of wells
throughout the area for injection of an oxidizing agent into the ground; the oxidizing agent would
permanently break down contaminants to non-hazardous products. Excavation alternative GW-5
will reduce toxicity, as hot spot contaminants will be removed from the site; this will additionally
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greatly reduce mobility and volume, but not through treatment (although some materials shipped
off-site may require treatment prior to disposal).
Site-wide Groundwater Study Area - Alternate Water Supply: None of the alternatives
reduce toxicity, mobility, or volume through treatment. Natural attenuation may eventually
reduce the toxicity and volume of contaminants in groundwater. AWS-4 provides some
treatment of contaminated groundwater through the use of filters; however, this treatment is
incidental and for water supply purposes only; this alternative does not provide active
remediation of contaminated groundwater.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP): No action
alternatives SZ-1 and DP-1 do not reduce toxicity, mobility, or volume through treatment.
Alternative SZ-2 would reduce toxicity, mobility and volume through treatment of VOCs,
SVOCs and metals in both the source zone and indirectly in the dissolved plume; extracted
groundwater would be treated to remove DNAPL in separation process, and treated via
precipitation and air stripping processes. Advanced oxidation would be required to remove 1,4-
dioxane. However, residual contamination in groundwater is expected to persist. Under
Alternative DP-2, natural attenuation would eventually reduce concentrations of contaminants in
groundwater, but no active treatment is contemplated and residual contamination is expected for
a timeframe likely greater than 100 years. Alternative DP-3 would reduce toxicity, mobility and
volume through treatment of VOCs, SVOCs and metals in the dissolved plume via groundwater
extraction and treatment, although residual contamination is expected to remains for a timeframe
likely greater than 50 years. Alternative DP-6, implemented alone, provides no active treatment,
although natural attenuation would eventually reduce concentrations of contaminants in
groundwater.
Alternatives were combined to include DP-6, Monitoring of the Dissolved Plume, Alternative
SZ-1, No Action for the Source Zone, and Alternative SZ-2, Groundwater Extraction for
Hydraulic Containment, specifically provided as a contingency, in the event that groundwater
plume migration does occur. These alternatives would be implemented in conjunction with the
provision of an alternative water supply as described in alternatives AWS-2 or AWS-3, as well as
a technical impracticability waiver for both the source zone and dissolved plume areas. No
active treatment is contemplated, unless the contingency of SZ-2 for containment is
implemented.
5. Short-Term Effectiveness
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.
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MMC Study Area: Because the no action alternatives, S-l and SV-1, would not require any
activities to be conducted, there would be no short-term impacts to the community or on-site
workers. The no action alternatives do not reduce risks to human health. Containment
alternative S-2 would have some short-term impacts to the community from the construction
activities, and dust control measures and air monitoring would be required. Installation of a cap
would take less than one year for construction. Excavation alternatives S-3 and SV-2 would also
have some short-term impacts to the community from the construction activities, and similar dust
control measures and air monitoring would be required. Construction activities related to
excavation and off-site disposal would take less than one year. In soil vapor extraction
alternatives S-4 and SV-3, air emissions would be monitored to ensure there are no impacts to
the community, and monitoring would be required during construction for worker protection.
SVE alone would meet response action objectives within 5 to 7 years for VOCs alone, but would
not address risks from other chemicals.
Combining S-2 Containment and SV-3 Soil Vapor Extraction may increase the efficiency of
VOC removal and therefore short-term effectiveness. No additional short term impacts to the
community or construction workers are contemplated for the remaining combinations of
alternatives.
DMC Study Area: The no action alternative GW-1 doesn't require any activities to be
conducted, therefore there would be no short-term impacts to the community or on-site workers;
this alternative does not reduce risks to human health. Impacts to the community by alternatives
GW-2 and GW-3 will be limited to the construction of a treatment facility. Risks may not be
adequately addressed for 100 years for GW-2 and 50 years for GW-3. Minimal risk is posed to
the community by alternative GW-4; risks may not be adequately addressed for 50 years. The
short-term impacts to the community with alternative GW-5 include a high volume of truck
traffic during excavation activities. Dust control may be required and construction workers
would be required to have appropriate health and safety training; risks may not be adequately
addressed for 50 years. Alternative GW-5, however, does provide the shortest timeframe for
remedial action, which reduces the potential for human exposure. If excavation is required to a
depth of 20 feet, there will be more material handling activities with concurrent additional short-
term risks.
Site-wide Groundwater Study Area - Alternate Water Supply; The no action alternative
AWS-1 doesn't require any activities to be conducted, therefore there would be no short-term
impacts to the community or on-site workers; this alternative does not reduce risks to human
health. Under alternatives AWS-2 and AWS-3, construction of water mains and service
connections are not expected to have a significant impact on the local community or construction
workers, with respect to exposure to contamination. Normal construction hazards associated
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with this type of activity will be mitigated through implementation of safe work practices and
compliance with OSHA requirements. Significant environmental impacts are not expected from
water supply infrastructure installation. Under alternative AWS-4, installation and monitoring of
treatment systems is expected to pose a mild disturbance to the community at large. Although no
active cleanup of groundwater is contemplated by alternatives AWS-2, AWS-3 and AWS-4, risks
to human health would be addressed immediately upon hookup to an alternate water supply or
provision of point of use treatment.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP); The no action
alternatives SZ-1 and DP-1 don't require any activities to be conducted, therefore there would be
no short-term impacts to the community or on-site workers; this alternative does not reduce risks
to human health.
Impacts to the community from alternative SZ-2 would be limited to construction of a treatment
facility and associated piping. Construction workers would be required to have appropriate
training. Alternative DP-3 has similar impacts, although the lateral extent of piping is greater,
and therefore would increase impacts to the community due to installation of extraction wells and
piping. Under both alternative SZ-2 and DP-3, no short-term reduction to human health risk
would be realized.
Alternatives DP-2 and DP-6 do not propose active remediation beyond monitoring, therefore no
significant adverse impacts to the community or workers occur. Minimal impacts occur from the
installation of additional monitoring wells if necessary and from monitoring activity. Also, there
is no short-term reduction to human health risk.
Alternatives were combined to include DP-6, Monitoring of the Dissolved Plume, Alternative
SZ-1, No Action for the Source Zone, and Alternative SZ-2, Groundwater Extraction for
Hydraulic Containment, specifically provided as a contingency, in the event that groundwater
plume migration does occur. These alternatives would be implemented in conjunction with the
provision of an alternative water supply as described in alternatives AWS-2 or AWS-3, as well as
a technical impracticability waiver for both the source zone and dissolved plume areas. Unless
the contingency of SZ-2 for containment is implemented, no impact to the community or workers
is contemplated and no short-term reduction in human health risk occurs. (See alternatives
AWS-2 and AWS-3 for relevant discussion on short-term effectiveness.)
6, Implementabilitv
Implementability addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of materials and services,
administrative feasibility, and coordination with other government entities are also considered.
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MMC Study Area: Alternatives S-l and SV-1 are the easiest to implement because no remedial
actions are required. All other alternatives and combinations of alternatives are easily
implemented because they all involve reliable technologies with proven histories of success. The
personnel, equipment and materials required to implement each of these technologies are readily
available. Alternatives involving excavation and containment would require access to an
adjacent residential property, as well as potential institutional controls. Also, excavation
alternatives would not be implemented underneath the existing building, if contaminants are
found in that area.
DMC Study Area: Alternative GW-1 is the easiest to implement because no remedial actions
are required. Alternatives GW-2 and GW-3 are relatively easily implemented, involving reliable
technologies that have been implemented at many other such sites. The personnel, equipment
and materials required to implement each of these technologies are readily available. Alternative
GW-4 can be readily implemented, and has been demonstrated to be technically feasible at
similar sites; however, the reliability of oxidation of all potential DNAPL in a fractured till is
uncertain. Alternative GW-5, excavation, is a common remediation action. Challenges facing
this alternative are the proximity to a building that is actively used and subsurface utilities.
Alternatives GW-2, GW-3, GW-4 and GW-5 may all involve access to an adjacent residential
property, as well as potential institutional controls. Also, excavation alternatives would not be
implemented underneath the existing building, if contaminants are found in that area.
Site-wide Groundwater Study Area - Alternate Water Supply: AWS-l is the easiest to
implement because no remedial actions are required. Alternatives AWS-2, AWS-3 and AWS-4
are relatively easily implemented because they all involve reliable and common technologies.
The personnel, equipment and materials required to implement each of these technologies are
readily available. Alternatives AWS-2 and AWS-3 would require extensive coordination with
property owners, state and local agencies, and municipalities. Alternative AWS-4 would require
similar coordination. The effectiveness of treatment for 1,4-dioxane at individual wells is
questionable, and has not yet been proven to be entirely effective.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP): The no action
alternatives SZ-1 and DP-1 don't require any remedial actions and are therefore the easiest to
implement. Alternative SZ-2 is relatively easily implemented in that the technology is reliable
and common, and personnel, equipment and materials required to implement each of these
technologies are readily available. Placement of extraction wells, however, may be difficult due
to the complex hydrogeology found at the source zones, and frequent monitoring would be
required. Alternative DP-3 is similarly easily implemented due to readily available technology;
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however, placement of extraction wells may be difficult due to the complex hydrogeology in the
dissolved plume area.
Alternatives DP-2 and DP-6 do not propose active remediation or construction beyond
installation of monitoring wells, therefore these alternatives are much easier to implement.
Alternatives were combined to include DP-6, Monitoring of the Dissolved Plume, Alternative
SZ-1, No Action for the Source Zone, and Alternative SZ-2, Groundwater Extraction for
Hydraulic Containment, specifically provided as a contingency, in the event that groundwater
plume migration does occur. These alternatives would be implemented in conjunction with the
provision of an alternative water supply as described in alternatives AWS-2 or AWS-3, as well as
a technical impracticability waiver for both the source zone and dissolved plume areas,
Implementation of alternatives DP-6 and SZ-1 is easy, but implementing the contingency of SZ-2
for containment would be more difficult as previously described,
7. Cost
MMC Study Area; No action alternatives S-l and SV-1 have no associated costs. Soil vapor
extraction alternatives S-4 and SV-3 are generally the least expensive alternative, with cost
estimates ranging from $494,000 to $505,000 if implemented alone. Containment alternative S-2
has a cost estimate of $2.7 million. The excavation alternatives, S-3 and SV-2, have cost
estimates ranging from $2.6 to $3.8 million, depending on the lateral extent and depth to which
excavation is required.
The combination of the two excavation alternatives for soil and soil vapor, S-3 and SV-2,
achieves some overlap in volumes of soil requiring excavation, which saves some shared costs
for a total of $4.9 million. The combination of excavation alternative S-3 and soil vapor
extraction alternative SV-3 achieves cost savings by implementing SVE first in order to reduce
VOC contaminants and the extent to which excavation is required; the total for this combination
is $2.2 million. Combining containment alternative S-2 and soil vapor extraction SV-3 results in
some cost savings by increasing the effectiveness of the SVE; the total for this combination is
$3.0 million.
DMC Study Area: No action alternative GW-1 has no associated cost. The In-situ Chemical
Oxidation alternative, GW-4, is the least expensive alternative at $1.8 million. Excavation
alternative GW-5 has a cost estimate of $3.2 million. The containment alternative, GW-2, and
multi-phase extraction alternative, GW-3, are both priced at an estimate of $4.9 million. The
cost for taking action for potential vapor intrusion, if found, has not been included in the cost
estimates.
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Site-wide Groundwater Study Area - Alternate Water Supply: No action alternative AWS-1
has no associated cost. Alternative AWS-3, Development of New Groundwater Source and
Water Distribution System, has an estimated cost of $6.6 million. This cost could change if area
wells are determined to have adequate supply, and/or if treatment of water from such wells is
necessary prior to distribution. Alternative AWS-2, Connection to Middletown Water
Distribution System, has a cost estimate of $7.0 million. Alternative AWS-4, Point of Use
Treatment is the most expensive alternative, with a cost estimate of $7.2 million.
Site-wide Groundwater - Source Zone (SZ) and Dissolved Plume (DP): No action
alternatives SZ-1 and DP-1 have no associated cost. Alternative DP-6, Monitoring of the
Dissolved Plume, has a cost estimate of $434,000. Alternative DP-2, Monitored Natural
Attenuation for the Dissolved Plume, has an estimated cost of $1.9 million. Alternative DP-3,
Groundwater Extraction - Restoration for the Dissolved Plume, has an estimated cost of $8.5
million, while alternative SZ-2, Groundwater Extraction - Hydraulic Containment for Source
Zone, has a cost estimate of $8.7 million. The cost for investigating and taking action for
potential vapor intrusion risks beyond the MMC and DMC Study Areas, if found, has not been
included in the cost estimates.
8. State Acceptance
CT DEP submitted comments on August 11,2005, during the public comment period for the
Site, generally supporting the preferred alternative. CT DEP specifically concurred with the
proposals for the MMC Study Area {combination of Alternatives S-3 and SV-3), the DMC Study
Area (DMC Alternative GW-5), the Site-wide Groundwater Study Area alternative water supply
proposal (Alternative AWS-2, connection to the Middletown Water Distribution System), and
the Site-wide Groundwater Study Area source zone and dissolved plume proposals (Alternative
SZ-1 and Alternative DP-6, with a contingency to implement a groundwater extraction system,
SZ-2). CT DEP also concurred with the implementation of a waiver of federal and state
requirements that would normally require cleanup of the groundwater to meet drinking water
standards due to technical impracticability.
CT DEP commented that the institutional control component of the remedies should specifically
utilize Environmental Land Use Restrictions (ELURs) pursuant to Section 22a-133q-l of the
Regulations of Connecticut State Agencies. This comment has been incorporated into this ROD.
CT DEP concurred with the need for further characterization to assess the potential for VOCs in
shallow groundwater to migrate and pose a potential indoor air risk to areas beyond the MMC
and DMC Study Areas. CT DEP disagrees with EPA's determination that further actions will be
taken to address such risks only after a determination that there is an unacceptable risk, instead
proposing that actions be taken if there are any exceedances of CT RSRs, without the need for
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further risk assessment. EPA and CT DEP do not agree on this matter, and as a result, CT DEP
is not concurring on this specific portion of the remedy, CT DEP is concurring on all other
components of the remedy.
EPA responds to these comments in the Responsiveness Summary attached to this ROD as
Appendix D.
A copy of the state's partial concurrence letter is included as Appendix C of this ROD.
9. Community Acceptance
During the public comment period, the community and State agencies expressed their support for
an alternate water supply. Opinions were mixed regarding the source of water, with a number of
comments supporting Alternative AWS-2, Connection to Middletown Water Distribution
System, and a lesser number of comments supporting Alternative AWS-3 in which a new
groundwater source would be developed in close proximity to the Study Area. No comments
were received that explicitly expressed non-support for an alternate water supply.
Only one comment was received (from the Durham Manufacturing Company) regarding non-
support of the remediation proposed for the DMC Study Area. DMC comments further indicated
that the DMC Study Area should not be included in this Record of Decision. EPA does not agree
with this comment.
All comments received during the public comment period and EPA's response to comments are
included in the Responsiveness Summary, Appendix D of this Record of Decision,
L. THE SELECTED REMEDY
1. Summary of the Rationale for the Selected Remedy
The selected remedy is a comprehensive remedy which addresses principal Site risks by
mitigating potential human health risks at the MMC Study Area, the DMC Study Area, and the
Site-wide Groundwater Study Area, The selected remedy is the proposed preferred alternative
that was identified in the Proposed Plan and is presented in more detail in the FS.
The major components of the selected remedy include:
* Soil excavation and off-site disposal, in conjunction with soil vapor extraction, at the
MMC Study Area to address risks to human health from contamination in soil and soil
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vapor. Excavation of a localized area of surface soil contamination on an adjacent
residential parcel will also occur.
• Soil excavation and off-site disposal of hot spot areas at the DMC Study Area in order to
address risks to human health from contamination in overburden (shallow) groundwater
and to address source contamination.
• Connection to the Middletown Water Distribution System to distribute an alternative
source of public water to all residences currently affected by groundwater contamination
and a buffer zone of residences located near the contaminated area. Development of and
connection to a new groundwater source is retained as a contingency measure in the event
that a connection to the City of Middletown Water Distribution System cannot be
implemented for administrative or other reasons, or cannot be implemented in a timely
manner. Also included is the interim measure of continued monitoring and filtration, and
provision of bottled water as necessary, of impacted residential wells, and any other
residential wells within the Site-wide Groundwater Study Area that come to be impacted
by Site-related contamination, as currently required under state order and state
regulations, to ensure continued protectiveness of human health and the environment until
construction of the alternate water supply portion of the remedy is complete and
operational. This alternative addresses current and future risk to human health from
ingestion of groundwater.
• For the overall area of groundwater contamination, implementing a monitoring network
for the dissolved plume to ensure no migration of groundwater occurs beyond its current
general boundary.
• Contingency to implement a groundwater extraction system for hydraulic containment if
the overall plume or source zone is spreading or migrating beyond its current general
boundary,
• Implementation of a technical impracticability waiver of the applicable or relevant and
appropriate requirements that would normally require cleanup of the groundwater, since it
is not technically practicable to clean up the groundwater to drinking water and other
standards in a reasonable amount of time.
• Institutional controls, primarily in the form of Environmental Land Use Restrictions
(ELURs) as defined in the CT RSRs, and/or by local ordinance, in a variety of areas to
prevent unrestricted future use of certain areas of the Site or use of contaminated
groundwater.
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• Further delineation of areas posing potential indoor air risks on and outside of the MMC
and DMC Study Areas by further characterization, including the collection of shallow
groundwater data. If there are unacceptable risks, then further actions will be taken to
address such risks, including without limitation, sub-slab depressurization systems and
institutional controls on vacant properties or portions of properties, in accordance with
EPA and CT DEP requirements,
• Five-year reviews to ensure the remedy continues to be protective of human health and
the environment.
A detailed description of the remedial components of the selected remedy follows.
2. Description of Remedial Components
Specific remedial components are presented for each Study Area.
MMC Study Area. Soil and soil vapor contamination on the property will be addressed using a
combination of two alternatives: Alternative MMC S-3C Excavation and Off-site Disposal, and
Alternative MMC SV-3 Soil Vapor Extraction (SVE).
The major components of Alternative MMC S-3C Excavation and Off-site Disposal include;
• Pre-remedial study;
• Excavation support activities;
• Soil excavation and off-site disposal;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
The major components of Alternative MMC SV-3C Soil Vapor Extraction include:
• Pre-remedial study;
• Site preparation;
• Installation and operation of the SVE system;
• T reatment of o ff-gas;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
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This alternative requires that VOCs in soil vapor be treated via SVE first in order to reduce
concentrations of VOCs in soil overtime and minimize the volume and depth of required
excavation needed to address all contaminants on site. SVE may also reduce the mass of any
DNAPL residing in subsurface soils. Remaining soil that exceeds cleanup levels shall be
excavated and shipped off-site to an approved disposal facility. Scenario S-3C addresses current
and future residential risk by excavating and removing soil that exceeds RBGs, CT RSR
residential and industrial/commercial Direct Exposure Criteria (DECs), and CT RSR Pollutant
Mobility Criteria (PMCs). The estimated lateral extent of contaminated soil to be addressed is
approximately 0.75 acres, and the estimated depth ranges to 4 feet, although soils deeper than 4
feet shall be remediated in accordance with ARARs.
While SVE will treat soil vapor prior to excavation on the bulk of the MMC property, excavation
of a localized area of PAH contamination in surface soils primarily located on the 275 Main
Street parcel shall occur more immediately, to address potential dermal contact risks to the
adjacent resident.
Confirmatory sampling during soil excavation will determine how the soil must be disposed. For
cost estimating purposes, it was assumed that all excavated soil would be characterized as non-
hazardous under RCRA, since soil vapor extraction is expected to reduce the levels of RCRA
listed waste in soil.
Institutional controls in the form of an Environmental Land Use Restriction (ELUR) pursuant to
CT RSRs shall be required for the MMC parcels. The significant restrictions of the ELUR will
be to (i) ensure that any new structures on the property will be constructed to minimize potential
inhalation risks from any remaining contamination, and (ii) prevent the future use of groundwater
for drinking water. The status of the parcels owned by the Estate of Mr. Allan Adams is
currently in transition; in the absence of an identifiable owner of the MMC or other parcels, other
forms of an institutional control shall be investigated (e.g., local ordinance, by-law, deed notice)
and implemented to the extent possible. After remedy completion, the restrictions on future use
are expected to be minimal, compared to other alternatives considered for the MMC Study Area.
After the cleanup levels have been met and the remedy is determined to be protective, an
environmental monitoring program shall be required to ensure continued protectiveness of
human health and the environment. The environmental monitoring program will include soil
vapor monitoring, for an estimated duration of 7 years, and groundwater monitoring, estimated
for 50 years, to ensure that the cleanup levels continue to be met and the remedy remains
protective.
PMC Study Area. Contamination in overburden (shallow) groundwater on the property will be
addressed through Alternative DMC GW-5 Soil Excavation and Off-site Disposal. The major
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components of this alternative include:
• Pre-remedial study;
• Excavation support activities;
• Soil excavation and off-site disposal;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a source control, or removal, remedy. The removal of sources
of contamination is expected to reduce the concentrations in groundwater, as well as significantly
reduce the risk posed to construction workers through direct contact of contaminants in
groundwater immediately upon completion of the excavation. Under this alternative, all
accessible hot spot areas (including DNAPL if encountered) shall be excavated and transported
for off-site disposal. It is expected that DNAPL has penetrated the unsaturated zone, requiring a
deep excavation to remove all possible source materials, up to 20 feet deep in some locations.
The presence of buildings and utilities presents challenges, and it is possible that contaminated
soils exist under the buildings.
This alternative requires excavation of the most contaminated areas on the property which are
providing a risk to human health and appear to be providing an ongoing groundwater
contamination source. The hot spot areas to be excavated have a total area of 0.20 acres. Of the
alternatives contemplated for the DMC Study Area, excavation and off-site disposal is the only
alternative expected to reduce the risk in a relatively short timeframe (less than the 50-100 year
estimates associated with other alternatives). This alternative is also the most reliable option if
all contaminated soils are removed, and provides for a shorter timeframe for remedial action,
which is desired to reduce the potential for human exposure. Excavated soil will be shipped off-
site to an approved disposal facility. Confirmatory sampling during soil excavation will
determine how the soil must be disposed, but for cost estimating purposes, it was assumed that
all excavated soil would be characterized as a hazardous waste under RCRA.
Soil removal may also have the additional benefit of reducing contaminant mass loading to
groundwater, and consequently reducing overall groundwater contaminant levels over time.
Consistent with EPA's Technical Impracticability Guidance for the Site-wide groundwater, this
alternative will also remove source areas to the maximum extent practicable and remove soils
exceeding CT RSR Pollutant Mobility Criteria (PMC).
Further delineation of VOCs in soils and VOCs in overburden groundwater beneath the DMC
facility building will occur during pre-design and/or remedial activities. If it is determined that
contaminated soils or contaminants in overburden groundwater under the DMC facility building
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are posing an unacceptable risk to current workers inside the facility, additional measures shall
be taken to address this exposure pathway. The inhalation risk to a future resident from
contaminants in overburden groundwater shall be addressed by institutional controls as described
below.
Institutional controls in the form of an Environmental Land Use Restriction (ELUR) pursuant to
CT*^ CTT* 1*1*1 * 1 f" if T\1 f/"! 1 rflt » »/— . f , I T->Tr T m "11 I
RSRs shall be required for the DMC parcel. The significant restrictions of the ELUR will be
as follows:
(i) to prevent construction of a building over groundwater that exceeds CT RSR VC unless the
Commissioner of CT DEP grants a release based on the stipulation that any new structures will
be constructed to minimize potential inhalation risks from any remaining contamination,
(ii) to prevent the use of overburden groundwater as drinking water or for other domestic
purposes,
(iii) to prohibit residential activities at the DMC Study Area, unless the Commissioner of CT
DEP grants a release from the ELUR, and
(iv) to prohibit soil disturbance at the DMC Study Area and exposure to groundwater by
activities such as construction, grading, digging, drilling, excavation and other intrusive activities
unless the Commissioner grants a release from the ELUR. Such release would be based on a
plan which includes controls to protect the health of construction workers by preventing contact
with groundwater in uncontrolled conditions.
Long-term monitoring of groundwater would be implemented upon removal of source materials
to demonstrate the effectiveness and protectiveness of the remedy. Groundwater monitoring
shall continue for an estimated duration of 50 years.
Site-wide Groundwater Study Area - Alternative Water Supply. Contamination in Site-wide
bedrock groundwater will be addressed through Alternative AWS-2: Connection to Middletown
Water Distribution System. The major components of this alternative include:
• Extend the existing Middletown water system;
• Construct water distribution system within Study Area;
• Connect residences to new distribution system;
• institutional controls; and
• Five-year reviews.
Under this alternative, the existing Middletown Water Distribution System shall be extended
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from the City of Middletown south along Route 17 to residences within the Study Area providing
potable water to all impacted residents and eliminating all current and future risk to human health
from ingestion of groundwater, This alternative will provide a permanent source of drinking
water to all residences currently affected by groundwater contamination and a buffer zone of
residences located near the contaminated area. It is assumed 85 service connections would be
made to the water mains. The proposed distribution system is looped within the Study Area in
order to service all impacted constituents as well as to address water quality and pressure
considerations. This alternative, combined with institutional controls on existing groundwater
use, will prevent exposure to contaminated groundwater,
A connection to the Middletown Water System has the advantage of providing flexibility for the
Town to address other contaminated areas in the Town of Durham north of the Site and avoiding
locating a source well in or near contaminated areas.
While the Middletown Water System may also have adequate capacity to provide water service
to other portions of town, as well as fire protection, the alternative analyzed in the Feasibility
Study was limited to providing water service only to the Superfund Site for drinking water
purposes. With respect to fire protection, the Feasibility Study does provide a breakout of
additional costs that would be required to provide fire protection, including greater capacity
piping as well as the added cost for hydrants should the Town of Durham decide to expand the
use of the water service.
Institutional controls in the form of an Environmental Land Use Restriction (ELUR) pursuant to
CT RSRs, or in some other form (e.g., local ordinance) shall be implemented to the extent
possible in order to prevent the use of groundwater for drinking water purposes, and to prevent
other uses that may pose a potential risk to human health or that may have an adverse impact on
the remedy.
Implementation of this alternative shall also require the development of administrative and
operation and maintenance functions. Administrative responsibilities will include billing,
customer service, and regulatory compliance. Operation and maintenance of the water supply
and distribution components, including regulatory compliance, will also be necessary.
Administrative agreements between the City of Middletown and the Town of Durham shall be
required to formally assign these responsibilities.
Currently, 38 impacted wells have carbon filters and are monitored on at least a quarterly basis.
DMC is responsible for servicing 14 of these wells under a CT DEP order. MMC is responsible
for servicing 24 of these wells, but ceased these activities in late 2004; CT DEP has taken over
monitoring and maintenance of these locations. As an interim measure, monitoring and
filtration, and provision of bottled water as necessary, of these residential wells, and any other
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residential wells within the Site-wide Groundwater Study Area that come to be impacted by Site-
related contamination, shall continue as currently required under state order and state regulations,
to ensure continued protectivcness of human health and the environment until construction of the
alternate water supply portion of the remedy is complete and operational.
As a contingency measure, Alternative AWS-3, Development of a New Groundwater Source and
Distribution System, shall be retained in the event that AWS-2, Connection to Middletown Water
Distribution System, cannot be implemented for administrative or other reasons, or cannot be
implemented in a timely manner. Alternative AWS-3 is very similar to AWS-2, with the
exception of the source of potable water to be distributed. Under contingency remedy AWS-3, a
new groundwater source would be developed in close proximity to the Study Area. All other
components of the remedy are similar with respect to construction of a distribution system within
the Study Area, the scope of the distribution system, and the number of service connections to the
water mains.
The institutional control and five-year review components of the remedy remain the same
regardless of whether AWS-3 or AWS-2 is implemented, with the possible exception of
requiring institutional controls on and around the new groundwater source to prevent other
groundwater use or other land use activities that may interfere with the new source of water.
The interim measure of continued monitoring and filtration, and provision of bottled water as
necessary, of affected wells under state order also remains the same, regardless of whether AWS-
3 or AWS-2 is implemented.
Site-wide Groundwater Study Area - Source Zone and Dissolved Plume. Contamination in the
source zone and the dissolved plume in Site-wide bedrock groundwater will be addressed
through a combination of Alternatives SZ-1 No Action, and Alternative DP-6 Monitoring. The
major components of this combination of alternatives include:
• Installation of bedrock groundwater monitoring wells;
• Environmental monitoring;
• Institutional controls;
• Five-year reviews.
For the overall area of Site-wide groundwater contamination, alternatives to fully restore the
groundwater were screened out. It is not technically practicable to clean up the groundwater to
drinking water and other standards in a reasonable amount of time. As outlined in Section I of
this ROD, EPA is implementing a technical impracticability waiver of chemical-specific ARARs
that would normally require cleanup of groundwater to drinking water and other standards.
This combination of alternatives provides limited action. No remedial actions are proposed.
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Monitoring of the Site-wide Groundwater Study Area, including the source zone and the
dissolved piume, shall occur for a period of up to ten years after the construction of an alternate
water supply in order to determine whether the plume is migrating or attenuating; however,
further monitoring may be conducted pursuant to five-year reviews. The monitoring well
network shall be implemented within and outside of the current known boundaries of the overall
groundwater plume in order to monitor plume migration, and ensure the plume does not migrate
beyond the limits of the Technical Impracticability zone.
In conjunction with the water supply alternative, institutional controls in the form of ELURs or
some other control such as a local ordinance shall be implemented within the Technical
Impracticability zone to avoid Site uses of contaminated groundwater.
Site-wide Groundwater Study Area - Contingency SZ-2 Groundwater Extraction for Hydraulic
Containment. If monitoring results indicate that contaminants are likely to spread beyond the
limits of the Technical Impracticability zone, as defined through the monitoring network
implemented in Alternative DP-6, Alternative SZ-2 shall be implemented as a contingency. The
major components of this contingency alternative include:
• Groundwater extraction;
• Ex-situ groundwater treatment;
• Environmental monitoring;
• Institutional controls; and
• Five-year reviews.
This alternative was developed as a containment alternative to manage the migration of
contaminated groundwater. Under this contingency alternative, groundwater shall be extracted
from the source zones (VOCs and possibly DNAPL, if encountered) using new extraction wells,
or by converting existing monitoring wells to extraction wells. Such action shall be undertaken
with the specific goal to prevent the migration of contaminated bedrock groundwater into areas
beyond the Technical Impracticability zone. Extracted groundwater would be piped to a
centralized treatment system.
If necessary in areas surrounding the existing Technical Impracticability zone, institutional
controls shall be implemented to avoid Site uses of contaminated groundwater.
Additional Areas RequirinE Investigation. Based upon the potential future indoor air risks found
at both the MMC and DMC Study Areas, there is a potential, at other locations, for current or
future exposures through volatilization of organic compounds. Prior to or during remedial
design there shall be further delineation of the area posing potential indoor air risks on or outside
of the MMC and DMC Study Areas by further characterization, including the collection of
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shallow groundwater data. If there are unacceptable risks, then further actions will be taken to
address such risks, including without limitation, sub-slab depressurization systems, and
institutional controls, such as ELURs, on vacant properties or portions of properties, in
accordance with EPA and CT DEP requirements.
To the extent required by law, EPA will review the Site at least once every five years after the
initiation of remedial action at the Site if any hazardous substances, pollutants or contaminants
remain at the Site to assure that the remedial action continues to protect human health and the
environment. EPA will also conduct a review of the Site prior to completion of the remedial
action, and prior to any future deletion of this Site from the National Priorities List.
The selected remedy may change somewhat as a result of the remedial design and construction
processes. Changes to the remedy described in this Record of Decision will be documented in a
technical memorandum in the Administrative Record for the Site, an Explanation of Significant
Differences or a Record of Decision Amendment, as appropriate.
A portion of the DMC Study Area contains wetlands, and portions of the Site are located within
the 100-year floodplain. EPA has determined it is unlikely that the remedial alternatives will
involve activity that will impact wetlands or floodplain areas at or around the Site, If, however,
as part of future design activities, EPA determines that there is no practical alternative to
conducting work in wetlands or in floodplains, EPA will then minimize potential harm and avoid
adverse effects to the extent practical, and comply with all wetlands and floodplains ARARs
identified for this Site.
3. Summary of the Estimated Remedy Costs
Remedy costs were estimated separately for each of the study areas as follows:
• MMC Study Area estimated cost: $2.2 million. Combination of Alternative MMC S-3C
Excavation and Off-site Disposal, and Alternative MMC SV-3 Soil Vapor Extraction.
• DMC Study Area estimated cost: $3.2 million. Alternative DMC GW-5 Soil Excavation
and Off-site Disposal.
• Site-wide Groundwater Study Area, Alternate Water Supply estimated cost: $7.0 million.
Alternative AWS-2 Connection to Middletown Water Distribution System. Contingency
of AWS-3 Development of a New Groundwater Source and Distribution System
(estimated cost $6.6 million).
• Site-wide Groundwater Study Area, Source Zone and Dissolved Plume estimated cost;
$434,000. Combination of Alternatives SZ-1 No Action and Alternative DP-6
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Monitoring.
• Site-wide Groundwater Study Area, Contingency Remedy for Groundwater Containment
estimated cost; $8.7 million.
The estimated total of the remedy is $12,834,000 without the contingency for groundwater
containment, or action for any vapor intrusion beyond the DMC and MMC Study Areas. For the
Alternate Water Supply component of the Site-wide Groundwater Study Area, if the contingency
of AWS-3 Development of a New Groundwater Source and Distribution System is implemented
instead of AWS-2 Connection to Middletown Water Distribution System, some cost savings may
be achieved, however, any need for treatment would increase the cost estimate. (The cost
estimate for AWS-3 of $6.6 million does not include treatment.)
Cost tables (ROD Tables 31 through 40) provide a summary of the major capital and annual
O&M cost elements for the Selected Remedy for each Study Area, and present the major
construction and O&M activities required to implement each remedy component along with their
associated unit and total costs. For long term operation and maintenance (O&M) activities, the
cost summary generally provides estimates based on a 50 year timeframe, although in some
instances, the O&M activities are expected to exceed 50 years. The cost estimate for Alternative
DP-6, Monitoring, assumes an O&M timeframe of 10 years. Data obtained from remedial action
and five-year reviews will be utilized to refine long-term O&M cost estimates as necessary.
Regarding the cost summary for AWS-2, Connection to the Middletown Water Distribution
System, this estimate includes bringing the water main into the Town of Durham and into the
Superfund Site area. Cost estimates include all costs associated with hookup of individual
homes, including abandonment of on-site private drinking water wells and implementation of
institutional controls to prevent drilling and use of future wells in the area. EPA's authority does
not include providing funding of the actual supply of water to individual homeowners; this cost
would be borne by the homeowners, either by a direct agreement with the City of Middletown, or
to the Town of Durham through a broader agreement between the City of Middletown and the
Town of Durham.
While the Middletown Water Distribution System may also have adequate capacity to provide
water service to other portions of town, as well as fire protection, the alternative analyzed in the
Feasibility Study was limited to providing water service only to the Superfund Site for drinking
water purposes. With respect to fire protection, Appendix I of the Feasibility Study [M&E,
2005b] does provide a breakout of additional costs that would be required to provide fire
protection, including greater capacity piping as well as the added cost for hydrants. An
additional cost estimate of $70,000 is provided for including the Strong School, located at 191
Main Street, to the water line. While the Strong School was previously using an on-site well,
filtered to remove groundwater contamination, as of August 2004, it is now using a clean source
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of water from the District 13 Consolidation well system. This system uses wells at the
Coginchaug Regional High School and the Korn Elementary School that are not impacted by the
Durham Meadows Site. The additional capital costs to provide all additional costs necessary to
provide pipe capacity for fire protection, range from approximately $200,000 to $600,000. This
range is a function of the potential fire flow demands.
Also, as noted, Alternative AWS-3, Development of a New Groundwater Source and
Distribution System, is retained as a contingency measure in the event that AWS-2, Connection
to Middletown Water Distribution System, cannot be implemented for administrative or other
reasons, or cannot be implemented in a timely manner. Alternative AWS-3 is very similar to
AWS-2, with the exception of the source of potable water to be distributed. While Alternative
AWS-3 is slightly less costly than Alternative AWS-2, any need for treatment would increase the
cost estimate for AWS-3.
The information in the cost estimate summary tables is based on the best available information
regarding the anticipated scope of the remedial alternative. Changes in the cost elements are
likely to occur as a result of new information and data collected during the engineering design of
the remedial alternative. Major changes may be documented in the form of a memorandum in the
Administrative Record file, an ESD, or a ROD amendment. This is an order-of-magnitude
engineering cost estimate that is expected to be within +50 to -30 percent of the actual project
cost.
4. Expected Outcomes of the Selected Remedy
The expected outcomes of the selected remedy include:
• To mitigate human health risks associated with potable and domestic use of groundwater
within the Site-wide Groundwater Study Area by the connection of residences to an
alternate water distribution system. This goal will be achieved as soon as the alternate
distribution system is installed, likely to be within three years.
• To prevent unacceptable risks to potential receptors who may come in contact with soil
and to reduce the leaching of soil contaminants to groundwater at the MMC Study Area.
Remedial goals consistent with residential and industrial/commercial use of the MMC
Study Area and protective of leaching to groundwater will be achieved upon the removal
of volatile compounds and soils, essentially at the close of construction activities.
• To reduce the potential for exposures via the vapor intrusion pathway at the MMC Study
Area. Remedial goals for the vapor intrusion pathway will be achieved upon the removal
of vapors and soils, or upon the installation of engineering controls that limit the potential
migration of volatile compounds present in the subsurface to volatilize into current or
future buildings.
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• To reduce the potential for direct contact and inhalation exposures associated with
shallow groundwater at the DMC Study Area, Remedial goals for these pathways will be
achieved after the removal of soil containing chemicals of concern with the potential to
migrate to groundwater, and by the implementation of institutional controls for worker
safety and land use controls. Mass contaminant removal may also have the additional
benefit of reducing overall contaminant levels over time; this alternative shall remove
source areas to the maximum extent practicable.
• To address the potential for vapor intrusion impacts beyond the boundaries of the MMC
and DMC Study Areas by further delineation of volatile groundwater contaminants
outside the MMC/DMC boundaries.
Required monitoring at all of the Study Areas is expected to last for a minimum of 50 years.
However, if the contingency remedy of groundwater extraction for hydraulic containment is
implemented, the estimated operation time may be in excess of 100 years.
Once the institutional controls have been implemented, compliance with the restrictions will be
monitored and enforced to ensure that the institutional controls are effective. Over time, EPA
and CT DEP will also evaluate whether restrictions can be removed because the restrictions are
no longer needed to protect public health and the environment.
While Site-wide groundwater will not present an unacceptable risk to human health once the
remedy is implemented, the remedy does not provide for groundwater cleanup. A technical
impracticability waiver encompasses all areas in the overburden and bedrock aquifers that are
currently or conceivably could be impacted by contamination emanating from the Site. The
overburden and bedrock aquifers are not expected to ever be suitable for drinking water use.
The selected remedy will also provide environmental benefits such as mass removal of
contaminants and the potential reduction of DNAPL present in subsurface soil at the MMC Study
Area, and soil and overburden groundwater at the DMC Study Area. It is anticipated that the
selected remedy may also provide socio-economic and community revitalization impacts such as
potential increased property values due to the implementation of a permanent and safe source of
drinking water to affected residences, and the anticipated eventual reuse of the MMC Study Area
for industrial/commercial, residential, or other municipal purposes.
Based on the results of the Baseline Risk Assessment, surface soil, subsurface soil, and soil vapor
were identified as media requiring the development of cleanup levels at the MMC Study Area.
a. Cleanup Levels By Study Area
1. MMC Study Area
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While the surrounding area is currently zoned for residential and residential/farm use, industrial
use on the parcels previously occupied by MMC is and would be allowed at the MMC Study
Area. A tenant is currently using the warehouse in the rear portion of the property for
industrial/commercial purposes, but the remainder of these parcels have been unused since the
main building was destroyed by fire in 1998. A third parcel is currently zoned and being used for
residential purposes; the 275 Main Street residence is rented out as two separate apartments, and
both apartments have tenants.
There is considerable uncertainty regarding the future reuse of the MMC Study Area parcels.
Under the existing zoning, residential homes could also be built on the property. If this were to
occur, future use of the property would then default to the area's residential and residential/farm
existing zoning, and industrial/commercial use would be prohibited. Additional uncertainties
exist due to the need to resolve Site liabilities, and the unknown ownership status of the property
as described in Section F of this ROD. Given these uncertainties, and the range of reasonably
anticipated future land uses, potential future residential use of this property was considered in the
FS and the human health risk assessment as the most conservative assumption with respect to
exposure, and the remedy is tailored for potential future residential use.
For soil, promulgated State standards have been established for both direct contact exposures
(i.e., CT RSR DEC) and for pollutant mobility (i.e., CT RSR PMC). The lower of the available
CT RSRs, based on either direct contact or pollutant mobility, for each soil chemical of concern
was used as the cleanup level. Each of the identified CT RSRs were less than EPA calculated
risk-based values, consistent with residential and commercial use, except for arsenic,
benzo(a)pyrene, and dibenz(a,h)anthracene. However, because the risk-based values were below
background values for these three compounds, the soil cleanup goal for each of these compounds
was set at the CT RSR DEC standard. For lead, the CT RSR DEC for residential receptors,
including children, was selected as the soil cleanup goal.
For soil vapor, promulgated State standards have been established for the vapor intrusion
pathway (i.e., CT RSR VC). The CT RSR VC for trichloroethene, protective of residential
inhalation exposures of impacted indoor air, was used as the cleanup level.
Table 41 summarizes the soil and soil vapor cleanup levels for carcinogenic and non-
carcinogenic chemicals of concern in soils and soil vapor established to protect public health.
Soil cleanup levels are also provided for contaminants that have the potential to leach to
groundwater.
These cleanup levels in soils and soil vapor are consistent with ARARs, attain EPA's risk
management goal for remedial actions, and have been determined by EPA to be protective. The
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cleanup levels apply to surface soil, subsurface soil, and soil vapor at the MMC Study Area only.
For areas targeted for soil vapor extraction or soil excavation, the soil cleanup levels must be met
at the completion of the remedial action. Compliance with the soil cleanup levels will be
demonstrated by confirmatory sampling in remediated areas. Compliance with the soil vapor
cleanup levels will be achieved upon the removal of vapors or soil, or upon the installation of
engineering controls that limit the potential migration of volatile compounds present in the
subsurface to volatilize into buildings.
2. DMC Study Area
Based on the results of the Baseline Risk Assessment, overburden (shallow) groundwater was
identified as the medium requiring the development of cleanup levels at the DMC Study Area.
Interim cleanup levels have been established in shallow groundwater for all chemicals of concern
identified in the Baseline Risk Assessment found to pose an unacceptable risk to public health,
by direct contact or inhalation, or which were found to exceed an ARAR. Interim cleanup levels
have been set based on the ARARs (e.g., non-zero Drinking Water Maximum Contaminant Level
Goals (MCLGs), MCLs, and more stringent CT RSR GA/GAA GWPC or GWVC) as available.
The remedy includes excavation of soil containing contaminants with the potential to adversely
impact shallow groundwater. Periodic assessments of the protection afforded by the remedial
action will be made as the remedy is being implemented and following the completion of the
remedial action.
Table 42 summarizes the Interim Cleanup Levels for carcinogenic and non-carcinogenic
chemicals of concern identified in shallow groundwater at the DMC Study Area. Interim
Cleanup Levels are applicable to the contaminated shallow groundwater plume located on the
10.5-acre parcel between Main Street and Ball Brook, where Superfund investigations and
sampling have occurred. The Interim Cleanup Levels are consistent with ARARs, attain EPA's
risk management goals for remedial actions, and have been determined by EPA to be protective.
However, the Interim Groundwater Cleanup Levels will not be fully achieved because restoration
of groundwater to ARARs is technically impracticable in a reasonable timeframe.
While groundwater cleanup ARARs cannot be met, the unacceptable risk to public health must
still be addressed. Excavation and off-site disposal is selected in order to meet risk-based goals
calculated to reduce the potential exposure of future construction workers at the DMC Study
Area to trichlorocthene via direct contact to overburden groundwater. The elimination of hot
spot areas through excavation and off-site disposal of contaminated soils is the alternative that
provides the greatest degree of overall protection of human health that is technically practicable
at this study area, and also provides for a shorter remediation timeframe. Excavation will remove
source areas to the maximum extent practicable and also remove any soils exceeding PMCs
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pursuant to CT RSRs, which may have the additional benefit of reducing overall contaminant
levels over time. The implementation of institutional controls to protect workers during shallow
groundwater exposures and to control the potential for exposures via the vapor intrusion pathway
provides an added measure of long-term protectiveness.
3. Site-wide Groundwater Study Area
Based on the results of the Baseline Risk Assessment, bedrock groundwater was identified as the
medium requiring the development of cleanup levels at the Site-wide Groundwater Study Area.
Interim cleanup levels have been established in bedrock groundwater for all chemicals of concern
identified in the Baseline Risk Assessment found to pose an unacceptable risk to public health or
which were found to exceed an ARAR, Interim cleanup levels have been set based on the
ARARs (e.g., non-zero Drinking Water MCLGs, MCLs, and more stringent CT RSR GA/GAA
GWPC, GWVC, or SWPC) as available.
Because the aquifer under the Site is classified as a GA/GAA aquifer, which is a potential source
of drinking water, MCLs and non-zero MCLGs established under the Safe Drinking Water Act
and any more stringent State cleanup levels are ARARs. In the absence of an MCLG, an MCL, a
proposed MCLG, proposed MCL, a more stringent State standard, or other suitable criteria to be
considered (i.e., health advisory, state guideline), interim cleanup levels were derived for 1,4-
dioxane, benzo(b)fluoranthene, dibenz(a,h)anthracene, and indeno(l,2,3-cd)pyrene having
carcinogenic potential (Classes A, B, and C compounds) based on a 10"6 excess cancer risk level
per compound considering the current or future ingestion of groundwater during domestic water
usage. In the absence of the above standards and criteria, an interim cleanup level for 1,2-
dichloroethene (Class D) was established based on a level that represent an acceptable exposure
level to which the human population including sensitive subgroups may be exposed without
adverse affect during a lifetime or part of a lifetime, incorporating an adequate margin of safety
(hazard quotient =1) considering the current or future ingestion of groundwater during domestic
water usage.
Table 43 summarizes the Interim Cleanup Levels for carcinogenic and non-carcinogenic
chemicals of concern identified in groundwater. Interim Cleanup Levels are potentially
applicable to the contaminated bedrock groundwater plume located within the boundaries of the
Site-wide Groundwater Study Area. However, the Interim Groundwater Cleanup Levels will not
be achieved because restoration of groundwater to ARARs and risk-based goals is technically
impracticable in a reasonable timeframe. Instead, the bedrock groundwater remedy is viewed as
having long-term protectiveness by the provision of an alternate water supply and institutional
controls to prevent the use of groundwater for drinking water purposes. Periodic assessments of
the protection afforded by this remedial action will be made as this portion of the remedy is being
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implemented and at the completion of the remedial action, as well as during five-year reviews.
There exists a potential for groundwater volatile contaminants to impact indoor air outside the
boundaries of MMC and DMC Study Area boundaries. To address the potential for vapor
intrusion impacts beyond the boundaries of the MMC and DMC Study Areas, EPA will conduct
further studies to delineate volatile groundwater contaminants outside the MMC/DMC
boundaries and take actions, as necessary.
M, STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Durham Meadows Superfund Site is
consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy is
protective of human health and the environment, will comply with ARARs, with the exception of
chemical-specific ARARs for overburden and bedrock groundwater which are waived, and is
cost effective. In addition, the selected remedy utilizes permanent solutions and alternate
treatment technologies or resource recovery technologies to the maximum extent practicable.
The remedy does not satisfy the statutory preference for treatment that permanently and
significantly reduces the mobility, toxicity or volume of hazardous substances as a principal
element.
1. The Selected Remedy is Protective of Human Health and the Environment
The remedy at this Site will adequately protect human health and the environment by eliminating,
reducing or controlling exposures to human and environmental receptors. For the MMC Study
Area, implementing soil vapor extraction in combination with excavation and off-site disposal
will eliminate unacceptable risk to adjacent and potential future onsite residents via ingestion,
dermal contact or inhalation of contaminated surface soil and soil vapors. Institutional controls in
the form of an ELUR or other mechanism (e.g., local ordinance, by-law, deed notice), shall
ensure that any new structures on the property be constructed to minimize potential inhalation
risks from any remaining contamination and will prevent use of groundwater as drinking water.
For the DMC Study Area, implementing soil excavation and off-site disposal and institutional
controls will reduce the mass transfer of soil contaminants to shallow groundwater, and mitigate
unacceptable risks to future construction workers via dermal contact and inhalation to
contaminated groundwater, or risks to future onsite residents via inhalation. Institutional controls
in the form of an ELUR shall ensure (i) that any new structures will be constructed to minimize
potential inhalation risks from any remaining contamination; (ii) that groundwater will not be
used for drinking water or other domestic purposes; (iii) that residential activities are prohibited
unless the Commissioner of CT DEP grants a release from the ELUR; and (iv) that soil
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Durham, Connecticut
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disturbance and exposure to groundwater is prohibited unless the Commissioner of CT DEP
grants a release from the ELUR based on a plan which includes controls to protect the health of
construction workers.
For the Site-wide Groundwater Study Area, the alternate water supply will eliminate
unacceptable risk to current and future residents via ingestion, dermal contact, or inhalation of
contaminated groundwater. The interim measure of continued monitoring and filtration, and
provision of bottled water as necessary, of impacted residential wells, and any other residential
wells within the Site-wide Groundwater Study Area that come to be impacted by Site-related
contamination, as currently required under state order and state regulations, ensures continued
protectiveness of human health and the environment until construction of the alternate water
supply portion of the remedy is complete and operational. A technical impracticability waiver is
invoked for chemical-specific ARARs in groundwater. Implementing a monitoring well network
within and outside of the current known boundaries of the overall groundwater plume shall
ensure the plume does not migrate beyond the limits of the Technical Impracticability zone. If
groundwater contamination does migrate at a rate that will eventually approach the limits of the
Technical Impracticability zone, a contingency alternative shall be implemented to hydraulically
contain contaminated groundwater through groundwater extraction. Institutional controls in the
form of ELURs or some other control such as a local ordinance shall be implemented within the
Technical Impracticability zone to avoid Site uses of contaminated groundwater.
Further delineation of the area posing potential indoor air risks on or outside of the MMC and
DMC Study Areas by further characterization, including the collection of shallow groundwater
data, shall control potential vapor intrusion risks in those areas. If there are unacceptable risks,
then further actions will be taken to address such risks, including without limitation, sub-slab
depressurization systems, and institutional controls, such as ELURs, on vacant properties or
portions of properties, in accordance with EPA and CT DEP requirements.
The selected remedy will reduce potential human health risk levels such that they do not exceed
EPA's acceptable risk range of 104 to 1Q"6 for incremental carcinogenic risk and such that the
non-carcinogenic hazard will not exceed one. It will reduce potential human health risk levels to
protective ARARs levels, Le., the remedy will comply with ARARs and To Be Considered
criteria, with the exception of chemical-specific ARARs in Site-wide groundwater for which a
waiver is invoked. The Screening-Level Ecological Risk Assessment concluded that no
ecological receptors are expected to experience significant, long-term risk from Site-related
contaminants present in surface water or sediment, and there is no actionable ecological risk
associated with the Site. Implementation of the selected remedy will not pose any unacceptable
short-term risks or cause any cross-media impacts.
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Durham, Connecticut
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2. The Selected Remedy Waives Chemical-Specific ARARs in Site-wide Groundwater
and Complies with All Other ARARs
The selected remedy will comply with all federal and any more stringent state ARARs that
pertain to the Site, with the exception of chemical-specific ARARs in Site-wide groundwater for
which a waiver is invoked. A discussion of the requirements that are applicable or relevant and
appropriate to the selected remedy is provided in detail in Section 2 of the FS [M&E, 2005b].
Tables of federal and state ARARs and 'To Be Considereds" (policies, advisories, criteria, and
guidance also considered for the selected remedy) are included in Appendix F; a discussion of
why these requirements are applicable or relevant and appropriate is also provided in the tables in
Appendix F, as well as in Section 2 of the FS.
As discussed in the Technical Impracticability Evaluation Report [M&E, 2005c], EPA conducted
an evaluation to determine whether it was technically practicable to clean up the groundwater in
the area of the Site within a reasonable timeframe. The evaluation concluded that restoration of
both the overburden and bedrock aquifers in a reasonable timeframe is not practical for the
reasons discussed in Section I of this ROD.
A technical impracticability waiver of ARARs is warranted under NCP Section
300,430(f)(l)(ii)(C)(3) and EPA's Technical Impracticability Guidance for groundwater. The
groundwater zone over which the technical impracticability zone applies encompasses all areas in
the overburden and bedrock aquifers that are currently or conceivably could be impacted by
contamination emanating from the Site, as outlined on Figure 8.
The waiver applies to chemical-specific ARARs for groundwater at the Site, which include
Connecticut Remediation Standard Regulation (CT RSR) standards, including the Groundwater
Protection Criteria applicable to the GA groundwater underlying the Site, Surface Water
Protection Criteria, and the current and proposed Residential and Industrial/Commercial
Volatilization Criteria (which have not yet been promulgated and are "to be considered").
Chemical-specific ARARs also include federal Maximum Contaminant Levels (MCLs) which
govern the quality of drinking water provided by a public water supply, and are relevant and
appropriate requirements in establishing groundwater remediation goals for private wells. The
compounds and their respective ARARs for which a technical impracticability waiver will apply
are presented in Table 30. For compounds where no ARARs exist, risk-based goals are
presented. Human health risk-based goals are presented in Section 2 of the FS [M&E, 2005b].
The compounds include all chlorinated solvents released at the Site and related compounds, such
as breakdown products and additives (i.e., 1,4-dioxane) as well as other co-located compounds
dissolved in groundwater such as PAHs, BTEX compounds, and several metals (arsenic, copper,
lead, mercury, vanadium, and zinc). The chlorinated compounds are the most widespread and
recalcitrant, the most likely to restrict the ability to restore groundwater, and the primary risk
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drivers. There is little benefit to attempting to remediate co-located compounds, therefore the TI
waiver will apply to all dissolved contaminants found at the Site.
No waiver of location-specific or action-specific ARARs is required for the Site.
3. The Selected Remedy is Cost-Effeetive
In EPA's judgment, the selected remedy is cost-effcctive because the remedy's costs are
proportional to its overall effectiveness (see 40 CFR 300.430{f)(l)(ii)(D)). This determination
was made by evaluating the overall effectiveness of those alternatives that satisfied the threshold
criteria (i.e.. that are protective of human health and the environment and comply with all federal
and any more stringent ARARs, or as appropriate, waive ARARs). Overall effectiveness was
evaluated by assessing three of the five balancing criteria — long-term effectiveness and
permanence; reduction in toxicity, mobility, and volume through treatment; and short-term
effectiveness, in combination. The overall effectiveness of each alternative then was compared
to the alternative's costs to determine cost-effectiveness. The relationship of the overall
effectiveness of this remedial alternative was determined to be proportional to its costs and hence
represents a reasonable value for the money to be spent.
Remedy costs were estimated separately for each of the study areas as follows;
• MMC Study Area estimated cost; $2.2 million. Combination of Alternative MMC S-3C
Excavation and Off-site Disposal, and Alternative MMC SV-3 Soil Vapor Extraction.
• DMC Study Area estimated cost: $3.2 million. Alternative DMC GW-5 Soil Excavation
and Off-site Disposal.
• Site-wide Groundwater Study Area, Alternate Water Supply estimated cost: $7.0 million.
Alternative AWS-2 Connection to Middletown Water Distribution System.
• Site-wide Groundwater Study Area, Source Zone and Dissolved Plume estimated cost:
$434,000. Combination of Alternatives SZ-1 No Action and Alternative DP-6
Monitoring.
• Site-wide Groundwater Study Area, Contingency Remedy for Groundwater Containment
estimated cost: $8.7 million.
The estimated total of the remedy is $12,834,000 without the contingency for groundwater
containment, or action for any vapor intrusion beyond the DMC and MMC Study Areas. For the
Alternate Water Supply component of the Site-wide Groundwater Study Area, if the contingency
of AWS-3 Development of a New Groundwater Source and Distribution System is implemented
instead of AWS-2 Connection to Middletown Water Distribution System, some cost savings may
be achieved, however, any need for treatment would increase the cost estimate. (The cost
estimate for AWS-3 of $6.6 million does not include treatment.)
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Durham, Connecticut
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For the MMC Study Area, EPA determined that the combination of Alternative MMC S-3C
Excavation and Off-site Disposal, and Alternative MMC SV-3 Soil Vapor Extraction was the
most cost effective of the three remedial alternatives as it meets both threshold criteria and
provides the best balance of the five balancing criteria. This and two other combinations
provided the greatest degree of overall protection of human health, and were very similar in all
other comparisons. The selected combination, however, relies on a phased approach of soil
vapor extraction followed by excavation, which may reduce the volume and extent of soil
requiring excavation. This results in a monetary savings that places this combination at the least
expensive alternative that meets threshold criteria and allows for the least restrictive future use of
the MMC Study Area.
For the DMC Study Area, EPA determined that Alternative DMC GW-5 Soil Excavation and
Off-site Disposal was the most cost effective of the remedial alternatives as it meets both
threshold criteria and provides the best balance of the five balancing criteria. For all of the other
alternatives contemplated for this Study Area, the possible presence of DNAPL and possible
contamination under buildings and utilities increases the expected timeframe for reduction in
concentrations. All alternatives are expected to leave some residual DNAPL in overburden, and
it is not technically practicable to clean up this DNAPL, thus requiring institutional controls to
ensure protection of human health. Of all the remedial alternatives for this Study Area, the
selected alternative of excavation and off-site disposal is only the second least expensive,
however, it provides the greatest degree of overall protection of human health that is technically
practicable at this Study Area. (The least expensive alternative would meet RAOs after an
estimated treatment period of 50 years.)
Remedial alternatives for the Site-Wide Groundwater Study Area were divided into two
categories, provision of an alternate water supply, and treatment of the source zone and dissolved
plume. For the alternate water supply, the three alternatives were very similar in price, ranging
from $6.6 to $7.2 million. EPA determined that Alternative AWS-2 Connection to Middletown
Water Distribution System was the most cost effective of the remedial alternatives as it meets the
threshold criteria and provides the best balance of the five balancing criteria. Alternative AWS-
3, Development of a New Groundwater Source and Distribution System, is retained as a
contingency measure in the event that AWS-2, Connection to Middletown Water Distribution
System, cannot be implemented for administrative or other reasons, or cannot be implemented in
a timely manner.
For the source zone and dissolved plume, EPA determined that Alternatives SZ-1 No Action and
DP-6 Monitoring of the Dissolved Plume, in conjunction with implementation of an alternate
water supply and a technical impracticability waiver of chemical-specific ARARs, was the most
cost effective of the remedial alternatives as it meets both threshold criteria and provides the best
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Durham, Connecticut
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balance of the five balancing criteria. Alternative SZ-2 Groundwater Extraction for Hydraulic
Containment is also incorporated into the remedy as a contingency in the event that monitoring
results indicate that contaminated groundwater is likely to migrate beyond the limits of the
Technical Impracticability zone.
4, 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.
At the MMC Study Area, most of the alternatives proposed for soil or soil vapor, if assessed
individually, would not provide long-term effectiveness or permanence. Combinations of the
alternatives for the two media significantly improved long-term effectiveness and permanence,
and EPA determined that the combination of Alternative MMC S-3C Excavation and Off-site
Disposal, and Alternative MMC SV-3 Soil Vapor Extraction best satisfied this criteria. This
combination only partially satisfies the preference for treatment as a principal element; soil vapor
extraction will provide treatment and removal of VOCs, however, remaining contaminated soil
will be excavated and disposed off-site. No alternatives retained after the initial screening were
able to treat the combination of VOCs in soil and soil vapor, and PAHs and metals in soil due to
various reasons. Other alternatives were less technically or cost effective, or would pose an
unacceptable risk to residents located adjacent to the study area and at one residential property
located on-site.
At the DMC Study Area, all of the alternatives provide some measure of long-term effectiveness
by reducing concentrations of VOCs in both the hot spot areas and the associated plume.
However, the likely presence of DNAPL, including residual DNAPL within till fractures, creates
the possibility of residual contamination being available for dissolution many years into the
future. All alternatives provide adequate and reliable controls, with the possible exception of
alternative GW-4, in-situ chemical oxidation, due to the potential for mobilization of metals with
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Durham, Connecticut
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certain oxidant and soil types, EPA determined that Alternative DMC GW-5 Soil Excavation
and Off-site Disposal best satisfied this criteria, as it provides the greatest degree of overall
protection and is the most effective in the short term. This alternative does not satisfy the
preference for treatment as a principal element; instead, untreated waste will be primarily
disposed off-site (although some materials shipped off site may require treatment prior to
disposal).
At the Site-wide Groundwater Study Area, the alternate water supply alternatives all provide
some measure of long-term effectiveness by reducing or eliminating potential risk to human
health via ingestion of contaminated groundwater. The alternatives that provide water from the
City of Middletown or from an unspecified off-site well would provide the most long-term
effectiveness and permanence. None of the alternatives reduce toxicity, mobility, or volume
through treatment. Natural attenuation may eventually reduce the toxicity and volume of
contaminants in groundwater but will take many decades. AWS-4 provides some treatment of
contaminated groundwater through the use of filters, however this treatment is incidental and for
water supply purposes only; this alternative does not provide active remediation of contaminated
groundwater. Based on the lack of information to support the viability of an available nearby
supply well, EPA determined that AWS-2 Connection to Middletown Water Distribution System
best satisfied the criteria for long-term effectiveness and permanence. However, AWS-3,
Development of a New Groundwater Source and Distribution System, is retained as a
contingency measure in the event that AWS-2, Connection to Middletown Water Distribution
System, cannot be implemented for administrative or other reasons, or cannot be implemented in
a timely manner.
For the source zone and dissolved plume, while some of the alternatives satisfy the preference for
treatment, none of the alternatives provide certain long-term effectiveness and permanence.
Alternative SZ-2, groundwater extraction for hydraulic containment, would reduce
concentrations of VOCs in both the source zone and indirectly in the dissolved plume, but
residual risk from DNAPL will remain at the Site for many years into the future. Under
alternative DP-2, monitored natural attenuation for the dissolved plume, residual risk remains
due to contaminated groundwater for a timeframe likely greater than 100 years. Alternative DP-
3, groundwater extraction for restoration of the dissolved plume, may minimize migration of
contaminated water and reduce the size of the dissolved plume, but residual risk remains for a
timeframe likely greater than 50 years. Alternative DP-6, monitoring, includes no controls to
reduce contaminant levels.
Alternatives were combined to include DP-6 Monitoring of the Dissolved Plume, Alternative SZ-
1 No Action for the Source Zone, and Alternative SZ-2 Groundwater Extraction for Hydraulic
Containment (SZ-2 is specifically provided as a contingency, in the event that groundwater
plume migration does occur). In conjunction with the provision of an alternative water supply, as
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Durham, Connecticut
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well as a technical impracticability waiver for both the source zone and dissolved plume areas,
this combination achieves long-term effectiveness and permanence for protection of human
health and the environment.
5. The Selected Remedy Does Not Satisfy the Preference for Treatment as a Principal
Element
The selected remedy does not satisfy the statutory preference for treatment as a principal element,
primarily due to a determination that it is not technically practicable to clean up contaminated
overburden and bedrock, groundwater throughout the Site and at the DMC Study Area in a
reasonable timeframe. As described in Section I of this ROD, a technical impracticability waiver
of chemical-specific ARARs is warranted for groundwater at the Site.
Only the combination of alternatives at the MMC Study Area partially satisfies the preference for
treatment, by implementing soil vapor extraction to treat VOCs prior to excavating contaminated
soil and disposing of it off-site.
6. Five-Year Reviews of the Selected Remedy are Required.
Because this remedy will result in hazardous substances remaining on-site above levels that
allow for unlimited use and unrestricted exposure (and groundwater and/or land use restrictions
are necessary), a review will be conducted within five years after initiation of the remedial action
to ensure that the remedy continues to provide adequate protection of human health and the
environment. Five-year reviews will continue as long as waste remains at the Site and unlimited
use is restricted.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a Proposed Plan for remediation of the Site on July 12, 2005. The preferred
alternative included:
* Excavation and off-site disposal, in conjunction with soil vapor extraction, at the MMC
Study Area.
• Excavation and off-site disposal of hot spot areas at the DMC Study Area.
* Connection to the Middletown Water Distribution System to distribute an alternative
source of public water to all residences currently affected by groundwater contamination
and a buffer zone of residences located near the contaminated area.
• Implementing a monitoring network for the overall area of groundwater contamination to
ensure no migration of groundwater beyond its current general boundary.
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Durham, Connecticut
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• Contingency to implement a groundwater extraction system for hydraulic containment if
the overall plume or source zone migrates beyond its current general boundary.
• Implementation of a technical impracticability waiver of the applicable or relevant and
appropriate requirements that would normally require cleanup of the groundwater to meet
drinking water standards.
• Institutional controls in a variety of areas to prevent unrestricted future use of certain
areas of the Site or use of contaminated groundwater.
• Further delineation of areas posing potential indoor air risks on and outside of the MMC
and DMC Study Areas, and further actions to address any unacceptable risks.
EPA reviewed all written and verbal comments submitted during the public comment period. It
was determined that no significant changes to the remedy, as originally identified in the proposed
plan, were necessary.
A number of elected officials, citizens, and state agencies supported the proposal for an alternate
source of water, although a subset of comments preferred that the source of water be from an in-
town groundwater well instead of the connection to the City of Middletown Water Distribution
System. EPA also received comments identifying a number of technical and administrative
requirements for implementing the Middletown Water Distribution System alternative. As a
result, EPA retained the connection to the City of Middletown Water Distribution System as the
preferred alternative water source, but identifies the development of and connection to a new
groundwater source as a contingency measure in the event that the preferred alternative cannot be
implemented for administrative or other reasons, or cannot be implemented in a timely manner.
Given that both alternatives were presented in the Proposed Plan and EPA specifically requested
comments on both alternatives, as well as the fact that these alternatives share many common
elements, EPA does not consider the inclusion of AWS-3 as a contingency measure to be a
significant change to the remedy.
Also included is the interim measure of continued monitoring and filtration, and provision of
bottled water as necessary, of impacted residential wells, and any other residential wells within
the Site-wide Groundwater Study Area that come to be impacted by Site-related contamination,
as currently required under state order and state regulations, to ensure continued protectiveness of
human health and the environment until construction of the alternate water supply portion of the
remedy is complete and operational. This activity is currently occurring under state order, and as
such, EPA does not consider the inclusion of this interim measure to be a significant change to
the remedy.
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Durham, Connecticut
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O. STATE ROLE
The Connecticut Department of Environmental Protection has reviewed the various alternatives
and has indicated its partial 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 and
facility siting laws and regulations. The State of Connecticut partially concurs with the selected
remedy for the Durham Meadows Superfund Site. A copy of the declaration of concurrence is
attached as Appendix C.
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Durham, Connecticut
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Appendices
Appendix A
Tables
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Durham, Connecticut
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Date: September 30, 2005
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Appendices
LIST OF TABLES;
Section D. Scope and Role of Response Action;
Table 1. Site Contaminants Summary.
Section G.l. Human Health Risk Assessment;
Table 2, Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Current, Soil, Surface Soil,
Table 3, Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Future, Soil, Surface Soil.
Table 4, Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Current/Future, Soil Gas, Indoor Air.
Table 5. Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Future, Shallow Groundwater, Indoor/Outdoor Air.
Table 6, Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Future, Groundwater, Shallow Groundwater.
Table 7. Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Current/Future, Groundwater, Bedrock Groundwater.
Table 8. Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Current, Groundwater, Bedrock Groundwater (Private
Wells).
Table 9. Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration; Future, Groundwater, Bedrock Groundwater.
Table 10. Cancer Toxicity Data Summary.
Table 11. Non-Cancer Toxicity Data Summary.
Table 12. Risk Characterization Summary - Carcinogens; Current, Adjacent
Resident, Young Child/Adult.
Table 13. Risk Characterization Summary - Carcinogens; Future, Resident, Young
Child/Adult.
Table 14. Risk Characterization Summary - Non-Carcinogens; Future, Resident,
Young Chi Id/Adult.
Table 15. Risk Characterization Summary - Carcinogens; Current/Future,
Commercial Worker, Adult.
Table 16. Risk Characterization Summary - Non-Carcinogens; Current/Future,
Commercial Worker, Adult.
Table 17. Risk Characterization Summary - Non-Carcinogens; Future, Construction
Worker, Adult.
Table 18. Risk Characterization Summary - Carcinogens; Current, Resident, Young
Child/Adult.
Table 19. Risk Characterization Summary - Non-Carcinogens; Current, Resident,
Young Child/Adult.
Table 20. Risk Characterization Summary - Carcinogens; Future, Resident, Young
Child/Adult.
Table 21. Risk Characterization Summary Non-Carcinogens; Future, Resident,
Young Child/Adult.
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Durham Meadows Superfund Site
Durham, Connecticut
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Appendices
Section G.2. Ecological Risk Assessment:
Table 22. Selection of contaminants of potential concern in surface water from Ball
Brook,
Table 23. Selection of contaminants of potential concern in sediment from Ball
Brook,
Table 24. Selection of contaminants of potential concern in wetland soil.
Table 25. Ecological exposure pathways and endpoints.
Table 26. Hazard quotients for surface water from Ball Brook,
Table 27. Hazard quotients for the sediment samples from Ball Brook.
Table 28. Hazard quotients for shrew (maximum exposure scenario).
Table 29. Hazard quotients for the shrew (mean exposure scenario).
Section 1.3. Technical Impracticability Evaluation:
Table 30. Compounds To Which Technical Impracticability Waiver Will Apply.
Section L.3. Summary of the Estimated Remedy Costs:
Table 31. Cost Estimate for MMC Study Area.
Table 32. Summary of Present Worth Analysis - MMC Study Area.
Table 33. Cost Estimate for DMC Study Area.
Table 34. Summary of Present Worth Analysis - DMC Study Area.
Table 35. Cost Estimate Summary for Alternative Water Supply.
Table 36. Summary of Present Worth Analysis - Alternative Water Supply.
Table 37. Cost Estimate Summary for Site-wide Groundwater Study Area
(Monitoring).
Table 38. Summary of Present Worth Analysis - Site-wide Groundwater Study Area
(Monitoring).
Table 39. Cost Estimate Summary for Site-wide Groundwater Study Area
(Contingency Remedy for Hydraulic Containment).
Table 40, Summary of Present Worth Analysis - Site-wide Groundwater Study Area
Contingency Remedy for Hydraulic Containment),
Section L.4.a. Cleanup Levels By Study Area:
Table 41. Cleanup Levels for the MMC Study Area.
Table 42. Interim Cleanup Levels for the DMC Study Area.
Table 43, Interim Cleanup Levels for the Site-wide Groundwater Study Area.
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version; FINAL
Date: September 30,2005
Appendices
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Table 1. Site Contaminants Summary
Princioal Threats
Source/
Affected Media
Contaminants
Maximum Concentration
Reason(s)
Receptors
Source
(from validated data used in HHRA)
Media
DNAPL
Groundwater
VOCs
Bedrock Groundwater (ua/L):
Soil
Soil
1,4-Dioxane
1.2-DCA (0.8)
Mobility
Resident
PAHs
Benzene (5)
Toxicity
Commercial
Soil Vapor
cis-1,2-Dichloroethene (640)
Worker
Metals
Methylene Chloride (51)
Tetrachloroethene (210)
Trespasser
Trichloroethene (2,500)
Construction
Vinyl chloride (18)
Worker
1,4- Dioxane (34)
Benzo(a)Anthraeene (1)
Benzo(a)pyrene (1)
Benzo(b)f!uorantbene (1)
Bis(2-ethylhexyl)phthalate (7)
Dibenz(a h)anthracene (1)
lndeno(1.2.3-cd)pyrene (1)
Pentachloropheriol (28)
Arsenic{25)
Mercury (4,2)
Vanadium (34.5)
Overburden Groundwater (ua/L)
TCE (66,000)
Soil Vaoor (DDbvl:
TCE (6,900)
S0il (mQ/kq):
TCE (26)
As (130)
Cr (8,370)
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BaA (41)
BaP (43)
BbF (41)
Dibenz(a.h)anthracene (9.2)
lndeno(1,2,3-cd)pyrene (27)
Low Level Threats
Source Media
Affected
Media
Contaminants
Receptors
Soil
•Indoor Air
(potential,
not
confirmed)
•Surface
Water
•Sediment
VOCs
PAHs
Metals
Resident
Commercial Worker
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ROD RISK WORKSHEET
Table 2
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(1)
Minimum
Maximum
Merriam Manufacturing
Benzo(a)a nthracene
0 053
41
trig/kg
4/4
41
mg/kg
Max
Benzo(a)pyrene
0.06
43
mg/kg
4/4
43
mg/kg
Max
Benzo(b)fluoranth©ne
0.08
41
mg/kg
4/4
41
mg/kg
Max
Dibenz(a,h)anthracene
0.2
9.2
mg/kg
2/4
9.2
mg/kg
Max
Indenof 1,2,3-cdJpyrene
0.052
27
mg/kg
4/4
27
mg/kg
Max
Arsenic
2 5
66
mg/kg
4/4
6.1
mg/kg
95% UCL - N
Key
(1) Statistics: Maximum Detected Value (Max); 95% UCL of Transformed Data (95% UCL • T); 95% UCL of Normal Dala (95% UCl - N), 95% UCL of Non-parametric Data (95% UCL - NP],
95% UCL of Gamma Distributed Data (95% UCL - G), Arithmetic Mean (Mean)
The table represents the current chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in surface soil (i e., the concentrations that will be used to estimate the exposure
and risk for each COC in surface soil). The table includes the range of concentrations detected for each COC, as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples
collected at each exposure point!. the EPC. and how the EPC was derived. This Sable indicates that the inorganic compound arsenic and the organic polycyclic aromatic hydrocarbons (PAHs) are the most frequently
detected COCs in surface soil at the site The 95% UCL on the arithmetic mean was used as the EPC for arsenic. Due to the limited amount of sample data for the PAHs, the maximum detected concentration was used
as the default EPC for benzo(a)anthracene, benzofajpyrene benzo!b}fluoranthene. dibenz(a,h)anthracene, and indeno(1 .2,3-cd)pyrene.
Source: A Guide to Preparing Superfurtd Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 3
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(1)
Minimum
Maximum
Merriam Manufacturing
Trichloroethene
0.001
26
mg/kg
13/35
8.3
mg/kg
95% UCL•NP
Benzo(a)anthracene
0.052
41
mg/kg
28/35
14
mg/kg
95% UCL-NP
Benzo(a}pyrene
0.05
43
mg/kg
28/35
15
mg/kg
95%UCL-NP
Benzo(b)fiuoranthene
0.048
41
mg/kg
30 / 35
16
mg/kg
95% UCL-NP
Dibenz(a, h )a nth racene
0.02
9.2
mg/kg
21 / 35
3.2
mg/kg
95% UCL-NP
lndeno(1,2,3-cdJpyrene
0.052
27
mg/kg
27/35
10
mg/kg
95% UCL-NP
Arsenic
0.00083
130
mg/kg
29/35
44
mg/kg
95% UCL-NP
Chromium
0.0064
8370
mg/kg
35/35
2755
mg/kg
95% UCL-NP
Key
(1) Statistics Maximum Detected Value (Max), 95% UCL of Transformed Data (65% UCL - T5; 95% UCL of Normal Data (95% UCL - N); 95% UCL of Non-parametric Data (95% UCL - NP):
95% UCl of Gamma Distributed Data (95% UCL - G); Arithmetic Mean (Mean)
The table represents the future chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in surface soil (i.e., the concentrations that will be used to estimate the exposure
and risk for each COC in surface soil). The table includes the range of concentrations detected for each COC as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples
collected at each exposure point), the EPC. and how the EPC was derived This table indicates that the inorganic compound chromium is the most frequently detected COC in surface soil at the site. The 95% UCL on
the arithmetic mean was used as the EPC for all COCs
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents {U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 4
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Soil Gas
Exposure Medium: Indoor Air|3>
Exposure Point
Chemical of
Concern
Concentration
Detected
Minimum
Maximum
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(1)
Mernam Manufacturing
T richloroathene
4.6
37082
ug/m
4/5
37082
ug/m
Max
Key
{1) Statistics' Maximum Detected Value (Max); 95% UCL of Transformed Data (95% UCL - T); 95% UCL of Normal Data (95% UCL - N), 95% UCL of Non-parametric Data (95% UCL - NP)
95% UCL of Gamma Distributed Data (95% UCL - G); Arithmetic Mean (Mean)
(a) Soil gas concentrations were modeled to indoor air concentrations using ERA'S Johnson and Ettinger model Measured soil gas concentrations are presented in this table.
The table represents the current/future chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in soil gas (i.e., the concentrations that will be used to estimate the exposure
arid risk for each COC in soil gas) The table includes the range of concentrations detected for each COC. as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples
collected at each exposure point), the EPC, and how the EPC was derived This table indicates that trichloroethene is the oniy COC in soil gas at the site. To estimate a conservative indoor air concentration from the so
gas data, the maximum detected soil gas concentration was used as the EPC for tnchloroetherie.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 5
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Shallow Groundwater
Exposure Medium: Indoor/Outdoor Air ""
Exposure Point
Chemical of
Concern
Concentration
Detected
Minimum
Maximum
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(1)
Durham Manufacturing
Trichloroelhene
66000
ug/l
19/24
39284
ug/L
95% UCL-T
Key
(1) Statistics' Maximum Detected Value (Max); 95% UCL of Transformed Data (95% UCL - T); 95% UCL of Normal Data (95% UCL - N); 95% UCL of Non-parametric Data (95% UCL - NP);
95% UCL of Gamma Distributed Data (95% UCL - G); Arithmetic Mean (Mean).
;«! Shallow groundwater concentrations were modeled to indoor/outdoor air concentrations using EPA's Johnson and Ettiriger model. Measured shallow groundwater concentrations are presented in this table.
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in shallow groundwater (i.e., the concentrations that will be used to estimate the exposure
and risk for each COC in shallow groundwater). The table includes the range of concentrations detected for each COC, as well as the frequency of detection (i.e. t the number of times the chemical was detected in the
samples collected at the site), the EPC. anc! how the EPC was derived This table indicates that trichioroethene is the only COC in shallow groundwater at the site. To estimate an indoor/outdoor air concentrations from
the shallow groundwater data, the 95% UCL on the arithmetic mean was used as the EPC for trichioroethene.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, arid Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 6
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Shallow Groundwater
Exposure Point
Chemical of
Concern
Concentration
Detected
Minimum
Maximum
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
m
Durham Manufacturing
Tnchforoethene
66000
ugfl-
19/24
39284
ugfl-
95% UCL - T
Key
(1) Statistics: Maximum Detected Value (Max), 95% UCL of Transformed Data (95% UCL - T); 95% UCl of Normal Data (95% UCL - N); 95% UCL of Non-parametric Data (95% UCL - NP);
95% UCL of Gamma Distributed Data {95% UCL - 6); Arithmetic Mean (Mean)
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in shallow groundwater (i.e., the concentrations that will be used to estimate the exposure
and risk for each COC in shallow groundwater). The table includes the range of concentrations detected for each COC, as well as the frequency of detection {i.e., the number of times the chemical was detected in the
samples collected at the site), the EPC and how the EPC was derived. This table indicates that trichloroethene is the only COC in shallow groundwater at the site. The 95% UCL on the arithmetic mean was used as the
EPC for trichloroethene
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, arid Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 7
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium; Groundwater
Exposure Medium: Bedrock Groundwater
Exposure Point
Chemical of
Concern
Concentration Detected
Minimum
Maximum
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(D
Durtiam Manufacturing - DMC#1
Tetrachloroethene
ug/L
1 12
ug/L
Max
T richloroethene
84
150
ug/L
212
150
ug/L
Ma*
Key
(1) Statistics: Maximum Detected Value (Max); 95% UCL of Transformed Data (95% UCL - T); 95% UCL of Normal Data (95% UCL - N); 95% UCL of Non-parametric Data (95% UCL - NP);
95% UCL of Gamma Distributed Data (95% UCL - G); Arithmetic Mean (Mean)
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs delected in well DMC#1 bedrock groundwater (i.e., the concentrations that will be used to estimate
the exposure and risk for each COC in well DMC#1 bedrock groundwater). The table includes the range of concentrations detected for each COC. as well as the frequency of detection (i.e., the number of times the
chemical was detected in the samples collected at the well), the EPC, and how the EPC was derived- This table indicates that the organic chemical trichioroethene is the most frequently detected COC in bedrock
groundwater at well OMC#l. The maximum detected concentration was used as the default EPC foe all COCs detected in well DMC#1 bed nock groundwater.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table S
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Bedrock Groundwater (Private Wells)
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(D
Minimum
Maximum
11 Maiden
TnchSoroethene
88
u01
2/2
S3
utfL
Max
l10 Mapte
Telrachtoroetfwne
0 5
OS
ug/l
1/2
0.5
y^L
Ma*
T riehiorotthcrvfe
13
20
ugA.
2/2
20
Ma*
133 MBpiB
Teiraehtorofitfiena
02
0.3
ugfl.
3/5
0.3
ug/l
Max
Trichloroethene
C 5
16
5/5
16
uiQfL
Max
139 Maple
TeiracAforaeVifine
02
0.2
u$l
1/2
0.2
ug/l
Max
T nchloroethene
36
16
Uftfl.
2/2
16
ug/L
Ma*
168 Main
t.2-Dic^.Jofoafhena (lara!)
310
3 SO
u$L
2/2
38Q
ug&
Ma*
Bartons
1
5
ugfl.
2/4
5
VBfL
Max
as-1,2-Oichtoraethene
410
410
ugtl
1 12
410
ug/L
Max
Teirachlaroeihene
20
38
u$i
3/4
2&
ugn
Max
Trjeftfometheri®
ttoo
1300
UQfL
3/4
T300
ugft.
Max
Vinyl chloride
11
3/4
11
ugfL
Ma*
Arsenic
11 1
138
uqtl
3/4
13.8
uejfL
Max
174 Mam
1,2-Dichioroethene dotal)
420
680
ug»'l
212
880
ugn.
Max
Methylene Chloride
34
34
vg/L
1 12
34
ugfl
Max
T etrac^ii woe?h^r.e
42
70
ujyi
2! 2
70
ug/L
Max
Tri^ioroethferie
1500
2500
ug-'i
2/2
2500
u^L
Max
Vinyl cWande
9
9
u0fL
i ! 2
9
ugi'L
Max
.Arsenic
23 5
21 5
u^'L
1J2
21 5
u#L
Max
1?e Mam
Tetfachtoroeth*r*9
0.3
06
ug/L
2/4
08
U9TL
Max
Trichloroethene
2
80
y^'L
3/ 4
30
ug/L
Max
Benzo(a)anlhracpne
1
ugfl.
1 / I
1
UtfL
Ma*
Benzola^pyrene
1
1
ug'L
1 f \
1
u^'L
Max
0eri£o{b}fluoranthene
1
1
ug/l
1 / 1
1
ug/l
Max
Dibariz{a,h)artfirac9ne
1
ugll
1 / 1
1
ufl/l
Max
lndano(1,2.3-cdSpyrena
1
1
ug/L
1 ! 1
1
ugfL
Max
Penlachlorophenol
28
28
ug/l
1 / !
28
yg?L
Max
t8 Maiden
Tnchloroethene
58
58
ugfl
1 / 2
5.8
ug-'L
Max
186 Main
Teirachloroeltierie
3
a 3
u^L
2/7
43
ug/L
Ma*
T rich lo res the^e
27
32
UU'L
2 .'2
32
Ufl/L
Max
1$ Maiden
Tetrachloroettiane
06
06
ug/L
1 .' 2
06
ug?L
Max
Tnchlonoefhene
06
12
ug/L
2/2
12
ug/L
Max
-------
ROD RISK WORKSHEET
TabiaS
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Bedrock Groundwater {Private Wells)
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
PtlBCtfen
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
t
2 4
ta
ug'L
Mas
Bis(2^thylhfcxyl)phth«1a»
7
7
ugil
1 1 3
?
ug/l
Max
Arsensc
69
25
ugrt.
1M
25
ug/l
Ma*
196 mm
TetracNIoroBlhenei
04
04
uqIL
2 3
04
ug/L
Max
Trichloro«1fi«ne
9&
18
ugA,
3/3
1S
ug/t
Max
202 Man
T etracMoroetMnft
06
0.6
ug/L
1 l 2
06
ug#L
Max
Trrchtofaaihene
54
22
ug>'l
2/2
22
u&l
Max
205 Warn
T etcachioratithem
02
03
ugfi
2 3
03
ug/L
Max
TncWof"Ci«tn«n6
S3
2S
ug/L
3/3
26
ug/L
Max
227 *ta«i
Tetrgchiaroetiene | 0 3
09
UQ/'L
2 i 2
09
ug/L
Max
Tnchloroaiharie j 11
18
ugfL
2 i 2
18
ugrL
Max
?35 Main
TetrachlcroetNrne
04
0 4 ug'l
1 / 2
04
ug/L
Max
Trichloraelhena
09
12
u^'L
2(2
12
ug/L
Ma>
238 Mam
TricWomaihane
5S
7 1
y^'L
2/2
7 1
ug/L
Max
239 Wam
Totrachlfcroelhene
02
08
u(A
2/2
OS
ug/L
Max
T nthlaroethene
82
27
u&'L
2 / 2
27
ug>L
Max
24 Maiden
Tnchloroeth«n€
6
6
ug/L
1 / 2
6
ug#L
Max
242 Main
T eiracftlofoetherie
l 5
2
ug/L
2/2
ug/L
Max
T rK^otioe(h«n*
53
54
ugfL
2/2
54
ug/L
Max
243 Main
Tel ra c hi oroetfie^e
1.2
1.2
u»fl
! ' 2
V2
ugfL
Max
Tnchlaroettsene
1 7
45
u»a
2/2
45
ug'L
Max
246 Mam
T eirachioroethene
1 2
1 4
2/2
1 4
ug/L
Max
TncNoroethene
53
58
U3/L
2/2
hd
ug/l
Max
-------
ROD RISK WORKSHEET
Table 8
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium; Bedrock Groundwater (Private Wells)
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
d)
Minimum
Maximum
248 Main
Teiracr)?oroe1*ieie
3 3
3 8
ug/l
W2
38
yg/L
Max
T nchinroelhene
140
140
ug/l
1 12
14D
ug/L
Max
252 Wain
f,4-P;o*arw
4
8S
ug/L
in
86
ug-'L
Ma*
Tfifracfiioraelfterta
5 1
ug/L
2 i 4
5 1
ug/l
Max
rncWaraeCtene
ts
68
og/l
as
ug/i.
Max
Sis{2-«tf(yfrte*^)pfifhafafe
s
G
ug/L
t ?
5
ugfl
Ma*
Arsenic
?
?
ug/L
f ?
t
tt&L
Max
253 Main
Tfllracfiloroeinene
1.1
2
ug/L
2/2
2
ug/l
Max
TricNaroeihene
66
130
yg/L
212
130
ug/L
Max
256 Main
1,4-Diajten*
2
14
6/7
U
Ma*
Tslrachloroatti»n«
3 4
34
vift'L
1 n
34
uQfl.
Max
Jnchloroeih^ne
im
200
UgflL
? i
200
ugtl
Max
257 Main
Telracftlomalfcene
0.45
>4
ug/L
2 < 2
1.4
ug/L
Max
TnchiofQeihene
38
94
u«A.
2 i' 2
94
ug/L
Max
2S1 Main
T etrachJorcfethene
2
4
uS'L
2-'2
4
iii^L
Max
Tncnioro8lh$ri8
110
1S0
ug/l
2/2
100
ug/l
Max
Arsenic
& 7
67
upl
1 2
6?
Ma*
Vanadium
34 5
345
1/2
34 5
u^L
Max
262 Mato
Tatrachloroethene
1 5
uflfl.
2/2
2
ug/L
Max
Tnchiome thane
65
73
Mg/L
2/2
73
ug/L
Max
Z5S Main
TetracMorwsthene
1
2 3
k^'t
2/2
2.3
ug/L
Max
Tocnioroelhene
165
94
ugfL
2/2
94
ug.'l
Max
26? Mam
Teirachioroethene
42
5
bg/L
2/2
5
UQ/L
Max
fnchlo'Mihene
200
220
ug/l
2/2
220
ug/L
Mat
Arsenic
79
79
u^'L
1 1
79
ug/L
Max
-------
ROD RISK WORKSHEET
Table 8
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Bedrock Groundwater (Private Wells)
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Unite
Statistical
Measure
Hi
Minimum
Maximum
268 Main
M-Dioxaoe
0 90S
26
ug/l
9 i 9
26
J# L
Max
T etra chl oroethene
3
3
ug/L
3(4
3
ug/L
Max
Tnchioroetbene
S3
no
u&'l
3/4
110
up/L
Ma*
Vinyl chloride
02
D2
ug/l
1 i 4
02
~g/L
Max
8 enz.
The table represent ma chemicals of concern (COCsf and exposure point concentrations (EPGs) (or each of the COCs detected m Oedrack groundViBler from each pnvate well {i e , me concenirations lhaf *Hl be used io
esltmafe fne exposure and risk for each COC in bedrock groundwater from each private The tatsie tricfudas the range of concentrations defected for each COC. as xMeJf as tne frequency of detection (f e , the number
of times Ibe chemical wss oat frequently detected COC in
bedrock groundwater at the site The maximum delected concentration *as used as the EPC Jar all COCs delected m fcedrocfc graunrt*at«r from each private *eH
Source; A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Document* (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 9
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: future
Medium: Groundwater
Expos Lira Medium: Bedrock Groundwater
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
en
Minimum
Maximum
Site Wide
1 2-0ichloroethane
0.2
08
ug/L
4/142
08
ug/L
Max
1,2-Dichteroethenxane
0 51
34
ug/L
72/14?
34
ug/L
Max
Benzene
0.2
5
ug#L
4; 77
5
ug/t
Max
cis-1,2-DiChlOfae?hene
02
640
ug/L
77/145
640
ug/L
Max
Methylene chloride
0.16
51
U$L
40/184
51
ug/L
Max
T eirachloroethene
Q2
210
yg/L
94/189
210
ug/L
Max
Trtchforoefhene
0.19
2600
ug/L
152 1B9
2500
ug/L
Max
Vinyl Chionde
02
18
ug/L
13/189
18
ug/L
Max
Benzo^ajanthraeene
0 105
1
ug/L
3/27
1
ug/L
Max
Benzol a)pyrene
0.105
1
ug/L
3/27
ug/L
Max
Benzo(bjfluoranthene
0.01
1
ug/L
4/27
1
ug/L
Max
Bis(2n9lhylhe*yl}phlha1aie
2
?
ug/L
3/27
7
ug/L
Max
Oiberi2(a,h]anihracene
0 105
1
ug/L
3/2?
ug/L
Max
indent^ 1,2.3-cd )py rene
0.105
1
ug/L
3/27
ug/l
Max
Pentachiorophenol
28
28
ug/L
1 / 27
2a
ug/L
Max
Arsenic
0.6
25
ug/L
15/29
25
ug/L
Max
Mercury
4 2
4 2
ug/L
1 12 9
42
ug/L
Max
Vanadium
0.55
34,5
ufl/L
16/29
34 5
ug/L
Max
Key
[ 1) Statistics. Maxprnum Delected Value (Ma*), 95% UCL of Transformed Data (96% UCL - T>. 95% UCL of Normal Data (95% UCL - N). 95% UCL of Non-parametric Data (9S% UCL - NP),
95% UCL of Gamma Distributed Data (95% UCL - G), Arithmetic Mean (Mean)
The table represents the chemtcafs of concern (COCs.) and exposure point concentrators (EPCsJ for each of the COCs detected rr Sra-wete bedrock groundwater (r e. the concentrations thai wrff 5e used to eshmaie the
exposure and n$k for each COC in SHe-wide bedrock groundwater) The table includes tne range of concentrations detected lor each COC. as well as the frequency of detection (i e , the number of times the chemical was
detected in tne samples collected a? the s-te). the EPC, and how the EPC was denied This tabie indicates that the organic chemical tnr.hlcroetnene is the most frequently detected COC in Site-wide bedrock groundwater at
the sile The mammum delected concentration was used as the EPC for alt COCs detected in Sue-wide bedrock groundwater
Sourer A Guide to Preparing Superfcmd Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
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ROD RISK WORKSHEET
Table 10
Cancer Toxicity Data Summary
Pathway: Ingestion, Dermal
Chemical of
Concern
Oral Cancer
Slope Factor
Dermal Cancer
Slope Factor
Slope Factor
Units
Weight of
Evidence/Cancer
Guideline Description
Source
Date
(MM/DD/YYYY)
1.2-Dichloroethane
9.1E-02
9.1 £-02
(mg/kg-day)'1
B2
IRIS
01/05/05
1,2-Dichloroethene (total)
N/A
N/A
N/A
D
tRIS
01/05/05
1 A-Dioxane
1.fE-02
t.lE-02
(mg/kg-day)"1
B2
mm
0!/05/05
Benzene
5.5E-02
5.5E-G2
(mg/kg-day)"'
A
IRIS
01/05/05
ci s -1.2 ¦ D ich lor oeth e n e
N/A
N/A
N/A
0
IRIS
01/05/05
Methylene chloride
7 5E-03
7.5E-03
(mg/kg-day)1
B2
IRIS
01/05/05
Tetrachloroelhene
5.4E-Q1
5.4E-01
(mg/Kg-day)1
B2
CalEPA
01/05/05
Trichloroethene
4.0E-01
4.0E- 01
(mg/kg-day)'1
C 32
NCEA
01/05/05
Vinyl Chloride
7.5E-01
7.5E-01
{mg/kg-day)"1
A
IRIS
01/05/05
Ben20( a) a nth r acene
7 3E-04
7.3E-01
(mg/kg~day)1
B2
IRIS
01/05/05
Benzo(a)pyrene
7.3E+G0
7 3E+00
(mg/kg-day)'1
B2
IRIS
01/05/05
8enzo(b)fiuoranthejie
7 3E-01
7.3E-01
{mg/kg-day)'
B2
IRIS
01/05/05
Bis^2-ethythexyt)phlhalate
1 4F-02
1.4E-02
(mg/kg-day)1
B2
IRIS
01/05/05
Diben£(a.hjanthracene
7.3E+00
7.3E+00
{mg/kg-day)'1
B2
IRIS
01/05/05
Indeno(l ,2,3-cd)pyrene
7.3E-01
7,3E-01
{mg/kg-day)f
B2
IRIS
01/05/05
Peniachlorophenol
1.2E-01
1.2E-01
{mg/kg-day)1
B2
IRIS
01/05/05
Arsenic
1,5E*QG
1.5E+00
(mg/kg-day)"1
A
IRIS
01/05/05
Chroniium
N/A
N/A
HIA
D
mis
01/05/05
Mercury
N/A
N/A
N/A
G
mts
01/05/05
Vanadium
N/A
N/A
N/A
N/A
N/A
N/A
Pathway: Inhalation
Chemical of
Concern
Unit Risk
Units
Inhalation
Cancer Slope
Factor
Weight of
Evidence/Cancer
Guideline Description
Source
Date
(MM/DD/YYYY)
1,2-Dichloroethane
2.8E-05
(u gmY
N/A
B2
IRIS
01/05/05
1,2 Dichkyroethene (total)
N/A
N/A
N/A
D
}RSS
01/05/05
Benzene
7.8E-08
(mmY
N/A
A
IRIS
01/05/05
os 1,2- Dichloroethene
N/A
N/A
N/A
D
IRIS
01/05/05
Methylene chloride
4.7E-G7
(ug/m3)1
N/A
B2
IRIS
01/05/05
Tetrachloroelhene
5 9E 06
{ug/m3)1
N/A
B2
CafEPA
01/05/05
Trichloroethene
1.1 £-04
{ug/mV
N/A
C-B2
NCEA
01/05/05
Vinyt Chloride
4.4E-06
(ug/m3)"1
N/A
A
IRIS
01/05/05
Key EPA Group
N/A: Not applicable A - Human carcinogen
IRIS: integrated Risk Information System, U S. EPA B1 - Probable human carcinogen - Indicates thai limited human data are available
NCEA; National Center for Environmental Assessment, U.S. EPA B2 - Probable human carcinogen - indicates sufficient evidence in animals and inadequate or no
CalEPA = California Environmental Protection Agency evidence in humans
C - Possible hum an carcinogen
D - Not classifiable as a human carcinogen
E - Evidence of noncarcinogenicity
This table provides the carcinogenic nsk information which is relevant 10 the contaminants of concern in soil, soil gas. and groundwater Al this time, slope factors are not available lor
the dermal route of exposure. Thus, the dermal slope factors used in this assessment have been extrapolated from oral values. An adjustment factor is sometimes applied, and is
dependent upon how well the chemical is absorbed via the oral route. Adjustments are particularly important for chemicals with less than 50% absorption via the ingestion route.
However, adjustment is nor necessary for the chemicals evaluated al this site Therefore, the same values presented above were used as the dermal caranogerwc slope factors for
these contaminants Available inhalation unit risk values are also provided for the volatile COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
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ROD RISK WORKSHEET
Table 11
Non-Cancer Toxicity Data Summary
Pathway; Ingestion, Dermal
Chemical of
Concern
Chronic/
SwbchrorrJc
Oral RfD Value
Oral RfD Units
Dermal RfD
Dermal RfD
Units
Primary Target
Organ
Combined
Uncertainty/
ModfPiring
Factors
Sources or RfD:
Target Organ
Dales of Rfd:
Target Organ
(MM/DDATYY)
l 2-0,tlWQetrig-s«y
Kidney
3000
NC£A
01'05/05
i 2-Dichleroeih*n« (tolal;
Chron*-
1 0E-C2
mg/kg rtay
1 01-01
Blood
3000
NCFA
01 (TO/OS
* 4
Ch'Of'C
N'ft
N-A
tL'A
Ni'A
N/A
N/A
MA
WA
ChMflUT
4 CM -G3
mg/kg-day
<4- iiE-<33
InT^u^eSyi!#*"
300
WfS
01-115/05
cis-1 V-DwhloioHhene
Ch.-onic
1 3€-C2
- 06 02
mp^Kg-da^
Blood
2000
NCEA
C1/05.0S
iWorxle
Chr gmc
6 36 02
ing/sg
6 CF-02
mq/|.g-<33y
100
IRIS
Q1/n5/D5
~fltr9rtitorQein«nt>
Chronic
1 01.0?
Ti^S-.g-diiy
1 DE-02
mBi'kg-day
UVK
lOUC
IRIS
€1/05/05
'nthioioethene
Chronic
3 Q£~C4
rtiB/kg-das1
3 C€ 04
mj/Vqdav
..VSI
3000
NCEA
Ol.TOOS
TjiCf>iyroetften«
SuDcWOAiC
3 DE-C<
wg/hg-os*
n oi 04
Ctver
-moo
NCEA
H1rt)6fQ5
Vmyl C-Ioi,oe
Chrnmc
3 WE-03
-ns/kg-tfay
a DE-03
mykg-day
Liver
30
IRIS
O1/0&135
Seme* 9131 ^ravifire
CflfOflNT
Ni"A
WA
IWA
WA
r-i/A
N/A
WA
N/A
0#nio. 2.3-CJ3 joy es^e
Chronic
U*A
UiA
N/A
N/A
N/A
N/A
WA
NfA
PwtachiDFophenai
Chianic
3 Or -02
mg/kg-dBy
3 DE-C?
-^.gAg-dsy
livefKidney
1U0
IRIS
3335?
4>ssnte
ChtdfHC
3 0E-M
m&kg-tey
3 0S-04
miin«iy """at'??
cvt. Jrrtf D'iwi*
Thi» t»bi« piu-rdirv f3n-t.S'CmB«5isnn; iikk miorms'ion Yiami!*,ant* of in soil, ttxi #"0 e
he*iTfv efleu> hi humans Ch'on'i. and iubc*na^t« ^mcily data avails)* 1v '.he (QU'ttHfi t;GC» fur o «o""ic om; Terence desss sRfDsf. prov»8#d in tf-.it »b<« Th« avwluifvcnrunic antf subcfiftxuc
loxidy ciata indicate tnat qmwmi affects I he 'Wftiune ti'ionae. Tetraciei«theiie. !r c.i*cvo#Ui«"w y-iifi *w"-(i¥l)ph!MaHitit and p^ntachiyrupriertQi s^sct I in iivet, 1 ^dichio'iMt^Mnf ptiWacNoropHBrioi an
vandOium [»• *nS"tf i J C'Clher,* *r,a 2-d«cftiofoei^ef!«- affed iM wood. *> wwi j^pcIs. i*m> »km c acacia lie u»s7rci'ir«|!nrfi mti s*c w*icury *fteers l*f ctnr.'ai n^voui syjlo/n R»rnvnc« aos» *t» r>of jvaiiatote
4-<5iaxiine »ht i Afcmixjmi c PANs Ddmsi RlDs arc noi iai>'e fw any ol -he cOCs As «a«. Ti» ta»« bn (he c«icinag«m>, 3a!a. fc'Dv >.dn fcewtiapoiatau from oral H10* la* applyi^ an a3|u*tmrM faulu' as *pprupii*t«
Cxai RftJis we adjusted 1m CUC> wtl'i Its* than hO':i. atuwiCt'O" ru i-yeiiiQn tout# ichigrriium rr>int#"-2 > i« derive duimal -51IH *or thuss COts
Avai<»Ri« nf'itf di w ie'e>»'ic« iwwU4l'D<>% (RtCsl wa alwc pfov^ed 'o1 ''-e ¥
-------
ROD RISK WORKSHEET
Table 12
Risk Characterization Summary - Carcinogens
Scenario Timeframe; Current
Receptor Population: Adjacent Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
Merriam Manufacturing
Benzo(a)anthracene
Benzo(a)pyrene
Bertzo(b)fluoranthene
Dibenz(a,h)anthracene
lndeno(1.2.3 cd)pyrene
Arsenic
2E-05
2E-04
2E-QS
5E-0S
1E-05
6E-06
--
8E-06
9E-05
8E-06
2E-05
5E-06
6E-07
--
3E-05
3E-04
3E-05
6E-05
2E-05
7E-06
Soil Risk Total =
4E-04
Soil Gas
Indoor Air
Merriam Manufacturing
Trichloroettiene
4E-05
--
4E-05
Soil Gas Risk Total»
4E-05
Total Risk -
5E-Q4
Key
Route of exposure is not applicable to this medium.
This table provides risk estimates for the significant routes of exposure for the current child and adult resident at the Merriam Manufacturing Study Area. These risk estimates are based on a reasonable maximum
exposure arid were developed by taking into account various conservative assumptions about the frequency and duration of a child's and adult's exposure to soil and indoor air, as well as the toxicity of the COCs. The
total risk from direct exposure to contaminated soil arid indoor air at this site to a future child and adult resident is estimated to be 5 x 10'*, The COC contributing most to this risk level is benzo(a)pyrene in surface soil.
This risk level indicates that if no clean-up action is taken, an individual would have an increased probability of 5 in 10,000 of developing cancer as a result of site-related exposure to the COCs at the Merriam
Maurifacturing Study Area-
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 13
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
Merriam Manufacturing
Thchloroethene
0enzo(a)an1hracene
Benzo(a)pyrene
Benzo(b)fluoranthenc
Dibenz(a,h)anthracene
indena(1,2,3-cd)pyrene
Arsenic
2E-06
TE-06
6E-Q5
8E-06
2E-05
5E-0S
4E-05
--
N/A
3E-06
3E-05
3E-06
TE-06
2E-06
4E-06
--
2E-QS
1E-05
1E-04
1E-DS
2E-Q5
7E-06
SE-OS
Soil Risk Total *
2E-Q4
Soil Gas
Indoor Air
Merriam Manufacturing
Trichloroethene
j 4E-0S
--
4E-05
Soil Gas Risk Total =
4E-05
Total Risk =
2E-Q4
Shallow Groundwater
indoor Air
Durham Manufacturing
i
Trichloroethene
8E-03
--
8E-03
Groundwater Risk Total =
8E-D3
Total Risk*
N/A
Key
— Route of exposure is not applicable to this medium
NM - Not applicable Summing of soil and indoor air risks across exposure points is not applicable since risks were estimated assuming ail of a receptor's exposure occurred at each exposure point.
This table provides risk estimates for the significant routes of exposure for the future child and adult resident at the Merriam and Durham Manufacturing Study Areas. These risk estimates are based on a reasonable
maximum exposure and were developed by taking into account various conservative assumptions a coot the frequency and duration of a child's and adult's exposure to soil and Indoor air, as well as the toxicity of ll>e
COCs The total risk from direct exposure to contaminated soil and indoor air auhis site to a future child and adult resident is estimated to be 2 x 10* for the Merriam Maunfacturing Study Area and 8 x 10'3 for the
Durham Manufacturing Study Area The COCs contributing the most to these risk levels are benzofajpyrene in sod at the Marriam Manufaturing Study Area and triedloroethens in indoor air at the Durham
Manufacturing Study Area. These risk levels indicate that if no clean-up action is taken, an individual would have an increased probability of 2 in 10,000 and 8 in 1,000 of developing cancer as a result of site-related
exposure to the COCs at the Merriam and Durham Manufacturing Study Areas, respectively
Source: A Guide lo Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents {U.S. EPA, 1999)
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ROD RISK WORKSHEET
Table 14
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe: Future
Receptor Population; Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Soil
Surface Soil
Merriam Manufacturing
Chromium
Gl System
5E*00
N/A
5E+Q0
So
1 Hazard Index Total =
5E+00
Gl System Hazard Index =
5E+0Q
Shallow Groundwater
Indoor Air
Durham Manufacturing
Trichloroethene
Liver/CNS
4E+0Q
--
4E+00
Groundwater Hazard Index Total =
4E+D0
Liver Hazard Index =
4E+00
CNS Hazard Index =
4E+00
Key
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
•- Route of exposure is not applicable to this medium
This table provides hazard quotients (HQs) (or each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the future child and adult resident exposed to soil and indoor air at
the Merriam and Durham Manufacturing Study Areas, The Risk Assessment Guidance (RAGS) (or Superfurtd states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer
effects. The estimated HI of 5 for the Merriam Manufacturing Study Area and 4 for Durham Manufacturing Study Area indicates that the potential for adverse noncancer effects could occur from exposure to
contaminated soil containing chromium at the Merriam Manufacturing Study Area and contaminated indoor air containing trichloroethene at the Durham Manufacturing Study Area.
Source: A Guide to Preparing Superfurtd Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
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ROD RISK WORKSHEET
Table 15
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Commercial Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Bedrock Groundwater
201 Main (DMC well 1)
Tetraehloroethene
Triehloroether*
9E-06
2E-Q4
1E-06
9E-06
1E-05
2E-04
Groundwater Risk Tgtal ¦
2E-04
Total Risk =
2E-Q4
Key
- Route of exposure is not applicable to this medium.
This table provides risk estimates for the significant routes of exposure for the current/future commercial worker at the Durham Maunfacturirig Study Area. These risk estimates are based on a reasonable maximum
exposure and were developed by taking into account various conservative assumptions about the frequency and duration of an adult's exposure to bedrock groundwater, as well as the toxicity of the COCs. The total risk
from direct exposure to contaminated groundwater at this site to a current/future commercial worker is estimated to be 2 x 10'4 The COC contributing most to this risk level is trichloroethene in bedrock groundwater.
This risk level indicates that if no clean-up action is taken, an individual would have an increased probability of 2 in 10,000 of developing cancer as a result of site-related exposure to the COCs at the Durham
Manufacturing Study Area.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 16
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Commercial Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Bedrock Groundwater
201 Main (DMC well 1)
Trichloroethene
Liver
5E+0D
-•
2E 01
5E+QQ
Groundwater Hazard lnd»x Total =
Liver Hazard Index =
SE+00
5E+00
Key
-- Route of exposure is no! applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the current/future commercial worker exposed to bedrock
groundwater. The Risk Assessment Guidance (RAGS) for Superfund states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. The estimated HI of 5 for the
Durham Manufacturing Study Area indicates thai the potential for adverse noncancer effects coutd occur from exposure to contaminated bedrock groundwater containing trichloroethene.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1899)
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ROD RISK WORKSHEET
Table 17
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe; Future
Receptor Population; Construction Worker
Receptor Age; Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Shallow Groundwater
Durham Manufacturing
Trichloroethene
Liver
--
--
3E+01
3E+Q1
Groundwater Hazard Index Total =
liver Hazard Index =
3E+01
3E+Q1
Key
-- Route of exposure is not applicable 10 this medium.
This table provides hazard quotients {HQs} for each route of exposure and the hazard index (sum of the hazard quotients} for all routes of exposure far the future construction worker exposed to shallow groundwater.
The Risk Assessment Guidance (RAGS) for Superfund states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. The estimated HI of 30 for the Durham
manufacturing Study Area indicates that the potential for adverse noneancer effects could occur from exposure to contaminated shallow groundwater containing trichloroethene.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
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ROD RISK WORKSHEET
Table 18
Risk Characterization Summary
- Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Chiid/Aduit
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure Routes
Total
Groundwaler
Bedrock Groundwater
110 Maple
TetracNoroeihene
TncNoroetftene
5E-06
It-OA
1E-07
8E-05
2E-Q6
2E-G5
¦¦
7E-06
2E-04
Groundwater Risk Total *
2E-04
Groundwater
Bedrock Groundwater
133 Maple
T^trachloroeJhene
Triehloroethene
3E-06
1E-04
6E-08
6E-05
1E-06
2E-05
4E-06
2E-04
Groundwater Risk Total -
2E04
Groundwater
Bedrock Groundwater
139 Maple
Telrachloroelhene
Tnchioroethene
2E-06
1E-04
4E-08
6E-05
9E-07
2E-05
--
3E-0S
2E-OS
Groundwater Risk Total *
2E-04
Groundwater
Bedrock Groundwater
166 Main
Benzene
Tetracttoroemene
Tnchloroethiene
Vinyl cNonde
5E-06
4E-04
9E-03
1E-03
2E-06
8E-08
5E-03
1E-05
SE-G?
2E-04
1E-03
4E-G5
..
7E-06
SE-04
2E-02
1E-03
Arsenic
4E-04
N/A
2E-06
4 E-04
Groundwater Risk Total ¦
2E-02
Groundwaler
Bedrock Groundwater
174 Main
Methylene Chloride
TetracMoroeihene
Triehloroethene
Vinyl chloride
4E-08
?E'04
2E-02
8E-04
7EQ7
1E-05
1E-0Z
9E-Q8
1EQ7
3E-04
2E-03
3E05
-
5E-06
1E-D3
3E-02
BE-04
Arsenic
6E-04
HI A
3E-G6
-¦
BE-04
Groundwater Risk Total»
3F.-02
Groundwater
Bedrock Grounchvaier
176 Mam
T etracfiioroethene
Trichioroelhene
8E-06
6E-04
2E-0?
3E-04
4E-06
8E-G5
1E-05
1E-03
Sen20(a)anlhracene
8er.zo(a;ipyfene
Serizo{b)fluGfanlhene
Diberi2< a hjanthracene
lndeno{ t 2.3 cd)pyfene
Penladhtaroprtenol
1E-05
1E-04
1E-05
IF-04
IE-OS
SE-05
N/A
N/A
WA
N/A
NM
N/A
N/A
N/A
N/A
N/A
N/A
N/A
--
1E-0S
1E-04
1E-05
1E-04
1E-Q5
6E-C6
Groundwater Risk Total *
1E-Q3
-------
ROD RISK WORKSHEET
Table 18
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child'Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure Routes
Total
Groundwater
Bedrock Groundwater
186 Mam
TstracNoroethena
Tnchloroethene
4E-D5
2104
&E-G7
1E-04
2E-05
3E-05
6£-G5
4E-04
GroumJwaier Risk Total -
4E-04
Groundwater
Bedrock Groundwater
19 Maiden
TetracNoroethene
Tnchloroethene
6E-06
8E-05
1E-07
5E-05
3E-06
1E-GS
-
9E-06
1E-04
Groundwater Risk Total =
2E-04
Groundwater
Bedrock Groundwater
191 Main
1,2-Dicnbroethane
1 4-Dioxgne
Methyteoe eftktfjde
Tetfacnioroetbene
Tnchloroethene
Vinyl chloride
8is(2-ethylhBxyl}phthalale
Arsenic
1E-06
2E-06
2E-06
7E-04
1E-D2
2E-03
26-06
7E-04
8E-07
N/A
2E-Q7
2E-05
76-03
2£-05
N/A
N/A
5E-08
5E-09
SE-08
4E-04
2E-03
5E-05
2E-C6
3E-06
2E-06
2E-06
2E-06
1E-G3
2E-Q2
2E-03
4E-06
7E-04
Groundwater Risk Total *
3E-02
Groundwater
Bedrock Groundwater
196 Main
TetrscWoroetnane
TrichlDroethene
4E-06
ie-04
8E-03
7E-05
2E-06
2E-05
SE-Q6
2P-04
Groundwater Risk Total -
2E-04
Groundwater
Bedrock Groundwater
202 Main
Telrachi or eminent?
Tnchloroethene
6E-06
2E-04
1E-07
9E-05
3E-Q6
2E 05
BE-06
3E-Q4
Groundwater Risk Total ¦
3E-QA
Groundwater
Bedrock Groundwater
205 Man
Teirachioroetheoe
Tnchforoethere
^E-06
2E-04
6E-0B
1E-G4
1E-06
3E-05
¦¦
4E-06
3E-04
Groundwater Riak Total ¦
3E-04
Groundwater
Bedrock Groundwater
227 Man
Tetrachioroelhene
Tnchloroethene
9E-O0
1E04
2E-Q7
7E-05
4E-06
2E-05
1E-05
2E-04
Groundwater Risk Total -
2E-04
-------
ROD RISK WORKSHEET
Table 18
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation}
Exposure Routes
Total
Qfouocfwater
Bedrock Grourcfcvaier
235 Ma>n
TelracHoroethene
TnthlDroethene
4E-D6
8E-0S
BE-08
5E-05
2E-06
1E 05
-
6E-06
1E-04
Groundwater Risk Total -
2E-04
Groundwater
Bedrock Groundwater
239 Main
T eiracWoroetrjene
TncMoroethene
SE-06
28-04
2S-07
1E-04
4E-06
3E-05
IE-06
3E-04
Groundwater Riak Tola} *
3 E-04
Groundwater
Bedrock Groundwater I 242 Maifi
T etrachloroeinene
TncNofoet^ene
2£-05
AE-Q4
46-07
2 E-04
9E-Q6
§£-05
3E-0S
7E-04
Groundwater RJftk Total *
7 E-04
Groundwater
Bedrock Groundwater
243 Main
T etracNoroefhene
Tnchitxoethen^
1E-0S
3E-CH
2E-07
2E-04
6E-06
4B-m
--
2E-05
5E-04
Groundwater Ri*fc Toiai *
6E 04
Groundwater
Bedrock Groundwater
246 Main
Te
-------
ROD RISK WORKSHEET
Table 18
Risk Characterization Summary
- Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure Routes
Total
Groundwater
QedrocK Groundwater
256 Main
1,4-Dioxaiie
TelracNoroetnene
T ncMoroetftene
3E-06
3E-D5
ie-03
N/A
7E-07
8E-D4
SE-09
2E-D5
2E-D4
3E-06
5E-05
2E-Q3
Groundwater Rish Total *
2E-03
Groundwater
Bedrock Groundwater
257 Main
T etr achi oroelhene
TncMoroethene
1E-05
7E-SH
3E-07
4E-04
7E-06
9E-Q5
--
2E-05
1E-03
Groundwater Risk Total *
1E-03
Groundwater
Bedrock Groundwater
261 Main
TelracNoroethene
TricNcroetnene
4E-0S
1E-03
BE_QJ
7E-Q4
2E-06
2E-G4
6E-05
2E-03
Arsenic
2E-04
N/A
9E-0?
--
2E-04
Groundwater Risk Total *
2E-03
Groundwater
Bedrock Groundwater
262 Main
Tetrachlonoethcsne
TncNoroetfiene
2E-05
5E-04
4E-0?
3E-04
9E-06
7E-05
3E-06
9E-G4
Groundwater Risk Total«
9E-G4
Groundwater
Bedrock Groundwater
256 Man
T etr ach! oroel hene
Tndiloroethene
2E-05
7E-04
5 E-07
4E-04
1E-DS
9E-G5
3E-Q5
IE-03
Groundwater Risk Total*
IE-03
Groundwater
Bedrock Groundwater
267 Main
T etrachtofoe thane
Tnchioroeihene
5E-05
2E-03
1E-06
9E-04
2E-Q6
2C-04
7E-05
3E-Q3
Arsenic
2E-04
N/A
1E-08
2E-04
Groundwater Risk Total»
3E-03
-------
ROD RISK WORKSHEET
Table 18
Risk Characterization Summary
- Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure Routes
Total
Groundwater
Bedrock Groundwater
268 Mam
1,4-D
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Bedrock Groundwater
11 Maiden
Tnchioroelhene
Liver
3E+00
3E-02
3E-C1
3E-KX)
Groundwater Hazard Index Total *
3E+-00
Liver Hazard Index *
3E+Q0
Groundwater
Bedrock Groundwater
110 Mapte
Trtdifonoefiherse
Uver
6E*Q0
SE-02
7E-01
7E+00
Groundwater Hazard Index Tola! *
7E*0O
Uv«f Hazand Index *
7E+00
Groundwater
Bedrock Groundwater
133 Maple
Trichtoroethene
Liver
5E-*00
55-02
5E-01
6E+00
Groundwater Hazard Index Total *
6E+00
Liver Hazard Index -
6E*G0
Groundwater
Bedrock Groundwater
? 39 Maple
Trichloroethene
Liver
5£*G0
5E-02
5E-01
6E+-00
Groundwater Hazard index TolaJ -
6E+00
Liver Hazard Index *
6E+00
Groundwater
Bedrock Groundwater
168 Man
1,2'OichiQroethene Ifolai)
o-s-1,2-DfChloroeth9ne
rnchlaroethene
Blood
aiooa
5 iver
4E-00
4E+00
4E+02
9E-01
36-01
4E+00
2E-01
3E-01
4E+01
5E*D0
5E*G0
5E+Q2
Arsenic
Skin
4E*0G
WA
2E-02
4£*00
Groundwater Hazard Index Tola! *
5E+02
Liver Hazard Index -
S£+Q?
Blood Hazard Index ¦
9E+C0
Skin Hazard Index *
4E+CO
Groundwater
Bedrock Groundwater
174 Mam
1,2-Dichiaroethene (tola!)
Trichloroettiene
Blood
Liver
7E+D0
sp+o?
2E+0C
8E+00
4E-01
SE+Q1
9E+00
SE+02
Arsenic
Skin
7E+00
N/A
36-02
7E+00
Groundwater Hazard index Total *
9E+G2
Skin Hazard Index ¦
7E+Q0
Blood Hazard Index *
96+00
Liver Hazard index *
9E+G2
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Bedrock Groundwater
mum
TncftoroeJhene
Liver
3E*01
3E-01
3E+GQ
3E*C1
Groundwater Hazard index Total *
3E*01
Liver Hazard Index *
3E+01
Groundwater
Bedrock Groundwater
13 Maiden
T ncNoroettiene
lives
2E*0Q
2E-D2
2E-01
2E+Q0
Groundwater Hazard Index Total ¦
2E+Q0
Llyer Hazard Index *
2E+GG
Groundwater
Bedrock Groundwater
18S Main
Trichlofoetfterie
Liver
1E+01
1E-01
1E+Q0
1E+01
Groundwater Hazaid Index Total3
1E^01
Uv*r Hazard Index ¦
16+01
Groundwater
Bedrock Groundwater
19 Maiden
Trtchioroetr^ne
Liver
4E+Q0
4E-02
4E-01
4&*0Q
Groundwater Hazard index Total ¦
4E+00
Liver Hazard Index -
4E+00
Groundwater
Bedrock Groundwater
191 Main
1 2-DicMoroethene (total)
cis 1 2-DicWoroeihene
TncNoroeibene
Blood
Biaod
Liver
7E+00
se+oo
6E *02
2E+00
5£-0l
6E+Q0
4E-01
5E-G1
9E+00
7E-K30
6E+02
Arsenic
Skin
8E*Q0
N/A
4E-0Z
8E+00
Groundwater Hazard index Total =
7 E 4-02
Skin Hazard Index ¦
3E+00
Blood Hazard Index *
2E+01
Liver Hazard index =
6E+02
Groundwater
Bedrock Grotmdwaier
196 Main
T ricNoro6t^ene
Liver
6E+00
8E-02
6E-01
6E+0G
Groundwater Hazard fntfe* Total -
6E+GG
Liver Hazard Index ¦
6E+0Q
Groundwater
Bedrock Groundwater
202 Msirt
TrcNoroeineoe
Liver
?E*00
7E-02
6E-01
8F>0Q
Groundwater Hazard Index Total ¦
8E+0C
Liver Hazard Index «
8E*0C
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Bedrock Groundwater
205 Man
Trtchioroethens
liver
3E+Q0
SE-G2
9E-01
9E+00
Groundwater Hazard Index Total -
9E+00
Liver Hazard Index =
9E+00
Groundwater j Bedrock Groundwater! 227 Main
TrrcMaroeertene
Lrtrer
mm
5E-Q2
ee-oi
ec'co
Groundwater Hazard Judex Tola* *
bE*m
Liver Hazard Index =
6E+D0
Grouncfwafer j Sadroek Groufltfwatsr
235 Man
Tnchloroethene
liver
4E*0Q 1 4E-Q2
4E-01
4E+00
Groundwater Hazard Index Total *
4E+QQ
LJvef Hazard Index *
4E+DG
Groundwater
Bedrock Groundwater
238 Main
Tnchloroethene
Liver
2E+0Q
2E-C2
2E-Q1
3E+00
Groundwater Hazard Index Total *
3E+0G
Liver Hazard Index »
3E+0G
Groundwater
Bedrock Groundwater
239 Wain
T nchloroethene J Lsver
9E*00
9E-02
9E-01
1E+01
Groundwater Hazard Index Total *
16*01
Liver Hazard Index *
1E+01
Groundwater
Bedrock Groundwater I 24 Maiden
Tnchloroethene
Liver
2E+00
2E-C2
2E-01
2E*G0
Groundwater Hazard Index Total %
2E + Q0
Liver Hazard Index *
2E+Q0
Groundwater 1 Bedrock Groundwater
242 Main
Trichtoroetnene
Liver
2E+01
2E-01
26+00
2E+01
Groundwater Hazard index Total -
2E"*<31
Liver Hazard Index *
2E*G1
Groundwater
Bedrock GrOarKtoaEer
243 Main
T nchioroetrwie
Liver
16*01
1E-Q1
26+00
2E*01
Groundwater Hazard Index Total»
2E+01
LJvef Hazard index »
2E*CJ
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Grourxlwater
Bedrock Grounctoatef
246 Mam
Tnchtoroei hene
Liver
2E*01
2E-01
2E+O0
2E*01
Groundwater Hazard Index Total *
2E*01
Liver Hazard Index *
2E+Q1
Groundwater
Bedrock Grouncfwater
248 Main
Trchioroetheoe
Liver 4E-KH
5E-01
5E+Q0
5£*0l
Groundwater Hazard Index Total =
5E+Q1
liver Hazard index ¦
5E+01
Groundwater
Bedrock Groundwater
252 Mam
Trichioroelhene
Liver 2E*01
2E-01
2E+00
2E+01
Groundwater Hazard Index Total«
2E*01
Liver Hxzani Index -
2£<-0l
Groundwater
Bedrock Groundwater
253 Man
TricWoroelhene
Liver
4E»ai
4E-01
4E+Q0
5E*01
Groundwater Hazard Index Total*
5E*D1
Liver Hazard Index ¦
SE*Gl
Graunc&vafef
©earock Grauntfrvafef
266 Mam
Trichioroelhene
Liver
6E*01
6E-01
7E*Q0
te*oi
Groundwater Hazard Index Total *
7E+G1
liver Hazard tndex *
7E+W
Groundwater
Bedrtxk Groundwater
257 Mam
Tnchloroefhene
Liver
3E*01
36-01
3E*W
3E*0t
Groundwater Hazard index Tatar *
3640t
Liver Hazard Index *
3E+01
Grout"! dwaier
Bedrock Groundwater! 261 Mam
TricNoroetftene
Arsenic
Vanadi um
Lsver 6E *-01 BE 01
Skin 2E*Q0 N/A
Kidmy 3E"00 NfA
6E+0G
9E-03
6£-Qt
SE+01
2E*0G
4E+QQ
Groundwater Hazard index Tata! ¦
?E*01
Skin Hazard Index *
2E*O0
Kidney Hazard Index *
4E*0G
Liver Hazard index *
6E+01
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: CurTent
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
ToW
Groundwater
Bedrock Groundwater
262 Main
Tnchforoefhene
Liver
2E+G1
26-01
2E*00
3£*Q1
Groundwater Hazard index Total *
3E+01
Liver Hazard Index *
3E+01
Groundwater
Bedrock Groundwater
265 Man
Tnchioroethene
Liver
3E+01
36-01
3E+D0
3E+G1
Groundwater Hazard Jnde* Total «
3E+01
Liver Hazard Index *
3E+01
Groundwater
SeOroeic Groundwater
26? Main
Trichloroethene
Arsenic
Liver
Skin
7E*01
3E+Q0
fE-01
WA
86+00
1E-Q2
BE+01
3E+0Q
Groundwater Hazard Index Total *
BE+01
Skin Hazard Index =
3E+00
LJver Hazard Index *
se+01
Groundwater
Bedrock Groundwater
266 Main
TfiCMoroe'ftene
Liver
4Et-C1
4E- 01
4E*D0
4£+01
Groundwater Hazard index Total =
4£>01
Liver Hazard Index *
4E+01
Groundwater
Bedrock Groundwater
2?5 Wain (1998]
Tnchloroethene
Liver
2E+01
2E-Q1
2E-D0
3E+01
Groundwater Hazard Index Total *
3E+01
Liver Hazard Index «
3E+D1
Groundwater
Bedrock Groundwater
275 Main /2004)
Tnchiofoetnene
Liver
1E+01
ie-01
1E*D0
1E+01
Groundwater Hazard Index Total *
1E+01
Liver Hazard Index ¦
1E+G1
Groundwater
Bedrock Groundwater
289 Mam
Tnchloroethene
Liver
1E+00
1E-02
2C-01
2E+00
Groundwater Hazard Index Total -
2E*00
Liver Hazard Index *
2E+00
Groundwater
Bedrock Groundwater
9?R Maple
TncrrtoTDeihene
Liver
BE+OO
SE-02
BE-D1
9E+00
Groundwater Hazard Index Total =
9E+O0
Liver Hazard Index =
9E+00
-------
ROD RISK WORKSHEET
Table 19
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Key
N/A - Toxicity cntsna are no! available (o qualitatively address IH& route of exposure
This table provides harard quotients HCs! for each route of exposure and the hazard index (sum of the hazard quotients) for all routes oi exposure'or I he current young chikj and adult resident using bedrock
groundwater for potable purposes The Risk Assessment Guidance (RAGS) tor Syperfund slates thai, generally, a hazard index (HI} of greater than 1 indicates the potential for adverse noncancer effects The
estimated His of between 2 and 900 indicate that the polentiat for adverse noncancer ejects could ocar from exposure to ccnlammated bedrock groundwater containing * 2-dicrtoroeihane, os-1.2-dichloroethene
tncrtloroethene. arsenic, and vanadium
Source: A Guide to Preparing Superfurtd Proposed Plans, Records of Decision, and Other Remedy Selection Decision Document* (U.S. EPA, 1S9S)
-------
ROD RISK WORKSHEET
Table 20
Risk Characterization Summary
- Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Bedrock Groundwater
Site-Wide
1,2-Dfchtaroethane
1,4-Dbxane
Benzene
Methylene chloride
Tetrachloroethene
Trichloroethene
Vinyl Chloride
1E-06
7E-Q6
5E-06
7E-06
2E-03
2E-02
2E-Q3
8E-07
HIA
2E-06
1E-06
4E-05
1E-02
2E-05
5E-08
2E-Q8
6E-07
26-07
1E-D3
2E-03
6E-0S
--
2E-Q6
7E-Q6
7E-06
BE-06
3E-03
3E-02
2E-03
Bertzo{a)anfiracene
Benzo(a!pyrene
Benzojbifluoranthene
Bis(2-ethylhexy[)phthalate
Dibenz(a,h)anthracene
Indenof 1,2,3-cd) pyrene
Pentachtorophenol
1E-05
1E-Q4
1E-05
2E-06
1E-04
1E-0S
6E-D5
HIA
N/A
N/A
N/A
N/A
N/A
N/A
HIA
N/A
N/A
2E-06
N/A
HIA
N/A
--
IE-OS
1E-Q4
1E-05
4E-06
1E-04
1E-05
6E-0S
Arsenic
7E-04
N/A
3E-0S
--
7E-04
Groundwater Risk Total =
4E-02
Total Risk »
4E-02
Key
-- Route of exposure is not applicable to this medium
N/A - Not applicable.
THis table provides risk estimates tor the significant routes ot exposure tor the future young child and adult resident. These risk estimates are based on a reasonable maximum exposure and were developed by taking
into account various conservative assumptions about ttie frequency and duration of an adult's and child's exposure to bedrock groundwater, as well as the toxicity of the COCs. The total risk from direct exposure to
contaminated groundwater at this site to a future resident is estimated to be 4 % 10"2. The COCs contributing to these risk levels are benzene. 1,2-dichloraethane, 1,4-dioxane, methylene chloride, tetrachloroethene,
trichloroethene, vinyl chloride, benzoEaianthracene, benzo(a)pyrene, benzo(b)fluoranthene, bis!2-ethylhex-yl)phthalate, dibenz(a.h)anthracene, indeno(1,2.3-cd|pyrene. pentachlorophenol, and arsenic. This risk level
indicates that if no clean-up action is taken, an individual would have an increased probability of 4 in 100 of developing cancer as a result of site-related exposure to COCs in bedrock groundwater
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
-------
ROD RISK WORKSHEET
Table 21
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe; Future
Receptor Population: Resident
Receptor Age; Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Bedrock Groundwater
Site-Wide
1,2-Dichforoethene (total)
cis-1,2-Dichloroethene
Tetrachioroethene
Tnchloraethene
Bfood
Blood
Liver
liver
7E+00
6E+00
2E+00
8E+02
2E+00
5E-01
9E-02
8E+Q0
4E-01
5E-01
8E-01
9E+Q1
se-i-oo
7E+00
3E+00
9E+Q2
Arsenic
Mercury
Vanadium
Sktn
CNS
Kidney
BE+00
4E+00
3E+00
N/A
N/A
N/A
4E-02
2E-02
SE-0!
BE *00
4E-XJQ
4E+00
Groundwater Hazard Index Total»
9E+02
Liver Hazard Index ~
9E+02
Blood Hazard Index =
2E+Q1
CNS Hazard Index =
4E+00
Kidney Hazard Index *
4E+00
Skin Hazard Index ¦
BE«C0
Key
N/A - Toxicity criteria are not available to quantitatively address this route of exposure
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the future young child and adult resident using bedrock
groundwater for potable purposes. The Risk Assessment Guidance (RAGS) for Superfund states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. The
estimated Hi of 900 indicates that the potential for adverse noncancer effects could occur from exposure to contaminated bedrock groundwater containing 1,2-dichloroethene, cis-1,2-dichloroethene, tetrachioroethene,
trtchloroelhene. arsenic, mercury, and vanadium.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents {U.S. EPA, 1999)
-------
Table 22: Selection of contaminants of potential concern in surface water from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Analyte
Frequency
of detection
Minimum
detected
conc. on site
Arithmetic means
Maximum
detected
conc. on site
Maximum
background
conc.
Surface
water
benchmarks
Source
Hazard
quotient
COPC?
Reason
detects
only
detects
+1/2 ND
VOCs (ug/L)
1,1,1 -T richloroethane
1/6
1,0
J
1.0
2.3
1
J
ND
11
(2)
9.09E-02
NO
a
1,2-Dichloroethylene isomers
2/6
6,0
7.0
4,0
8
ND
590
(2)
1.36E-02
NO
a
Trichloroethylene
2/6
4.0
4.0
3.0
4
2,0
J
47
(2)
8.51 E-02
NO
a
SVOCs (ug/L)
Bis(2-etbylhexy!)pbthalate I 1/6
2.0
J
2.0
2.9
2
J
ND
3
(2)
6.67E-01
NO
a
Diethylphthalate 1/6
5.8
J
5,8
3.6
5.8
J
ND
210
(2?
2.76E-02
NO
a
Dimethylphthalate 1/6
1.9
J
1.9
2.9
1.9
J
ND
NA
-
YES
c
|
Metals - unfiltered (ug/L, unless otherwise noted)
Aluminum
5/6
24
185.6
156.3
475
837
87
(1)
5.46E+0Q
YES
b
Barium
6/6
59.4
132.7
132.7
265
176
4
(2)
6.63E+01
YES
b
Calcium (mg/L)
6/6
30
38.1
38.1
48.8
35
116
(3)
4.21E-01
NO
a,d
Copper
2/6
9.1
9,35
3.6
9,6
ND
9
0)
1 07E+00
YES
b
Iron
6/6
92.2
295.4
295.4
880
1200
1000
(1)
8.80E-01
NO
a
Magnesium (mg/L)
6/6
5.1
5.2
5.2
5.3
5.4
82
<3)
6.46E-02
NO
a,d
Manganese
6/6
25
60.5
60.5
118
53.9
120
(2)
9.83E-01
NO
a
Potassium (mg/L)
6/6
1.8
2.7
2.7
3.7
6.4
53
(3)
6.98E-02
NO
a,d
Sodium (mg/L)
6/6
12
16,5
16.5
18,9
18.6
680
(3)
2.78E-02
NO
a,d
Zinc
6/6
1.8
16.7
16.7
43.9
4.6
120
(D
3.66E-01
NO
a
Metals - filtered (ug/L, unless otherwise noted)
Aluminum
3/6
26.8
133
71.5
278
ND
87
(V
3.20E+00
YES
b
Barium
6/6
56
J
125.9
125.9
251
141
4
(2)
6.28E+01
YES
b
-------
Table 22: Selection of contaminants of potential concern in surface water from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Analyte
Frequency
of detection
Arithmetic means
Maximum
detected
conc. on site
Maximum
background
conc.
Surface
water
benchmarks
Source
Hazard
quotient
COPC?
Reason
Minimum
detected
conc. on site
detects
only
detects
+1/2 ND
Calcium (mg/L)
6/6
29.3
41.9
41.9
60.4
37
116
5.21 E-01
NO
a,d
Copper
2/6
52
6.8
2,8
8.3
ND
9
0
9.22E-01
NO
a
Iron
6/6
48.5
127,2
127.2
294
116
1000
w
2.94E-01
NO
a
Magnesium (mg/L)
6/6
5.1
5.5
5.5
6.0
5.8
82
m
7.32E-C2
NO
a,d
Manganese
6/6
16,4
52.2
52.2
115
89.6
120
m
9.58E-01
NO
a
Potassium (mg/L)
6/6
1.9
2.8
2.8
3.9
3.4
53
(3)
7.36E-02
NO
a,d
Sodium (mg/L)
6/6
11.6
16.8
16.8
20
18.5
680
(3)
2.94E-02
NO
a,d
Vanadium
2/6
2.0
2.2
1.2
2.3
ND
20
(2)
1.15E-01
NO
a
Zinc
6/6
5.3
14.3
14.3
34.5
3.8
120
<1)
2.88E-01
NO
a
NA = not available
ND = not detected
Only those contaminants present above their analytical detection limit (DL) in at least one sample from the site were retained; contaminants present below their analytical DL
in all the site samples were omitted.
1
Note 1: The benchmarks used in selecting surface water contaminants of potential concern (COPC) were as follows:
(1) U.S. EPA, 2002. National Recommended Water Quality Criteria: 2002, EPA-822-R-02-Q47,
(2) Secondary chronic values in Suter, G.W, and C.L. Tsao. 1996. Toxicological benchmarks for screening potential contaminants of concern for effects on aquatic biota:
1996 revision. Oak Ridge National Laboratory. ES/ER/TM-96/R2.
(3) Lowest chronic values in Suter, G.W. and C.L. Tsao. 1996. Toxicological benchmarks for screening potential contaminants of concern for effects on aquatic biota: 1996
revision. Oak Ridge National Laboratory. ES/ER/TM-96/R2.
I
I
Note 2: The reason codes are as follows:
a = the max conc. does not exceed its screening value
b = the max. conc. exceeds its screening value
I
I
-------
Table 22: Selection of contaminants of potential concern in surface water from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Frequency
Analyte of detection
Minimum
detected
conc. on site
Arithmetic means
Maximum Maximum
detected background
conc. on site conc.
Surface
water
benchmarks
Source
Hazard
quotient
COPC?
I Reason
detects
only
detects
+1/2 ND
c = no benchmark is available
d = the analyte is a physiological electrolyte
-------
Table 23; Selection of contaminants of potential concern in sediment from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Minimum
Frequency detected
of conc. on
detection site
Arithmetic means
Maximum
detected
conc. on site
Maximum
background
conc.
"No Effect"
sediment
benchmarks
| Source
Hazard
quotient
COPC?
Reason
Detects
only
Detects
+ 1/2 ND
VOCs fug/kg dry weight)
1,1,1 -T richloroethane
1/5
4.0
J
4.0
4.3
4.0
J
4.4
L
170
(3)
2.35E-02
NO
a
1,2-Dichloroethylene
isomers
1/5
3.1
J
3.1
4.5
3.1
J
ND
31
(5)
1.0QE-01
NO
a
Methylene Chloride
215
3.0
J
18.5
10.1
34.0
2,7
L,B
NA
-
YES
c
T etrachloroethylene
2/5
3.3
J
4.1
3,9
3.8
J
5.8
L
530
0)
7.17E-03
NO
a
T richloroethylene
2/5
2.5
J
3.5
3.7
2.6
J
2.2
L
1,600
(3)
1.63E-03
NO
a
Vinyl Chloride
1/5
1.8
J
1.8
4,2
1.8
J
ND
15,186
(6)
1.19E-04
NO
a
T riehlorofluoromethane
3/5
7.6
J
13.0
9.4
17.0
24
3,398
(6)
5.00E-03
NO
a
sec-Butylbenzene
1/5
3.3
J
4.7
4.3
3.3
J
ND
NA
-
YES
c
SVOCs (ug/kg dry weic
rht)
Acenaphthene
5/5
11
24.5
24.5
44.5
57
16
(2)
2.78E+00
YES
b
Acenaphthylene
5/5
50
138.8
138.8
280
110
44
(2)
6.36E+00
YES
b
Anthracene
5/5
46
117.4
117.4
210
230
57.2
(1)
3.67E+00
YES
b
Benzo(a)anthracene
5/5
360
756
756
1450
1500
108
(1)
1.34E+01
YES
b
Benzo(a)pyrene
5/5
550
1078
1078
2050
2000
150
W
1.37E+01
YES
b
Benzo(b)f1uoranthene
5/5
820
1682
1682
3150
3100
NA
-
YES
c
Benzo(ghi}perylene
5/5
400
776
776
1400
1400
170
w
8.24E+00
YES
b
Benzo{k)fluoranthene
5/5
310
556
556
1000
920
240
w
4.17E+00
YES
b
Benzoic Acid
2/5
160
J
259
305
278
J
190
J
NA
-
-
YES
c
Bis{2-
ethylhexyljphlhalate
1/5
1300
1300
398
1300
ND
890,000
(5)
1.46E-03
NO
a
Butyl Benzyl Phthalate
1/5
150
J
150
166.6
150
J
ND
11,000
1.36E-02
NO
a
Carbazole
2/5
110
J
143
165
175
J
160
J
284,678
_i§L_
6.15E-04
NO
a
-------
Table 23: Selection of contaminants of potential concern in sediment from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Frequency
of
detection
Minimum
detected
conc. on
site
Arithmetic means
Maximum
detected
conc. on site
Maximum
background
conc.
"No Effect"
sediment
benchmarks
Source
Hazard
quotient
COPC?
|_ Reason
Detects
only
Detects
+1/2 ND
Chrysene
5/5
520
1020
1020
1900
1800
166
(V
1.14E+01
YES
b
Di-n-butylphthalate
1/5
110
J
110
159
110
J
60
J
11,000
(3)
1.00E-02
NO
a
Dibenzo(a,h)anthracene
5/5
110
223
223
435
370
33
(1)
1.32E+01
YES
b
Fluoranthene
5/5
890
1702
1702
3300
3600
423
(V
7.80E+00
YES
b
Fluorene
5/5
25
49.5
49.5
88.5
86
77.4
(V
1.14E+00
YES
b
lndeno( 1,2,3 cd)pyrene
5/5
520
1016
1016
1850
1800
200
w
9.25E+00
YES
b
Naphthalene
5/5
7.6
13.5
13.5
24
15
176
(1)
1.36E-01
NO
3
Phenanthrene
5/5
340
746
746
1400
1600
204
(1)
6.86E+00
YES
b
Pyrene
5/5
970
1768
1768
3300
3500
195
(1)
1 69E+01
YES
b
Sum of PAHs
-
6133.0
11667.0
11667.0
21804
-
1,610
(1)
1 35E+01
YES
b
Pesticides (ug/kg dry weight)
4,4'-DDD
2/5
1.6
J
1.8
1.2
1.9
2.7
1.88
(1)
1.01E+00
YES
b
4.4-DDE
2/5
2.4
J
4.3
2.2
6.1
3.5
3.16
(1)
1.93E+00
YES
b
Alpha Chlordane
1/5
1.8
J
1.8
1.0
1.8
J
1.8
7
(4)
2.60E-01
NO
a
Metals (mg/kg dry weic
iht)
Aluminum
5/5
5800
11780
11780
22000
13000
NA
*
-
YES
c
Barium
5/5
55.8
121
121
314
147
NA
-
-
YES
c
Beryllium
3/5
0.7
1.0
0.7
1.4
1.1
NA
-
-
YES
c
Calcium
5/5
1090
2230
2230
4250
2850
NA
-
-
NO
c.d
Chromium
5/5
8.2
16.0
16,0
32.0
19.5
43.4
(1)
7.37E-01
NO
a
Cobalt
5/5
3.5
9.0
9.0
17.8
7.6
NA
_
YES
c
Copper
5/5
6.8
59.8
59.8
250
22.5
31.6
(1)
7.91E+00
YES
b
Iron
5/5
7900
14800
14800
26000
18000
20,000
w
1.30E+00
YES
b
Lead
3/5
55.1
57.5
38.3
60.0
63.2
35.8
w
1.68E+00
YES
b
-------
Table 23: Selection of contaminants of potential concern in sediment from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Arithmetic means
Analyte
Frequency
of
detection
Minimum
detected
conc. on
site
Detects
only
Detects
+1/2 ND
Maximum
detected
conc. on site
Maximum
background
conc.
"No Effect"
sediment
benchmarks
0)
w
k.
3
o
w
Hazard
quotient
COPC?
Reason
Magnesium
5/5
1710
3454
3454
7090
3640
NA
-
-
NO
c,d
Manganese
5/5
204
386
386
746
592
460
w
1.62E+00
YES
b
Nickel
4/5
4,3
11.1
9.5
20.2
13.7
22.7
C)
8.90E-01
NO
a
Vanadium
5/5
15.9
29,6
29,6
53.5
32.2
NA
-
YES
c
Zinc
5/5
37.3
188
188
680
68.9
121
(1)
5.62E+00
YES
b
NA = not available
ND = not detected
Only those contaminants present above their analytical detection limit (DL) in at least one sample from the site were retained; contaminants present below their analytical DL in all
the site samples were omitted.
I I
Note 1: The benchmarks used in selecting sediment contaminants of potential concern (COPC) were as fallows:
(1) MacDonald, D.D., C.G. Ingersoll. and T.A. Berger. 2000. Development and evaluation of consensus-based sediment quality guidelines for freshwater ecosystems. Arch.
Environ. Contam. Toxicol. 39:20-31.
(2} Long, E.R., D.D. MacDonald, S.L. Smith and F.D. Calder. 1995. Incidence of adverse biological effects with ranges of chemical concentrations in marine and estuarine
sediments. Environ. Manag. 19:81-97.
(3) U.S. EPA. 1996. ECO Update; Ecotox Thresholds. EPA 540/F-95/038. January, 1996.
(4) Persaud, D., R. Jaagumagi and A. Hayton 1993. Guidelines for the protection and management of aquatic sediment quality in Ontario. Ontario Ministry of Environment and
Energy.
(5) Jones, D.S., G.W. Suter and R.N. Hull. 1997. Toxicological benchmarks for screening contaminants of potential concern for effects on sediment-associated biota: 1997
revision. Oak Ridge National Laboratory. ES/ER/TM-95/R4.
(6) This benchmark was calculated using the EPA's Equilibrium Partitioning (Eq-P) ap
proach
J
Note 2: The Reason codes are as
follows:
-------
Table 23: Selection of contaminants of potential concern in sediment from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Frequency
of
detection
Minimum
detected
conc. on
site
Arithmetic means
Maximum
detected
conc. on site
Maximum
background
conc.
"No Effect"
sediment
benchmarks
Source I
Hazard
quotient
COPC?
Reason
Detects
only
Detects
+ 1/2 ND
a = the maximum concentration does not exceed its "no effect" sediment screening value
b = the maximum concentration exceeds its "no effect" sediment screening value
c = no sediment screening value is
available
d - analyte is a physiological
electrolyte
-------
Table 24: Selection of contaminants of potential concern in wetland soil
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Frequency
of detection
Minimum
detected
conc. on
site
Arithmet
Detects
only
ic means
Detects +
1/2 ND
Maximum
detected
conc.
on site
Maximum
background
conc.
Benchmark
Receptor type
Hazard
quotient
COPC?
c
0
m
«s
D
01
VOCs (ug/kg)
Methylene chloride
2/6
2,5
J
32.3
15.5
62
NA
21,400
Mammal
2.90E-03
NO
a
T etrachloroethylene
1 / 6
-
18
8.3
18
L
NA
2,770
Mammal
6.50E-03
NO
a
1,1,1-Trlchloroethane
1 / 6
.
16
8,0
16
J
NA
2,060
Mammal
7.77E-03
NO
a
Trichloroethylene
1 IB
-
10
7.0
10
J
NA
1,387
Mammal
7.21 E-03
NO
a
T richlorofluoromethane
2/6
5,8
J
33.4
15.8
61
NA
NA
NA
NA
YES
c
SVOCs (ug/kg)
Acenaphthene
5/6
2,3
J
33.9
30.2
110
NA
20,000
Plant
5.50E-03
NO
a
Acenapbthylene
6/6
16
501
501
2100
NA
NA
NA
NA
YES
c
Anthracene
6/6
7,8
141
141
530
NA
NA
NA
NA
YES
c
Benzo(a)anthracene
8/6
63
1256
1256
5300
NA
NA
NA
NA
YES
c
Benzo(a)pyrene
6/6
89
2812
2812
13000
NA
1,980
Mammal
6.57E+00
YES
b
Benzo(b)fluoranthene
6/6
140
4563
4563
21000
NA
NA
NA
NA
YES
c
Benzo(g,h,r)perylene
6/6
79
2372
2372
11000
NA
NA
NA
NA
YES
c
Benzo(k)fluoranthene
6/6
51
1257
1257
5500
NA
NA
NA
NA
YES
c
Benzoic acid
2/6
220
J
425
713
630
J
NA
NA
NA
NA
YES
c
Carbazole
2/6
110
J
110
353
110
J
NA
NA
NA
NA
YES
c
Chrysene
6/6
88
1551
1551
6200
NA
NA
NA
NA
YES
c
Dibenzo(a,h)anthracene
6/6
20
708
708
3200
NA
NA
NA
NA
YES
c
Fluoranthene
6/6
140
2263
2263
8800
NA
NA
NA
NA
YES
c
Fluorene
6/6
3.7
43,6
43.6
120
NA
30,000
Earthworm
4.00E-03
NO
a
lndeno(1,2 3-cd)pyrene
6/6
100
3197
3197
15000
NA
NA
NA
NA
YES
c
2-Methylnaphthalene
1 / 6
-
130
377
130
J
NA
NA
NA
NA
YES
c
Naphthalene
5/6
2,5
42.5
37,4
100
NA
NA
NA
NA
YES
c
-------
Table 24: Selection of contaminants of potential concern in wetland soil
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Frequency
of detection
Minimum
detected
cone, on
site
Arithmei
Detects
only
ic means
Detects +
1/2 ND
Maximum
detected
conc.
on site
Maximum
background
conc.
Benchmark
Receptor type
Hazard
quotient
COPC?
0
to
>9
o
Phenanthrene
6/6
20
517
517
1300
NA
NA
NA
NA
YES
c
Pyrene
6/6
140
2868
2868
12000
NA
NA
NA
NA
YES
c
Pesticides/PCBs jug/kg)
4,4'-0DE
4/6
2.1
J
2.9
2.3
3.8
NA
NA
NA
NA
YES
c
alpha-Chlordane
1 15
•
2.1
1.1
2.1
J
NA
1,800
Avian
1.17E-03
NO
a
Dieldrin
1/6
2.4
1.2
2.4
J
NA
0.28
SSL
8.57E+00
YES
b
Metals (mg/kg)
Aluminum
6/6
8500
14000
14000
19000
NA
0.3
SSL
6.33E+04
YES
b
Barium
6/6
87,4
273
273
780
NA
330
SSL
2.36E+00
YES
b
Beryllium
6/6
0.51
0.9
0.9
1.4
NA
35
SSL
4.00E-02
NO
a
Cadmium
2/6
2.8
6.0
2.5
9.1
NA
0.38
SSL
2.39E+01
YES
b
Chromium
6/6
14.9
1491
1491
8370
NA
5,000
SSL
1.67E+00
YES
b
Cobalt
6/6
4.0
7.7
7.7
10.4
NA
13
SSL
8.00E-01
NO
a
Copper
6/6
11.4
79.3
79.3
276
NA
61
SSL
4.52 E+00
YES
b
Iron
6/6
9200
19000
19000
29000
NA
NA
NA
NA
YES
c
Lead
6/6
31.9
287
287
915
NA
16
SSL
5.72E+01
YES
b
Manganese
6/6
140
588
588
1350
NA
322
Mammal
4.19E+00
YES
b
Mercury
4/6
0.39
2.6
1.9
5.4
NA
0,10
Earthworm
5.40E+01
YES
b
Nickel
6/6
8.3
14
14
20.6
NA
11.22
Mammal
1.84E+00
YES
b
Vanadium
5/6
19
32
30.4
46.2
NA
0.71
Mammal
6.47E+01
YES
b
Zinc
5/6
136
515
452
1670
NA
12
Avian
1.39E+02
YES
b
Notes
-------
Table 24: Selection of contaminants of potential concern in wetland soil
Screening-level ecological risk assessment
Durham Meadows Superfund Site,
Durham, CT
Analyte
Frequency
of detection
Minimum
detected
cone, on
site
Arithmetic means J Maximum
I j detected
Detects Detects + conc.
only | 1/2 ND | on site
Maximum
background
conc.
Benchmark
Receptor type
Hazard
quotient
COPC?
c
o
10
n>
»
K
COPC - Chemical ofpotential concern
I !
I I
Note 1: the benchmarks used in selecting wetland soil contaminants of potential concern (COPC) were as follows;
SSL - USE PA Interim Final Ecological Soil Screening Level (USEPA, 2003)
Mammal - Benchmark based on lowest mammalian value (Sample, et al.. 1996)
Avian - Benchmark based on lowest avian value (Sample et al., 1996)
I
Earthworm - Benchmark based on toxicity concentrations for earthworm (Efroymson, et al., 1997a)
NA - Benchmark not available
i
Note 2: The Reason codes are as follows:
a = the maximum concentration does not exceed its "no effect" soil screening value
b = the maximum concentration exceeds its "no effect" soil screening value
c = no soil screening value is available
I
I
-------
Table 25: Ecological exposure pathways and endpoints
: Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Receptor
j group
Listed
species?
Main exposure
media
Exposure routes
Assessment endpoints
Measurement endpoints
benthic
invertebrates
NO
sediment
ingestion and direct
contact with chemicals in
sediment
maintain the long-term stability and viability
of the benthic invertebrate community
present within the substrate in Ball Brook
* compare the mean concentrations of
COPCs measured Ball Brook sediment
samples to published benchmarks
fish
NO
surface water
Ingestion and direct
contact with chemicals in
surface water
maintain the long-term stability and viability
of the fish community within Ball Brook
compare the mean concentrations of
COPCs measured in Ball Brook surface
wafer samples to published benchmarks
soil
organisms
NO
soil
direct contact (plants &
earthworms), ingestion
(earthworms)
maintain the long-term stability and viability
of the soil invertebrate and plant
community within the wet meadow
• compare the mean contaminant levels
measured in wet meadow soil samples to
published benchmarks
small
mammals
NO
soil and soil
invertebrates
ingestion
maintain the long-term stability and viability
of small-mammal populations that may
inhabit the wet meadow
* calculate an estimated daily dose in the
short-tailed shrew based on the ingestion
of soil and soil invertebrates
-------
Table 26: Hazard quotients for surface water from Ball Brook
Durham Meadows Superfund Sites
Durham, CT
Analyte
Chronic
surface
water
benchmark
Site locations
Reference locations
Chronic HQb
Ratios |
Mean corn
(detects
+1/2 NDs
Maximum
conc.
Mean conc.
(detects
only)
Mean conc.
(detects +1/2
NDs)
Maximum,
conc."
Site Max. over
Ref. Mean
(detects only)
Site Max. over
Ref. Mean
(detects+1/2
NDs)
Site Max. over
Ref. Max
SVOC (ug/L)
Dimethylphthalate
NA
2.9
1.9
J
-
3.8
U
6
u
-
5.00E-01
3.17E-01
Metals • unfiltered (ug/L)
Aluminum
87
156.3
475
430
220
837
1.80E+00
1.10E+00
2.16E+00
5.68E-01
Barium
4.0
132.7
265
92
92
176
3.32E+01
2.88E+00
2.88E+00
1.51E+00
Copper
9.0
3.6
9,6
-
1.2
U
0.8
u
4.00E-01
.
8.00E+00
1.28E+01
Metals - filtered (ug/L)
Aluminum
87
71.5
278
-
10
u
10
u
8.22E-01
.
2.78E+01
2.78E+01
Barium
4.0
125.9
251
S3
83
141
3.15E+01
3.02E+00
3.02E+00
1.78E+00
3 for analytes flagged as "U", the value shown is 1/2DL
6 chronic HQ = site mean concentration (detects + 1/2 NDs) /chronic surface water benchmark
DL = detection limit
ND = not detected
bold = HQ >1.0
I
-------
Table 27; Hazard quotients for the sediment samples from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfurtd Site
Durham, CT
Analyte
Sediment benchmarks
BBS
{reference
location)'
Site
arith.
mean
(detects
+1/2 DL)
Hazard quotients (HQs)
Ratio of ref,
conc. over site
arith. mean
"no-effect"
benchmark
m
u
tm
i
w
"effect"
benchmark
Source
"no effect"
HQs"
"effect" HQs'
VOCs (ug/kg dry weight)
Methylene Chloride
NA
-
NA
-
2.7
U
TO 1
-
-
2.67E-01
sec-Butylbenzene
NA
-
NA
-
4,2
u
4.0
-
.
1.05E+00
SVOCs (ug/kg dry weight)
Acenaphthene
16
(2)
536
(1*)
57
24.5
1.53E+00
4.57E-02
2.33E+00
Aeenaphthylene
44
(2)
536
(1*)
100
139
3.15E+00
2.59E-01
7.20E-01
Anthracene
57.2
(V
845
230
117
2.05E+O0
1.39E-01
1.96E+00
Benzo(a)antbracene
108
(1)
1,050
(1)
1,500
756
7.00E+00
7.20E-01
1.98E+QQ
Benzo{a)pyrene
150
(1)
1,450
(D
2,000
1,078
7.19E+00
7.43E-01
1.8SE+0Q
Benzo{b)fluoranthene
NA
636
(1*i
3,100
1,682
-
3.14E+O0
1 84E+00
Benzo(ghi)perylene
170
(3)
536
(1*)
1,400
776
4.56E+00
1.45E+00
1 80E+00
Benzo(k)fluoranthene
240
(3)
536
(1*)
920
556
2.32E+00
1.04E+QQ
1.65E+00
Benzoic Acid
NA
-
NA
-
330
UJ
305
-
-
1 08E+00
Chrysene
166
(1)
1,290
{*>
1,800
1,020
6.14E*0O
7.91E-01
1.76E+00
Dibenzo(a.h)anthracene
33
0)
536
(1*)
370
223
6.76E+00
4.16E-01
1.66E+00
Fluorarithene
423
(D
2,230
(D
3,600
1,702
4.02E+00
7.63E-01
2.12E+00
Fluorene
77.4
(1?
536
(1)
86
49 5
6.40E-01
9.24E-02
1.74E+00
lndeno(1,2,3-cd)pyrene
200
(3)
536
(1*)
1,800
1,016
5.O8E+00
1.90E+O0
1.77E+Q0
Phenanthrene
204
(1)
1,170
(1)
1.600
746
3.66E+00
6.38E-01
2.14E+00
Pyrene
195
d)
1,520
<*)
3,500
1,768
9.07E+00
1.1SE+00
1 98E+00
Sum of Total PAHs
1,610
(1)
22,800
(1)
22,078
11,667
7.25E+90
5.12E-01
1.89E+Q0
Pesticides (ug/kg dry weight]
4,4'-DDD
1.88
(1)
26
(1)
1.5
J
1.2
6.60E-01
4 43E-02
1 21E+00
4,4'-DDE
3.16
31.3
d)
2.0
J
2.2
7.09E-01
7 16E-02
8.93E-01
Metals (mg/kg dry weight)
Aluminum
NA
-
NA
-
12,000
1.2
-
-
1 .Q3E+04
Barium
NA
NA
-
102
121
-
-
8.43E-01
Bery Ilium
NA
-
NA
-
0.91
0.7
-
-
1.31 E+00
Cobalt
NA
-
NA
-
7.6
9.0
-
-
8.41E-01
Copper
31.6
(1)
149
(1)
22.5
59.8
1.89E+0O
4.01E-01
3.76E-01
Iron
20,000
«3)
40,000
<3)
18.000
14.800
7.40E-01
3 70E-01
1.22E+00
Lead
35.8
(1)
128
(t)
59.9
38.3
1.07E+00
2.99E-01
1.56E+00
Manganese
460
(3)
1,100
592
386
8.40E-01
3 51E-01
1.53E+00
Vanadium
NA
-
NA
17.7
u
29.6
-
-
5.99E-01
Zinc
121
0)
459
(1?
54
u
188
1.56E+00
4.10E-01
2.87E-01
" if an analyte was not present at a concentration above its detection limit (flagged as U or UJ), then the value shown is 1/2 DL
6 "no effect" HQ = site arithmetic mean cone (detects + 1/2 NDs)/"no effect" sediment benchmark
-------
Table 27: Hazard quotients for the sediment samples from Ball Brook
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Analyte
Sediment benchmarks
BBS
(reference
location J*
Site
Hazard quotients (HQs)
Ratio of ref.
conc, over site
arith. mean
"no-effect"
benchmark
Source
"effect"
benchmark
Source
arith.
mean
(detects
*112 DL)
"no effect"
HQs'
"effect" HQs'
c "effect" HQ = site arithmetic mean conc. (detects + 1/2 NDs)/"effect" sediment benchmark
Benchmark sources:
_
(1) MacDonald, D.D., C.G. Ingersoll, and T.A. Berget 2000. Development and evaluation of consensus-based sediment quality guidelines
for freshwater ecosystems. Arch. Environ. Contam. Toxicol. 39:20-31.
(2) Long, E R , DO, MacDonald, SL Smith and F D Calder, 1995. Incidence of adverse biological effects with ranges of chemical
concentrations in marine and estuarine sediments. Environ. Manag. 19:81-97.
(3) Persaud, D , R. Jaagumagi and A. Hayton. 1993, Guidelines for the protection and management of aquatic sediment quality in Ontario.
Ontario Ministry of Environment and Energy.
note:
* the value shown is for fluorene, the lowest-available probable effect concentration (PEC) for PAHs (MacDonald et al., 2000).
HQ = site mean concentration (detects + 1/2 NDs) /"no effect" or "effect" sediment benchmark
-------
Table 28: Hazard quotients for shrew (maximum exposure scenario)
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
Analyte
Total
dose
(mg/kg-day)
No effect
TRV
(mg/kg-day)
Total HQ
{max.
exposure)
Percent
food
HQ
Percent soil
HQ
Percent
surface
water HQ
VOCs
Trichlorofluoromethane
0.22
107
<0.1
99.7
0.3
NA
SVOCs
Acenaphthylene
1.5
159
<0.1
99.7
0.3
NA
Anthracene
0.47
1189
<0.1
99,7
0.3
NA
X
Benzo(a)anthracene
4.0
1.5
2.6
99.7
0.3
NA
X
Benzo(b)f?uaranthene
11
1.5
6.9
99.7
0.3
NA
Benzo(g, h, ijpery lene
5.1
159
<0.1
99.7
0.3
NA
X
Benzo(k)fIuoranthene
3.7
1.5
2.4
99.7
0.3
NA
Benzoic acid
2.2
1099
<0.1
99.7
0.3
NA
Carbazole
0.42
159
<0.1
99.7
0.3
NA
X
Chrysene
5.4
1.5
3.5
99.7
0.3
NA
X
Dibenzo(a,h)anthracene
1.9
1.5
1.2
99.7
0.3
NA
Fluoranlhene
8.0
149
<0.1
99.7
0.3
NA
X
lndeno(1,2,3-cd)pyrene
6.8
1.5
4.4
99.7
0.3
NA
2-Methylnaphthalene
0.50
135
<0.1
99.7
0,3
NA
Naphthalene
0.21
238
<0.1
99.7
0.3
NA
Ptienarithrene
3.3
159
<0.1
99,7
0.3
NA
Pyrene
7.7
159
<0.1
99.6
0.4
NA
PesticidesiPCBs
4.4'-ODE
0.016
3.2
<0.1
99.7
0.3
NA
alpha-Chlordane
0.0088
5.4
<0.1
99.7
0.3
NA
Dieldrin
0.010
0.044
0.2
99.7
0.3
NA
Metals
X
Aluminum
420
58
7.2
44.2
55.8
NA
X
Barium
20
12
1.7
51.8
48.2
NA
X
Cadmium
4.1
2.1
1.9
97.2
2,8
NA
X
Chromium
104
20
5.3
0.5
99.5
NA
Copper
5.4
33
0.2
36.4
63.6
NA
Iron
546
NA
NA
NA
NA
NA
X
Lead
28
18
f .6
59.1
40.9
NA
Manganese
22
442
<0.1
23.2
76.8
NA
X
Mercury
0.12
0.070
1.7
43.3
56.7
NA
Nickel
1.7
88
<0.1
85.4
14.6
NA
-------
Table 28: Hazard quotients for shrew (maximum exposure scenario)
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham, CT
jAnalyte
Total
dose
(mg/kg-day)
No effect
TRV
(mgJkg-day)
Total HQ
(max.
exposure)
Percent
food
HQ
Percent soil
HQ
Percent
surface
water HQ
X
Vanadium
0.86
0.43
2.0
37.1
62.9
NA
Zinc
101
352
0.3
79.7
20.3
NA
|
Notes:
HQ = Hazard quotient
TRV = Toxicity Reference Value
X = Indicates a COPC with a HQ >1.0
Total Dose = Sum of exposure from ingestion of animal (prey) and soil
NA = Not Applicable
-------
Table 29: Hazard quotients for the shrew (mean exposure scenario)
Screening-level ecological risk assessment
Durham Meadows Superfund Site
Durham , CT
Analyte
Total
dose
(mg/kg-
day)
No effect
TRV
(mg/kg-
day)
Total HQ
(mean
exposure)
Percent
food
HQ
Percent soil
HQ
Percent
surface
water HQ
SVOCs
X
Benzo(a)anthracene
1,8
1.5
12
99.7
0.3
NA
X
Benzo(b)f!uoranthene
5
1.5
3.4
99.7
0.3
NA
X
Benzo(k)fluoranthene
1.7
1.5
1.1
99.7
0.3
NA
X
Chrysene
2.6
1.5
1.7
99.7
0.3
NA
X
lndeno(f ,2,3-cd)pyrene
3.6
1,5
2,3
99.7
0.3
NA
Metals
X
Aluminum
312
58
5.4
44.2
558
NA
Barium
8
12
0.7
51.8
48,2
NA
Cadmium
1.6
2.1
0.8
97.8
2.2
NA
X
Chromium
23
20
1.1
2.6
97.4
NA
Iron
354
NA
NA
NA
NA
NA
Lead
11
18
0.6
63.8
36.2
NA
X
Mercury
0.07
0.070
1.0
S3.3
36.7
NA
X
Vanadium
0.54
0.43
1.2
37.1
62.9
NA
Notes:
HQ = Hazard quotient
TRV = Toxicity Reference Value
X * Indicates a COPC with a HQ > 1.0
Total Dose = Sum of exposure from ingestion of animal (prey) and soil
NA = Not Applicable | |
-------
Table 30. Compounds To Which Technical Impracticability Waiver Will Apply
Contaminant of Concern
USEPA MCL
(ug/L)
Minimum of
Applicable CT RSRs
(1) (ug/L)
HH RBG
ILCRs 1E-06
or HI = 1
(ug/L)
Maximum Groundwater
Concentration (5)
(ug/L)
Bedrock
DMC Overburden
1,1-Dichloroethane
—
70
126
93
1,1-Dichloroetherte
7
1
82.4
23,000
1,1,1-TCA
200
200
600
18,460
1,2-Dichloroethane
5
1
4
(2)
1,2-Dichloroethene (total)
-
--
104
740
58020
1,4-Dioxane
--
--
5.2
34
(4)
Benzene
5
1
27.8
50
cis-1,2-DCE
70
70
1017
(3)
Ethylbenzene
700
700
4700
(2)
Methylene chloride
5
5
53
4,157,000
PCE
5
5
410
7,900
Toluene
1,000
1,000
2700
37000
TCE
5
5
4200
170,000
Vinyl chloride
2
1.6
170
88
Xylene
10,000
530
26000
310
Benzo(a)anthracene
-
0.06
1
(7)
Benzo(a)pyrene
0.2
0.2
1
(7)
Benzo(b)fluorarithene
0.08
1
(7)
Benzo{k)ftuoranthene
-
0.3
0.8
(7)
Bis(2-ethylhexyl)phthalate
6
2
7
(7)
Dibenzo(a,h)anthracene
-
0.5
1
(7)
lndeno{1,2,3-c,d)pyrene
-
0.5
1
(7)
Pentachlorophenol
1
1
28
(7)
Phenanthrene
-
0.077
0.7
(7)
-------
Table 30. Compounds To Which Technical Impracticability Waiver Will Apply
Contaminant of Concern
USEPA MCL
(ug/L)
Minimum of
Applicable CT RSRs
(1) (ug/L)
HH RBG
ILCR = 1E-06
or HI = 1
(ug/L)
Maximum Groundwater
Concentration (5)
(ug/L)
Bedrock
DMC Overburden
Arsenic
10
4
25
(2)
Copper
1,300
48
754
(7)
Lead
15(6)
13
435
3,7
Mercury
2
0.4
4.2
(2)
Vanadium
-
50
34.5
(7)
Zinc
-
123
377
(7)
DCE - Dichloroethylene
ug/L - micrograms per liter (equivalent to parts per billion, ppb)
— Not available
NA - Not applicable due to lack of toxicity values
{1) The lowest of the CT RSR GA/GAA GWPC, SWPC, and the current and proposed RES VC and l/C VC are presented.
{2) The analyte was not reported as detected, based on available data.
{3) Cis-1,2-DCE was not reported. Total 1.2-DCE (cis and trans) was reported at a maximum concentration of 58,020 ppb.
(4) The anafyte 1 4-dioxane has not been analyzed for in overburden monitoring wells at the DMC Study Area.
(5) From reported historical records.
(6) The value presented for lead is a treatment technique action level.
(7) This analyte was not analyzed for, based on available data.
-------
Table 31. Cost Estimate Summary for MMC Study Area
Capital Costs for MMC Study Area
Description
Quantity
Unit
Unit Cost
Total
1 - Pre-Remedial Study (SVE)
Sampling and analyses (soil and soil vapor)
LS
$18,000
Field equipment
LS
$2,500
Surveying
LS
$5,000
Data evaluation
75
HR
$75
$5,625
2. Treatability Study
Treatability work plan
40
HR
$100
$4,000
Equipment mobilization
LS
$1,500
SVE Pilot Test
LS
$12,000
Treatability study report
40
HR
$100
$4,000
3, Soil Vapor Extraction System
Equipment mobilization
1
LS
$5,000
Submittals and plans
1
LS
$18,000
Install SVE System
1
LS
$81,000
Install Vapor Monitoring Wells
5
EA
$1,500
$7,500
Subtotal (SVE System)
$164,125
Contingency Allowances (30%)
$49 238
Subtotal [Remedy Implementation]
$213,363
Project Management (8%)
$17,069
Remedial Design (15%)
$32,004
Construction Management (10%)
$21,336
Institutional Controls
$15,000
Total Capital Cost (SVE System)
$298,772
4, Site Preparation and Management (Excavation)
Equipment mobilization
LS
$10,000
Submittals and plans
LS
$20,000
Temporary facilities
LS
$10,000
Erosion control measures
1,600
LF
$4
$6,400
Clearing and grubbing
1
LS
$10,000
$10,000
B. Pre-Remedial SoII Sampling
Drill rig
5
day
$1,500
$7,500
Sampling and analysis
LS
$70,000
Field equipment
1
EA
$2,500
$2,500
Surveying
1
EA
$5,000
$5,000
Data evaluation
75
HR
$7500
$5,625
C Excavate and Backfill
Excavate soil
4,800
CY
$5
$24,000
Dust control and air monitoring
1
EA
$10,000
$10,000
Post-remedial sampling
50
EA
$500
$25,000
Furnish clean fill
5,760
CY
$24
$140,000
D. Soil Disposal (non-haz)
7,200
ton
$70
$504,000
Subtotal (Excavation)
$850,025
Contingency Allowances (30%)
$255,007
Subtotal [Remedy Implementation]
$1,105,032
Project Management
$101,000
Remedial Design
$135,000
Construction Management
$122,000
Institutional Controls
$15,000
Total Capital Cost (Excavation)
$1,478,032
Total Capital Cost (MMC Study Area)
$1,776,804
-------
Table 31. Cos! Estimate Summary for MMC Study Area
Operation and Maintenance Cost for MMC Study Area
Description Quantity
Unit Unit Cost Total
1. SVE System O&M (Years 1-7)
Operational inspections and maintenance
Equipment maintenance allowance
Electricity allowance
Disposal allowance
2. Annual Site Monitoring {Year 1-7)
Soil vapor monitoring (Year 1-7)
Groundwater monitoring (Year 1-50)
Subtotal
Contingency allowances
Technical Support
Project Management
160
fir
LS
LS
LS
event
event
$75
$6,500
$6,500
$12,000
$500
$1,000
$1,000
$6,500
$6,500
$27,500
$8,250
$8,250
$1,375
Total Annual O&M Cost
$45,375
Periodic Costs for MMC Study Area
Description
Quantity
Unit
Unit Cost
Total
Five year review (Yea r 5, 10,... 50)
10
EA
$10,000
$100,000
Update Institutional Controls Plan
1
EA
$4,000
$4,000
Remedial Action Report
1
EA
$10,000
$10,000
Total Periodic Cost $114,000
Notes
1, Cost estimates may be refined when the remedy is designed and implemented and
are within +50 to -30% accuracy expectation.
2 Abbreviations
LS = lump sum; HR = hour; EA = each; CY = cubic yard
-------
Table 32. Summary of Present Worth Analysis - MMC Study Area
Present Present Worth
Annual Periodic Discount Worth of of Periodic
Year
Capital Cost
O&M Cost
Cost
Total Cost
Factor (7%)
O&M Cost
Cost
0
$298,772
$298,772
1
$45,375
$45,375
0,935
$42,407
2
$45,375
$45,375
0.873
$39,632
3
$45,375
$45,375
0.816
$37,040
4
$45,375
$45,375
0,763
$34,616
5
$45,375
$24,000
$69,375
0.713
$32,352
$17,112
6
$45,375
$45,375
0.666
$30,235
7
$1,478,032
$45,375
$1,523,407
0.623
$28,257
8
$12,350
$12,350
0,582
$7,188
9
$12,350
$12,350
0.544
$6,718
10
$12,350
$10,000
$22,350
0.508
$6,278
$5,083
11
$12,350
$12,350
0.475
$5,867
12
$12,350
$12,350
0.444
$5,484
13
$12,350
$12,350
0.415
$5,125
14
$12,350
$12,350
0.388
$4,790
15
$12,350
$10,000
$22,350
0,362
$4,476
$3,624
16
$12,350
$12,350
0.339
$4,183
17
$12,350
$12,350
0.317
$3,910
16
$12,350
$12,350
0.296
$3 654
19
$12,350
$12,350
0.277
$3,415
20
$12,350
$10,000
$22,350
0.258
$3,191
$2,504
21
$12,350
$12,350
0 242
$2,963
22
$12,350
$12,350
0.226
$2,788
23
$12,350
$12,350
0,211
$2,605
24
$12,350
$12,350
0.197
$2,435
25
$12,350
$10,000
$22,350
0,184
$2,275
$1,842
26
$12,350
$12,350
0.172
$2,127
27
$12,350
$12,350
0.161
$1,987
28
$12,350
$12,350
0,150
$1,857
29
$12,350
$12,350
0.141
$1,736
30
$12,350
$10,000
$22,350
0.131
$1,622
$1,314
31
$12,350
$12,350
0.123
$1,516
32
$12,350
$12,350
0.115
$1,417
33
$12,350
$12,350
0.107
$1,324
34
$12,350
$12,350
0.100
$1,238
35
$12,350
$10,000
$22,350
0.094
$1,157
$937
36
$12,350
$12,350
0.088
$1,081
37
$12,350
$12,350
0.082
$1,010
38
$12,350
$12,350
0.076
$944
39
$12,350
$12,350
0.071
$882
40
$12,350
$10,000
$22,350
0.067
$825
$668
41
$12,350
$12,350
0,062
$771
42
$12,350
$12,350
0.058
$720
43
$12,350
$12,350
0.055
$673
44
$12,350
$12,350
0.051
1629
45
$12,350
$10,000
$22,350
0.048
$588
$476
46
$12,350
$12,350
0.044
$550
47
$12,350
$12,350
0.042
$514
48
$12,350
$12,350
0 039
$480
49
$12,350
$12,350
0.036
$449
50
$12,350
$10,000
$22,350
0.034
$419
$339
Totals
$1,776,804
$848,675
$114,000
$2,739,479
$348,420
$33,980
Total Net Present Worth I $2,159,205 j
$2.2 million
-------
Table 33. Cost Estimate Summary for DMC Study Area
Capita) Costs for DMC Study Area
Description
Quantity
Unit
Unit Cost
Total
1, Site Preparation and Management
Equipment mobilization
1
LS
$5,000
Submittals and plans
1
LS
$8,740
Temporary facilities
1
LS
$5,000
Erosion control measures
500
LF
$4.00
$2,000
Excavation support system
2,800
SF
$9.18
$25,704
Utility dismantling/replacement
1
LS
$50,000
2. Pre-Remedial Soil Sampling
Drill rig
5
day
$1,500
$7,500
Sampling and analysis
LS
$30,500
Field equipment
LS
$2,500
Surveying
LS
$5,000
Data evaluation
75
HR
$75
$5,625
3. Excavate and Backfill
Excavate soil
5,100
CY
$5
$25,500
Dust control and air monitoring
1
EA
$10,000
Post-remedial sampling
15
EA
$550
$8,250
Furnish clean fill
6,120
CY
$24
$146,880
4. Soil Disposal (RCRA listed soil)
7650
ton
$225
$1,721,250
Subtotal
$2,059,449
Contingency Allowances (30%)
$617,835
Project Management
$72,318
Remedial Design
$86,782
Construction Management
$86,782
Institutional Controls
$15,000
Total Capital Cost
$2,938,166
Operation and Maintenance Cost for DMC Study Area
Description
Quantity
Unit
Unit Cost
Total
Site Monitoring
Groundwater sample collection
1
event
$6,500
$6,500
Contingency Allowances (30%)
$1,950
Technical Support
$3,575
Project Management
$975
Total Annual O&M Cost
$13,000
Periodic Costs for DMC Study Area
Description
Quantity
Unit
Unit Cost
Total
Five year review {Year 5, 10,... 50)
10
EA
$10,000
$100,000
Update Institutional Controls Plan (Year 5)
1
EA
$4,000
$4,000
Remedial Action Report (Year 10)
1
EA
$10,000
$10,000
Total Periodic Costs
$114,000
Notes
1. Cost estimates may be refined when the remedy is designed and implemented and
are within +50 to -30% accuracy expectation.
2. Abbreviations
LS = lump sum; HR = hour; EA = each; CY = cubic yard; SF = square foot
-------
Table 34. Summary of Present Worth Analysis - DMC Study Area
Present Present
Annual Periodic Discount Worth of Worth of
Year Capital Cost O&M Coat Cost Total Cost Factor (7%) O&M Cost Periodic Cost
0
$2,938,166
$2,938,166
1
$13,000
13000
0.935
$12,155
2
$13,000
13000
0.873
$11,349
3
$13,000
13000
0.816
$10,608
4
$13,000
13000
0.763
$9,919
5
$13,000
$24,000
$37,000
0,713
$9,269
$17,112
6
$13,000
13,000
0.666
$8,658
7
8
$13,000
$13,000
13,000
13,000
0,623
0,582
$8,099
$7,566
9
$13,000
13,000
0.544
$7,072
10
$13,000
$10,000
$23,000
0.508
$6,604
$5,080
11
$13,000
$13,000
0.475
$6,175
12
$13,000
$13,000
0.444
$5,772
13
$13,000
$13,000
0,415
$5,395
14
$13,000
$13,000
0.3B8
$5,044
15
$13,000
$10,000
$23,000
0.362
$4,706
$3,620
16
$13,000
$13,000
0.339
$4,407
17
$13,000
$13,000
0.317
$4,121
18
$13,000
$13,000
0.296
$3,848
19
$13,000
$13,000
0,277
$3,601
20
$13,000
$10,000
$23,000
0.258
$3,354
$2,580
21
$13,000
$13,000
0.242
$3,146
22
$13,000
$13,000
0.226
$2,938
23
$13,000
$13,000
0.211
$2,743
24
$13,000
$13,000
0.197
$2,561
25
$13,000
$10,000
$23,000
0.184
$2,392
$1,840
26
$13,000
$13,000
0.172
$2,236
27
$13,000
$13,000
0.161
$2,093
28
$13,000
$13,000
0.150
$1,950
29
$13,000
$13,000
0.141
$1,833
30
$13,000
$10,000
$23,000
0.131
$1,703
$1,310
31
$13,000
$13,000
0.123
$1,599
32
$13,000
$13,000
0.115
$1,495
33
$13,000
$13,000
0.107
$1,391
34
$13,000
$13,000
0,100
$1,300
35
$13,000
$10,000
$23,000
0.0937
$1,218
$937
36
$13,000
$13,000
0.0875
$1,138
37
$13,000
$13,000
0.0818
$1,063
38
$13,000
$13,000
0 0765
$995
39
$13,000
$13,000
0.0715
$930
40
$13,000
$10,000
$23,000
0,0668
$868
$668
41
$13,000
$13,000
0,0624
$811
42
$13,000
$13,000
0.0583
$758
43
$13,000
$13,000
0.0545
$709
44
$13,000
$13,000
0.0509
$662
45
$13,000
$10,000
$23,000
0.0476
$619
$476
46
$13,000
$13,000
0 0445
$579
47
$13,000
$13,000
0.0416
$541
48
$13,000
$13,000
0.0389
$506
49
$13,000
$13,000
0.0363
$472
50
$13,000
$10,000
$23,000
0.0339
$441
$339
Totals
$2,938,166
$650,000
$114,000
$3,702,166
$179,409
$33,962
Total Net Present Worth
$3,151,537 I
$3.2 million
-------
Table 35, Cost Estimate Summary for Alternative Water Supply
Capital Costs for Alternative Water Supply
Description
1. Mobilization/Demobilization
2. Site Preparation
Erosion arid Sediment Control Systems
Test Pits
Rock Removal
3. Public Safety
Maintenance & Protection of Traffic
Uniform Police (State Road Work)
4. Water Main Installation
6" DIP Water Main
6" DIP Water Main-Extension from Middletown
Wedge Blowoff
6" Gate Valve and box
Dewatermg
Stream Crossing
Copper water service connection (1" or 2")
Water meter (1" or 2")
Supply from property line to house (1" or 2")
Disinfection of water main
Pressure and leakage tests
5. Shut-down of former water systems
Potable well abandonment
Remove existing point of use systems
6. Pavement/Sidewalk Repairs
Sawcutting and Removal of Pavement
Temporary Paving
Permanent Paving
Driveway Repair/Replacement
Pavement Markings
Turf Establishment
Sidewalk Repairs
Subtotal
Contingency Allowances (30%)
Subtotal [Remedy Implementation]
Project Management
Remedial Design
Construction Management
Institutional Controls
UNIT
TOTAL
Quantity
Unit
Unit Cost
Total
1
LS
$20,000
1
LS
$15,000
$15,000
26
EA
$250
$6,500
1200
CY
$60
$72,000
1
LS
$100,000
$100,000
220
Day
$400
$88,000
7900
LF
$63
$497,700
7500
LF
$63
$472,500
3
EA
$1,000
$3,000
54
EA
$1,150
$62,100
1
LS
$15,000
$15,000
3
EA
$12,000
$36,000
85
EA
$844
$71,765
85
EA
$305
$25,925
6717
LF
$30
$201,510
1
LS
$15,000
$15,000
1
LS
$10,000
$10,000
85
EA
$1,800
$153,000
53
EA
$350
$18,550
LS
$166,405
LS
$57,000
LS
$509,200
LS
$23,220
LS
$5,400
LS
$248,000
LS
$16,000
$2,908,775
$872,832
$3,781,407
$189,070
$302,513
$226,884
$50,000
Total Capital Cost
$4,549,874
-------
Table 35, Cost Estimate Summary for Alternative Water Supply
Annual Operation and Maintenance Cost for Alternative Water Supply
Description
1. System maintenance/replacement
2. Labor (O&M, regulatory compliance, admin)
Subtotal
Technical Support (15%)
Contingency Allowances (30%)
Project Management (5%)
UNIT TOTAL
Quantity Unit Unit Cost Total
50 Year $75,628 $3,781,400
50 Year $40,000 $2,000,000
$5,781,400
$867,210
$1,734,420
$289,070
Total O&M Cost
18,672,100
Annual O&M Cost
$173,442
Periodic Costs for Alternative Water Supply
UNIT
Description
Quantity
Unit
Unit Cost
Total
Five year review (Year 5,10 . 50)
10
EA
$5,000
$50,000
Update Institutional Controls Plan
1
EA
$4,000
$4,000
Remedial Action Report
1
EA
$10,000
$10,000
Total Periodic Cost
$64,000
Notes
1. Cost estimates may be refined when the remedy is designed and implemented and
are within +50 to -30% accuracy expectation.
2, Abbreviations
LS = lump sum; HR = hour; EA = each; CY = cubic yard, SF = square foot; LF = linear foot
-------
Table 36. Summary of Present Worth Analysis - Alternative Water Supply
Present Present Worth
Annual O&M Discount Factor Worth of of Periodic
Year Capital Cost Cost Periodic Cost (7%) O&M Cost Cost
$4,549,874
1
$173,442
0.935
$162,168
2
$173,442
0.873
$151,415
3
$173,442
0.816
$141,529
4
$173,442
0.763
$132,336
5
$173,442
$9,000
0.713
$123,664
$6,417
6
$173,442
0.666
$115,512
7
$173,442
0.623
$108,054
8
$173,442
0.582
$100,943
9
$173,442
0.544
$94,352
10
$173,442
$5,000
0,508
$88,109
$2,540
11
$173,442
0.475
$82,385
12
$173,442
0.444
$77,008
13
$173,442
0,415
$71,978
14
$173,442
0.388
$67,295
15
$173,442
$5,000
0.362
$62,786
$1,810
16
$173,442
0.339
$58,797
17
$173,442
0,317
$54,981
18
$173,442
0.296
$51339
19
$173,442
0.277
$48,043
20
$173,442
$5,000
0.258
$44,748
$1,290
21
$173,442
0.242
$41,973
22
$173,442
0.226
$39,198
23
$173,442
0.211
$36,596
24
$173,442
0.197
$34,168
25
$173,442
$5,000
0.184
$31,913
$920
26
$173,442
0,172
$29,832
27
$173,442
0.161
$27,924
28
$173,442
0.150
$26,016
29
$173,442
0.141
$24,455
30
$173,442
$5,000
0.131
$22,721
$655
31
$173,442
0.123
$21,333
32
$173,442
0,115
$19,946
33
$173,442
0,107
$18,558
34
$173,442
0,100
$17,344
35
$173,442
$5,000
0,0937
$16,252
$469
36
$173,442
0.0875
$15,176
37
$173,442
0.0818
$14,188
38
$173,442
0.0765
$13,268
39
$173,442
0.0715
$12,401
40
$173,442
$5,000
0.0668
$11,588
$334
41
$173,442
0.0624
$10,823
42
$173,442
0.0583
$10,112
43
$173,442
0 0545
$9,453
44
$173,442
0.0509
$8,828
45
$173,442
$5,000
0 0476
$8,256
$238
46
$173,442
0.0445
$7,718
47
$173,442
0.0416
$7 215
48
$173,442
0.0389
$6,747
49
$173,442
0,0363
$6,296
50
$173,442
$15,000
0.0339
$5,880
$509
Totals
$4,549,874
$8,672,100
$64,000
$2,393,621
$15,181
Total Net Present Worth
j $6,958,676~~|
$7,0 million
-------
Table 37. Cost Estimate Summary for Site-wide Groundwater Study Area
Capital Costs For Site-wide Groundwater Study Area Monitoring
Description Quantity Unit
UNIT
Unit Cost
Total
1. Mobilization/Demobilization
2. Installation of bedrock well
3. Well Development
1 LS
8 EA
8 EA
$5,000
$8,000
$2,000
$5,000
$64,000
$16,000
Subtotal
$85,000
Contingency Allowances (30%)
$25,500
SUBTOTAL [Remedy Implementation]
$110,500
Project Management (8%)
Construction Management (10%)
Institutional Controls
$8,840
$11,050
$5,000
Total Capital Cost
$135,3S0
Operation and Maintenance Cost for Site-wide Groundwater Study Area Monitoring
Description
Quantity Unit
Unit Cost
Total
Groundwater Sampling
Equipment and Labor to Collect
Sample Analysis
12 event
12 event
$8,420
$13,600
$101,040
$163,200
Subtotal
Technical Support (15%)
Contingency Allowances (30%)
Project Management (5%)
$264,240
$39,636
179,272
$13,212
Total O&M Cost
$396,360
total Annual O&M Cost
$39,636
Periodic Costs for Site-wide Groundwater Study Area Monitoring
Description Quantity Unit
UNIT
Unit Cost
Total
Five year review (Years 5-10)
Update Institutional Controls Plan
Remedial Action Report (Year 10)
2 EA
1 EA
1 EA
$10,000
$4,000
$10,000
$20,000
$4,000
$10,000
Total Periodic Cost
$34,000
Notes
1 Cost estimates may be refined when the remedy is designed and implemented and
are within +50 to -30% accuracy expectation,
2. Abbreviations
LS = lump sum; HR = hour; EA = each; CY = cubic yard; SF = square foot; LF = linear foot
-------
Table 38. Summary of Present Worth Analysis - Site-wide Groundwater Study Area
Annual O&M Discount Factor Present Worth Present Worth
Year Capital Cost Cost Periodic Cost (7%) of O&M Cost of Periodic Cost
0 $135,390
1 $39,636 0.935 $37,043
2 138,636 0.873 $34,620
3 $39,636 0.816 132,355
4 $39,636 0,763 $30,238
5 $39,636 $14,000 0.713 $28,260 $9,982
6 $39,636 0.666 $26,411
7 $39,636 0.623 $24,683
8 $39,636 0.582 $23,069
9 $39,636 0.544 $21,559
1 0 $39,636 $20,000 0.508 $20,149 $10,167
Totals $135,390 $396,360 $34,000 $278,387 $20,149
Total Present Worth Cost ( $433,925
$434,000
-------
Table 39. Cost Estimate Summary for Sitewide Groundwater Study Area
Contingency Remedy for Hydraulic Containment by Groundwater Extraction
Capital Costs for Source Zone Hydraulic Containment
UNIT
TOTAL
Description
Quantity
Unit
Unit Cost
Total
1. Mobilization/Demobilization
1
LS
$10,000
$10,000
2. Site Preparation
Submitals
1
LS
$16,600
$16,600
Erosion and Sediment Control Systems
1
LS
$1,000
$1,000
Rock Removal
333
CY
$60
$19,980
3. Public Safety
Maintenance & Protection of Traffic
1
LS
$30,000
$30,000
Uniform Police (State Road Work)
30
Day
$400
$12,000
4. Pre-Remedial Study
Drill Rig
1
LS
$25,000
$25,000
Sampling arid Analysis
1
LS
$39,100
$39,100
Pump Test
1
LS
$5,000
$5,000
Surveying
1
LS
$7,500
$7,500
Data Evaluation
150
HR
$75
$11,250
5 Treatability Study
Work Plan
125
LS
$100
$12,500
Equipment Mobilization
1
LS
$27,000
$27,000
Sampling and Analysis
1
LS
$71,250
$71,250
Data Evaluation
300
HR
$100
$30,000
6 Groundwater Extraction System
Extraction Well Drilling
7
EA
$11,000
$77,000
Well Pumps Installation
7
EA
$3,000
$21,000
Well Development
7
EA
$2,000
$14,000
7. Groundwater Treatment System
Building Preparation and Construction
1
LS
$375,950
$375,950
Dewatering Allowance
1
LS
$15,000
$15,000
Treatment Equipment and Instrumentation
1
LS
$510,300
$510,300
Piping from extraction to treatment & to discharge
1
LS
$135,000
$135,000
Initial Start-up
1
LS
$19,330
$19,330
8- Groundwater Monitoring Wells
6
EA
$21,000
$126,000
9. Pavement/Sidewalk Repairs
Sawcutting and Removal of Pavement
1
LS
$46,900
$46,900
Local Road Pavement Repair
1
LS
554,800
$54,800
State Road Pavement Repair
1
LS
$34,250
$34,250
Replace Concrete Pavement with Bituminous
1
LS
$18,900
$18,900
Driveway Repair/Replacement
1
LS
$3,450
$3,450
Pavement Markings
1
LS
$3,000,00
$3,000
Turf Establishment
1
LS
$5,000
$5,000
Stream Crossing
1
EA
$12,000
$12,000
Sidewalk Repairs
1
LS
$1,440.00
$1,440
Subtotal
$1,791,500
Contingency Allowances (30%)
$537,45C
Subtotal [Remedy Implementation]
$2,328,950
Project Management
$139,737
Remedial Design
$279,474
Construction Management
$186,316
Institutional Controls
$10,000
Total Capital Cost
$2,944,477
-------
Table 39. Cost Estimate Summary for Sitewide Groundwater Study Area
Contingency Remedy for Hydraulic Containment by Groundwater Extraction
Annual Operation and Maintenance Cost for Alternative Water Supply
UNIT
TOTAL
Description
Quantity
Unit
Unit Cost
Total
1, Treatment and Building
50
Year
$128,779
$6,438,950
2. Sludge Handling
50
Year
$43,750
$2,187,500
3. Chemical
50
Year
$19,054
$952,700
4. Sampling and Analysis
50
Year
$51,600
$2,580,000
5 Extraction System
50
Year
$23,000
$1,150,000
Subtotal
$13,309,150
Technical Support (15%)
$1,996,373
Contingency Allowances (30%)
$3,992,745
Project Management (5%)
$665,458
Total O&M Cost
$19,963,725
Annual O&M Cost
$399,275
Periodic Costs for Alternative Water Supply
UNIT
Description
Quantity
Unit
Unit Cost
Total
Five year review (Year 5,10... 100)
20
EA
$10,000
$200,000
Update Institutional Controls Plan
1
EA
$4,000
$4,000
Remedial Action Report
3
EA
$10,000
$30,000
Total Periodic Cost
$234,000
Notes
1. Cost estimates may be refined when the remedy is designed and implemented and
are within +50 to -30% accuracy expectation.
2. Abbreviations
IS = lump sum; HR = hour; EA = each; CY = cubic yard; SF = square foot; LF = linear foot
-------
Table 40. Summary of Present Worth Analysis - Sitewide Groundwater
Contingency Remedy for Hydraulic Containment by Groundwater Extraction
Present
Present Worth
Annual O&M
Discount Factor
Worth of
of Periodic
Year
Capital Cost
Cost
Periodic Cost
-------
Table 40. Summary of Present Worth Analysis - Sitewide Groundwater
Contingency Remedy for Hydraulic Containment by Groundwater Extraction
Present Present Worth
Annual O&M Discount Factor Worth of of Periodic
Year Capital Cost Cost Periodic Cost (7%) O&M Cost Cost
51
$399,275
0,032
$12,668
52
$399,275
0030
$11,839
53
$399,275
0-028
$11,064
54
$399,275
0,026
$10,341
55
$399,275
$10,000
0 024
$9,664
$242
56
$399,275
0023
$9,032
57
$399,275
0.021
$8,441
58
$399,275
0,020
$7,889
59
$399,275
0,018
$7,373
60
$399,275
$10,000
0.017
$6,890
$173
81
$399,275
0.016
$6,440
62
$399,275
0,015
$6,018
63
$399,275
0.014
$5,625
64
$399,275
0.013
$5,257
65
$399,275
$10,000
0012
$4,913
$123
66
$399,275
0.011
$4,591
67
$399,275
0.011
$4,291
68
$399,275
0.010
$4,010
69
$399,275
0.0094
$3,748
70
$399,275
$10,000
0.0088
$3,503
$88
71
$399,275
0,0082
$3,274
72
$399,275
0 0077
$3,059
73
$399,275
0.0072
$2,859
74
$399,275
0.0067
$2,672
75
$399,275
$10,000
0.0063
$2,497
$63
76
$399,275
0,0058
$2,334
77
$399,275
0.0055
$2,181
78
$399,275
0.0051
$2,039
79
$399,275
0.0048
$1,905
80
$399,275
$10,000
0.0045
$1,781
$45
81
$399,275
00042
$1,664
82
$399,275
00039
$1,555
83
$399,275
00036
$1,454
84
$399,275
0.0034
$1,358
85
$399,275
$10,000
0.0032
$1,270
$32
86
$399,275
0.0030
$1,186
87
$399,275
0.0028
$1,109
88
$399,275
0,0026
$1,036
89
$399,275
0.0024
$969
90
$399,275
$10,000
0.0023
$905
$23
91
$399,275
0.0021
$846
92
$399,275
0.0020
$791
93
$399,275
0,0019
$739
94
$399,275
0.0017
$691
95
$399,275
$10,000
0 0016
$645
$16
96
$399,275
0.0015
$603
97
$399,275
0.0014
$564
98
$399,275
0.0013
$527
99
$399,275
0.0012
$492
100
$399,275
$20,000
0,0012
$460
$23
Totals
$2,944,477 $39,927,450
$234,000
$5,697,348
$30,600
Total Net Present Worth
1 $a.672.425~|
$8,7 million
-------
Table 41. Cleanup Levels for the MMC Study Area
Carcinogenic Chemical of
Concern
Cancer Classification
Interim Soil Cleanup Level
lug^kg)
Basis
RME Risk
Surface Soil
TetracMoroethene
B2
100
CT RSR (GA/GAA PMC)
4E-08
Trichloroetfiene
C-B2
too
CT RSR (GA/GAA PMC)
3E-08
Benzo(a)anthraeene
B2
1000
CT RSR (RES DEC, GA/GAA PMC)
7E-07
Benzo(a)pyrene
BZ
1000
CT RSR (RES & t/C DEC)
7E-06
Benzo(b)fluoranthene
B2
1000
CT RSR (RES DEC, GA/GAA PMC)
7E-07
Benzo(k)fluoranthene
B2
1000
CT RSR (GA/GAA PMC)
7E-08
Chrysene
B2
1000
CT RSR (GA/GAA PMC)
7E-09
Dibenz(a,h)anthracene
B2
1000
CT RSR (RES & l/C DEC)
7E-06
lndeno(1,2,3-cd)pyrene
B2
1000
CT RSR (RES DEC, GA/GAA PMC)
7E-07
Arsenic
A
10000
CT RSR (RES DEC)
1E-05
Subsurface Soil
Trichloroethene
C-B2
100
CT RSR (GA/GAA PMC)
3E-08
Carcinogenic Chemical of
Concern
Cancer Classification
Interim Soil Vapor Cleanup
Level
^ug/m3)
Basis
RME Risk
Soil Vaoor
Trichloroethene
C-B2
752
CT RSR (proposed RES VC)
9E-07
-------
Table 41. Cleanup Levels for the MMC Study Area
Non-Carcinogenic Chemical
of Concern
Target Endpoint
Interim Soil Cleanup Level
(ugfcg)
Basis
RME Hazard Quotient
Surface Soil
Tetrachloroethene
Liver
100
CT RSR (GA/GAA PMC)
0.00005
Trichloroethene
Liver
100
CT RSR (GA/GAA PMC)
0.002
Aceraphthylene
General Toxicity
8400
CT RSR (GA/GAA PMC)
0.003
Benzo(g,h,i)perylene
General Toxicity
4200
CT RSR (GA/GAA PMC)
0.002
Fluoranthene
Blood/Liver/Kidney
5600
CT RSR (GA/GAA PMC)
0.001
Phenanthrene
General Toxicity
4000
CT RSR (GA/GAA PMC)
0.001
Pyrene
Kidney
4000
CT RSR (GA/GAA PMC)
0.001
Arsenic
Skin
1000
CT RSR (RES DEC)
0.2
Chromium
Gl System
100000
CT RSR (RES and l/C DEC)
0.2
Mercury
CNS
20000
CT RSR (RES DEC)
1
Subsurface Soil
1,2,4-Trimethylbenzene
General Toxicity/Liver/Kidney
7000
CT RSR (GA/GAA PMC)
0.0008
Trichloroethene
Liver
100
CT RSR (GA/GAA PMC)
0.002
Xylene (total)
General Toxicity
19500
CT RSR (GA/GAA PMC)
0,0005
Non-Carcinogenic Chemical
of Concern
Target Endpoint
Interim Soil Vapor Cleanup
Level
(ug/m3)
Basis
RME Hazard Quotient
Soil Vaoor
Trichloroethene
Liver/CNS
752
CT RSR (proposed RES VC)
0.0005
Key
CT RSR - Connecticut Remediation Standard Regulations
GA/GAA PMC - Pollutant Mobility Criteria for Class GA/GAA groundwater
RES DEC - Residential Direct Exposure Criteria
l/C DEC - Industrial/Commercial Direct Exposure Criteria
RES VC - Residential Volatilization Criteria
-------
Table 42. Interim Cleanup Levels for the DMC Study Area
Carcinogenic Chemical of
Concern
Cancer Classification
Interim Cleanup Level
WL)
Basis
RME Risk
Shallow Groundwater
Telrachloroethene
B2
5
CT RSR (GA/GAA GWPC)
3E-08
Trichloroethene
C-B2
5
CT RSR (GA/GAA GWPC)
SE-09
Vinyl Chloride
A
1.6
CT RSR (proposed GWVC)
1E-09
Non-Carcinogenic Chemical
of Concern
Target Endpoint
Interim Cleanup Level
(ug n.)
Basis
RME Hazard Quotient
Shallow Groundwater
1,1,1 -Trichforoethane
Liver
200
CT RSR (GA/GAA GWPC)
0.00002
Ethylbenzene
Liver/Kidney
700
CT RSR (GA/GAA GWPC)
0,0005
Telrachloroethene
Liver
5
CT RSR (GA/GAA GWPC)
0.00004
Toluene
Liver/Kidney
1000
CT RSR (GA/GAA GWPC)
0-0002
T richloroethene
Liver
5
CT RSR (GA/GAA GWPC)
0.003
Vinyl Chloride
Liver
1-6
CT RSR (proposed GWVC)
0.00004
Xylene
General Toxicity
530
CT RSR (GA/GAA GWPC)
0.002
Key
CT RSR - Connecticut Remediation Standard Regulations RES GWVC - Residential Volatilization Criteria
GA/GAA GWPC - Groundwater Protection Criteria for Class GA/GAA groundwater SWPC - Surface Water Protection Criteria
HH RBG - Human health risk-based goal
HQ - Hazard Quotient
ILCR - Incremental Lifetime Cancer Risk
MCL - Safe Drinking Water Act Maximum Contaminant Level
-------
Table 43. Interim Cleanup Levels for the Site-wide Groundwater Study Area
Carcinogenic Chemical of
Concern
Cancer Classification
Interim Cleanup Level
(ug/L)
Basis
RME Risk
Bedrock Groundwater
1,2-Dichloroethane
B2
1
CT RSR (GA/GAA GWPC)
2E-06
Benzene
A
1
CT RSR (GA/GAA GWPC)
1E-06
Methylene Chloride
B2
5
MCL and CT RSR (GA/GAA GWPC)
7E-Q7
Tetrachloroethene
B2
5
MCI and CT RSR (GA/GAA GWPC)
5E-05
Trichloroethene
C-B2
5
MCL and CT RSR (GA/GAA GWPC)
4E-0S
Vinyl Chloride
A
1.6
CT RSR (proposed GWVC)
1E-04
1,4-Dioxane
B2
5-2
HH RBG (ILCR—10-6)
1E-06
Benzo(a)anthracene
B2
0.06
CT RSR (GA/GAA GWPC)
8E-07
BenzQ(a)pyrene
B2
0.2
MCL and CT RSR (GA/GAA GWPC)
3E-05
Benzo(b)fluo ranthene
B2
0,078
HH RBG (ILCR=10-6)
1E-06
Benzo(k)fluoranthene
B2
0.3
CT RSR (SWPC)
4E-07
Bis(2-ethylhexyl)pMhalate
B2
2
CT RSR (GA/GAA GWPC)
5E-07
Dibenz(a.h)anthracene
B2
0.0078
HH RBG (ILGR=1Q-6)
1E-06
lndeno(l ,2,3-cd)pyrene
B2
0.078
HH RBG (ILCR=10-6)
1E-06
Pentachlorophenol
B2
1
MCL and CT RSR (GA/GAA GWPC)
2E-06
Arsenic
A
4
CT RSR (SWPC)
1E-04
-------
Table 43. Interim Cleanup Levels for the Site-wide Groundwater Study Area
Non-Carcinogenic Chemical
of Concern
Target Endpoint
interim Cleanup Level
(ugfl-)
Basis
RME Hazard Quotient
Bedrock Groundwater
1,1-Dichloroethane
Kidney
70
CT RSR (GA/GAA GWPC)
0,07
1,1 -Dichloroethene
Liver
1
CT RSR (RES GWVC)
0.002
1,2-Dichloroethane
Kidney
1
CT RSR (GA/GAA GWPC)
0.005
1,2-Dichloroethene (total)
Blood
104
HH RBG (HQ=1)
1
Benzene
Immune System
1
CT RSR (GA/GAA GWPC)
0.02
cis-1,2-Dichloroethene
Blood
70
CT RSR (GA/GAA GWPC)
0.7
Methylene Chloride
Liver
5
MCL and CT RSR {GA/GAA GWPC)
0.008
Tetrachloroethene
Liver
5
MCL and CT RSR (GA/GAA GWPC)
0.05
Trichloroethene
Liver
5
MCL and CT RSR (GA/GAA GWPC)
2
Vinyl Chloride
Liver
1.6
CT RSR (proposed GWVC)
0.05
Bis(2-ethylhexyl)phthalate
Liver
2
CT RSR (GA/GAA GWPC)
0,01
Pentachlorophenol
Liver/Kidney
1
MCL and CT RSR (GA/GAA GWPC)
0.003
Phenanthrene
General Toxicity
0.077
CT RSR (SWPC)
0.0004
Arsenic
Skin
4
CT RSR (SWPC)
1
Mercury
CNS
0.4
CT RSR (SWPC)
0.4
Vanadium
Kidney
10
HH RBG (HQ = 1)
1
Zinc
Blood
123
CT RSR (SWPC)
0.04
Key
CT RSR - Connecticut Remediation Standard Regulations RES GWVC - Residential Volatilization Criteria
GA/GAA GWPC - Groundwater Protection Criteria for Class GA/GAA groundwater SWPC - Surface Water Protection Criteria
HH RBG - Human health risk-based goal
HQ - Hazard Quotient
ILCR - Incremental Lifetime Cancer Risk
MCL - Safe Drinking Water Act Maximum Contaminant Level
-------
Record of Decision
Appendices
Appendix B
Figures
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date; September 30, 2005
Appendices
-------
Record of Decision
Appendices
List of Figures:
Figure 1,
Figure 2.
Figure 3.
Figure 4.
Figure 5,
Figure 6.
Figure 7.
Figure 8,
Conceptual Site Model.
Site Locus Map.
MMC Study Area, Site Plan and Approximate Locations of Former Site
Features.
DMC Study Area, Site Plan and Approximate Locations of Former Site
Features,
Site-wide Groundwater Study Area, Private Wells and Site Monitoring
Wells.
TCE Results in Bedrock - Spring 1998, Site-wide Groundwater Study
Area.
TCE Results in Bedrock - Fall 1998, Site-wide Groundwater Study Area.
Technical Impracticability Waiver Zone, Site-wide Groundwater Study
Area.
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30, 2005
Appendices
-------
Figure 1. Conceptual Site Modal
PRIMARY PRIMARY SECONDARY SECONDARY
RELEASE RELEASE PATHWAY
sources mechanism sources mechanism
RECEPTOR
HUMAN
BIOTA
EXPOSURE
ROUT*
TmtfMMf
CofttmsrclaJ
Wwtar
C
-------
Cogmcftaug Rrver
76 BncK Lane
MERRIAM
MANUFACTURING
COMPANY
a L -i Hi M
DURHAM
MANUFACTURING
COMPANY
Kom School
Herstg Brook jfl
F W Strong School
Allyn Brook
li
c*" ; 'if
Main Street
Route 17
7 A#4*
\
.flip
egend i >4# Ju
LEGEND
SOURCE USGS 7 S Mmitt Saw I
Outturn; Conn . OuMrangto 1964
Pnolof«tM*d 18W
0V7OO9
METCALF&EDDY AECON
Fig in 2
MTt LOCUS MAP
Durham Mudowt Sup«*1und Srt»
Ourtvam Connecticut
-------
-------
-------
-------
-------
METCALF&EDDY
AECOM
-------
-------
Record of Decision
Appendices
Appendix C
State of Connecticut Letter of Partial
Concurrence
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version; FINAL
Date: September 30, 2005
Appendices
-------
09/30/05 FRI 10:32 FAI 188042440S1
Waste Planning
@002
DEPARTMENT OF ENVIRONMENTAL PROTECTION
79 ELM STREET HARTFORD, CT 06106-5127
PHONE; 860-424-3001
September 30, 2005
STATE OF CONNECTICUT
Gina McCarthy
Commissioner
Ms. Susan Studlien
Director
Office of Site Remediation and Restoration
EPA New England
I Congress Street, Suite 1100 (Mail Code HTO)
Boston MA 02114-2023
Subject; Letter of Partial Concurrence with Proposed Remedy for Durham Meadows MPL Site, Durham
CT
Dear Ms. Studlien,
The Connecticut Department of Environmental Protection (DEP) has reviewed the remedy being
selected by EPA for the Durham Meadows site in Southington, Connecticut. DEP concurs with most
components of the selected remedy, but does not concur with the component of the remedy in which EPA
is proposing to address the risk to public health posed by the volatile organic compounds in shallow
ground water that may migrate into existing or future buildings overlying the ground water plume,
DEP concurs with the following components of the selected remedy which comply with State
ARARS and which will fillly protect public health and the environment:
* excavation and offsite disposal of contaminated soil, in conjunction with soil vapor
extraction, at the Merriam Manufacturing Company (MMC) Study Area (including
excavation of a localized area of contaminated surface soil from an adjacent residential
property)
* excavation and off-site disposal of hot spot areas at the Durham Manufacturing Company
(DMC)
extension of the Middletown Water Distribution System to provide an alternative source
of drinking water (public water) to all residences currently affected by groundwater
pontamination and also to a buffer zone of residences located near the contaminated area.
Development of and connection to a water distribution system from a new groundwater
source is retained as a contingency iheasure. Continuation of interim measures including
monitoring and treatment (filtration) Of impacted residential wells, and provision of
bottled water, as needed are also included
* implementing monitoring of the dissolved groundwater plume to ensure the plume is not
expanding beyond its current general boundary
* a contingency to implement a groundwater extraction system for hydraulic containment if
the overall plume Or source zone is spreading or migrating beyond its current boundary
implementation of a Technical Impracticability Waiver of the applicable or relevant and
appropriate requirements that would normally require cleanup of the groundwater to meet
drinking water standards, since it is not technically practicable to clean up the
groundwater to drinking water standards in a reasonable amount of time
(Printed on Rccylcicd Piper)
http://ticp-4Lite.ct.il)
An Equal Opportunity Employer
-------
09/30/05 FRI 10;32 FAI 18804244051
Waste Planning
00 03
Durham Meadows NPL Site
Letter of Partial Concurrence
September 30,2005
Page 2
institutional controls, primarily in the form of Environmental Land Use Restrictions
(ELURs) as defined in the CT RSRs, and/or by local ordinance, in a variety of areas to
prevent unrestricted future use of certain areas of the Site or contaminated groundwater
Further, DEP supports the proposed collection of additional data to further delineate areas posing
potential indoor air risks on and outside of both the Memam Manufacturing Company and Durham
Meadows Company Study Areas within the Durham Meadows Site, However, DEP does not concur with
the vapor intrusion component of the remedy which proposes that actions will be taken to address
potential indoor air risks (due to volatilization} if unacceptable risks are identified. DEP"s position is that,
since it has already been demonstrated that volatile organic compounds in the shallow groundwater plume
at the Durham Meadows site pose risk outside EPA's acceptable risk range, Connecticut's Remediation
Standard Regulations are applicable requirements (ARARs) over the full area! extent of the shallow
groundwater plume (regardless of parcel boundaries) without any additional parcel-specific risk
assessments. If exceedances of the volatilization criteria for groundwater or soil vapor contained in
Connecticut's Remediation Standard Regulations are identified anywhere in the area) extent of the
shallow groundwater plume, the actions described in the remedy to address potential vapor intrusion
should be triggered. Because of the approach being proposed by EPA for the parcels described above,
DEP does not believe the proposed remedy for vapor intrusion complies with State ARARs and we are
concerned that the final remedial actions will not be adequately protective of public health.
However, the DEP supports every other component of the remedy, all of which are in compliance
with State ARARs, and are necessary and appropriate actions that will remove significant sources of
pollution from the environment and provide a safe supply of drinking water to the residents of Durham.
We look forward to working with you and Other State and local officials as we move toward
implementation of this clean-up to assure that Durham Manufacturing, a valued and valuable member of
Connecticut's business community, is not unduly burdened by the costs of this effort. It will require a
solid public-private partnership to ensure that the remediation we all agree is necessary does not come at
the cost of losing this community enterprise.
Gina McCarthy
Commissioner
GM/cal
-------
Record of Decision
Appendices
Appendix D
Responsiveness Summary
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30,2005
Appendices
-------
Record of Decision - Appendix D
The Responsiveness Summary
THE RESPONSIVENESS SUMMARY
A. PREFACE
In July 2005, the United States Environmental Protection Agency (EPA) issued a
Proposed Plan for the cleanup of the Durham Meadows Superfund Site (Site) in Durham,
Connecticut. The Proposed Plan was based on the Draft Final Baseline Human Health
Risk Assessment, Remedial Investigation, Feasibility Study, and Technical
Impracticability Evaluation Reports, These reports, the Proposed Plan, and all supporting
documents were presented in an Administrative Record and made available at public
information repositories at the Durham Public Library and at EPA's office in Boston,
Massachusetts.
The Proposed Plan included notice of a technical impracticability waiver for federal and
state requirements that would normally require cleanup of groundwater to meet drinking
water standards. The Proposed Plan also included notice of a potential determination,
and solicited comment on the proposed determination, to minimize destruction, loss or
degradation of wetlands pursuant to Section 404 of the Clean Water Act and Executive
Order 11990 (Protection of Wetlands), should work in wetlands areas be required.
Similarly, the Proposed Plan included notice of a potential determination, and solicited
comment on the proposed determination, to minimize potential harm to floodplains
pursuant to Executive Order 11988 (Protection of Floodplains), should work in floodplain
areas at or around the Site be required. Additionally, the Proposed Plan notified the
public of the availability of a Draft Reuse Assessment as part of the Site Administrative
Record, and solicited comments on this document.
From July 13, 2005 to August 12, 2005, the Agency held a 30 day public comment period
to accept public comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the public, EPA held a
public meeting on July 12, 2005, to discuss the Proposed Plan, and held a public hearing
on July 28,2005, to accept any oral comments. The comment period for the Proposed
Plan ended on August 12,2005.
Comments were submitted by a total of 27 entities, either during the public hearing, in
writing, or both. This Responsiveness Summary groups these entities into the following
categories:
• Individuals and elected officials (23 total),
• Connecticut Department of Public Health
• City of Middletown Water & Sewer Department,
• Connecticut Department of Environmental Protection, and
• Durham Manufacturing Company.
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Durham Meadows Superfund Site
Durham, Connecticut
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Date: September 30,2005
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A transcript of the public hearing and all written comments received during the comment
period are attached to this Responsiveness Summary, which is attached to the Record of
Decision, The purpose of this Responsiveness Summary is to provide a concise and
complete summary of significant comments received from the public during the public
comment period, and provide EPA's response to these comments, EPA considered all of
the comments summarized in this document before selecting the final remedy for the Site.
Several individuals mentioned the presence of "dioxin" in the drinking water, and that it
is not effectively captured by the carbon filters. "1,4-Dioxane" is the compound that was
recently identified in groundwater, and carbon filters do not capture this contaminant as
effectively as other volatile organic compounds (V OCs) present in groundwater, 1,4-
Dioxane, however, should not be confused with "dioxin," which is a different type of
contaminant; dioxin is NOT present in groundwater at the Site.
In addition, as a group, Congressmen Robert Simmons and Rosa DcLauro, and Senators
Christopher J. Dodd and Joseph I. Lieberman, submitted two letters to EPA
Administrator Stephen L. Johnson during the public comment period. The Members of
Congress and/or their representatives conducted a meeting with personnel from EPA's
Headquarters office, EPA's Region 1 office (by telephone), and the Durham
Manufacturing Company on July 21, 2005. EPA's response letters to the Members of
Congress, dated August 2, 2005, are provided in the Administrative Record, available at
the Site repositories in Boston, Massachusetts, and at the Durham Public Library in
Durham, Connecticut. The issues presented in the letters, and discussed during the July
21,2005 meeting, however, did not focus on the Site remedy; the letters and EPA's
response are therefore not included in or attached to this Responsiveness Summary.
B. SUMMARY OF CITIZENS' AND LOCAL OFFICIALS' COMMENTS
Twenty-three individuals and local and elected officials submitted comments, either
during the public hearing, in writing, or both. Where appropriate, EPA has grouped
similar comments and prepared a single response.
Citizen Comment 1: Elected officials expressed support for excavation and off-site
disposal of soil from properties owned by the responsible parties and adjacent properties,
and future monitoring for possible plume migration, and requested that impact of cleanup
activities be minimized on neighboring properties and residences.
Response to Citizen Comment 1: Some short-term impacts to the community from
construction related to cleanup activities are expected, however, EPA is committed to
minimizing these impacts to the extent possible. Dust control measures and air
monitoring will be required as necessary, and all construction workers will be required to
have appropriate health and safety training. Truck traffic and noise will be restricted to
certain hours of the day, and EPA will work very closely with the Town of Durham
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Durham, Connecticut
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during coordination of these activities. The duration of actual excavation will be
minimized to the extent possible.
Citizen Comment 2: Elected officials requested that institutional controls, while
necessary, should not place excessive limitations on future use of the properties, and
asked EPA to consider the Town's rural character and the Main Street Historic District,
One elected official specifically stated institutional controls be implemented to the fullest
extent as required to protect current and future occupants and neighbors. Another elected
official specifically requested that land use restrictions not indefinitely prohibit the
redevelopment of the Merriam Manufacturing Company property.
Response to Citizen Comment 2: The two main reasons EPA must require institutional
controls at this Site are to prevent certain groundwater and/or land uses to ensure
protection of human health and the environment, and also to ensure the integrity of the
remedial alternatives to be implemented. EPA endeavors to not place excessive
limitations on future use of properties when it requires institutional controls, to the extent
that protectiveness and remedy integrity can be maintained. The significant restrictions
associated with institutional controls in the different Study Areas can be found in the
Record of Decision, under Section L.2., Description of Remedial Alternatives.
With respect to the Merriam Manufacturing Company (MMC) Study Area, EPA
specifically tailored the cleanup of this Study Area to allow for any future use allowed by
the Town of Durham's zoning regulations (either for residential or industrial/commercial
purposes). The significant restrictions of the institutional controls at this property will be
to ensure that any new structures on the property will be constructed to minimize
potential inhalation risks from any remaining contamination, and to prevent the future use
of groundwater for drinking water. After remedy completion, the restrictions on future
use are expected to be minimal.
Citizen Comment 3: Elected officials and eight individuals expressed general support for
the Durham Manufacturing Company (DMC). Officials and individuals noted that DMC
is the Town's largest taxpayer, is a responsible member of the community, supports
employee participation in voluntary fire and ambulance needs, and has been cooperative
throughout the Superfund process. Several elected officials specifically requested that
EPA also consider financial contributions already made by the company during cleanup
negotiations. One elected official and one individual requested that EPA place no further
demands at all on Durham Manufacturing Company. One individual stated that the
cleanup plan should discuss potential adverse financial impacts to the Durham
Manufacturing Company. Two individuals commented that the responsible parties were
not out of compliance at the time they disposed, therefore they should not be held liable.
Response to Citizen Comment 3: EPA recognizes the community's support for the
Durham Manufacturing Company (DMC), and we also recognize that DMC has already
spent considerable funds on site work. In preparing and selecting a cleanup plan, EPA
selects a remedy that protects human health and the environment, complies with
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Durham, Connecticut
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applicable and relevant and appropriate requirements (ARARs), and satisfies EPA's other
remedy selection criteria, including cost. EPA considered cost in developing the remedy
alternative, and the selected remedy is the most cost-effective remedy that satisfies EPA's
remedy selection criteria.
In selecting a remedy, however, EPA does not consider the financial impact of the
remedy on any particular party or entity. After a remedy is selected, EPA typically looks
to the potentially responsible parties to perform or pay for the cleanup. Now that EPA
has issued this cleanup plan, EPA intends to discuss with all responsible parties the
performance and/or financing of the cleanup work and reimbursement of past costs that
have been incurred at the Site. It is EPA's national policy that responsible parties should
fund a cleanup in the first instance before a cleanup is financed through the federal
Superfund. If a potentially responsible party is unable to pay for or perform a cleanup,
that party can claim an inability to pay, which EPA would evaluate pursuant to
established guidance and procedures.
Under the Superfund law, DMC is a liable, responsible party even though it may not have
violated any laws or regulations when it disposed of hazardous substances If a person or
entity falls within one of the four classes of potentially responsible parties (PRPs), the
Superfund law imposes strict liability for all response costs at the site. This means that
PRPs are liable even if the problems caused by the hazardous substance release were
unforeseeable; the PRP acted in good faith; or state-of-the-art management practices were
used at the time the materials were disposed. The courts have consistently upheld this
retroactive liability scheme.
Citizen Comment 4: One individual expressed concern regarding adverse impacts of the
soil cleanup remedy on the Durham Manufacturing Company's ongoing business.
Response to Citizen Comment 4: EPA's primary goal for the cleanup alternative
selected for the DMC Study Area is mitigation of risk to human health, as well as mass
contaminant removal in order to remove source areas that continue to contribute to
groundwater contamination to the maximum extent practicable. During the screening of
remedial alternatives for this Study Area, EPA considered the implementability of certain
alternatives, as well as potential impacts on surrounding residents and businesses. While
potential adverse financial impacts are not explicitly addressed in the cleanup plan, EPA
will seek to minimize the disruption to DMC's ongoing business to the extent possible.
(Further discussion of this issue is provided in the Response to DMC Comment 6.)
Citizen Comment 5: One elected official and five individuals requested that more
pressure be put on Merriam Manufacturing Company, with three individuals specifically
mentioning the fact that Merriam Manufacturing Company is no longer filtering and
monitoring residences as it is required to under state order,
Response to Citizen Comment 5: As discussed above in the response to Citizen
Comment 3, EPA will work with all interested parties to examine ways to equitably pay
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Durham, Connecticut
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for a Site-wide remedy. If the negotiations to perform and/or finance the cleanup of the
Site are unsuccessful, EPA will consider enforcement action against any non-settling
PRP.
Citizen Comment 6; Three individuals stated that the companies were responsible for the
pollution and should be held liable. One individual stated further that the primary
contributors should be held accountable since the source of any grants and EPA funding
is the taxpayers. One individual specified that the cost of hook-ups to a water system for
the public facilities, businesses and residences with contaminated private water supplies
should be borne by Merriam Manufacturing Company and the Durham Manufacturing
Company, and that a special tax assessment would allow municipal bonding to be paid
off by these companies over an extended period of time.
Response to Citizen Comment 6; The two companies in question are PRPs as defined
under the Super fund Law (see Response to Citizen Comment 3), and EPA will seek to
enter cleanup negotiations with these parties. Any municipal bonding or special tax
assessment issues are at the discretion at the Town of Durham.
Citizen Comment 7: An individual stated that the source of funding for cleanup is a very
significant component of the plan, and that it is hard to make a decision if the source of
funding is unclear.
Response to Citizen Comment 7: EPA's Feasibility Study outlines the estimated cost for
each remedial alternative developed and considered for the Site. EPA's Proposed Plan
outlines these alternatives and their estimated costs, and presents EPA's preferred
alternative (or combination of alternatives), While the cost of the remedy is one of nine
criteria that EPA uses to evaluate the remedial alternatives, the source of funding is not
taken into consideration in the Record of Decision. The final cleanup plan is not
identified until the Record of Decision is issued, and until this happens, EPA cannot enter
into negotiations with PRPs to discuss performance and/or financing of the selected
remedy.
it is EPA's strong preference that the PRPs perform and/or fund cleanup work at
Superfund sites, and the Superfund Law is structured to encourage this (see Response to
Citizen Comment 3). If PRPs cannot or will not perform a remedy, Superfund monies
may be made available in the future towards this Site, as necessary.
Citizen Comment 8: Several elected officials expressed support for the future connection
to the Middletown Water Distribution System or another alternative source of public
water, with certain of the officials specifically identifying the connection to the
Middletown Water Distribution System. Eight individuals also specifically expressed
support for an alternative water supply. One individual stated they prefer using their own
well water, despite the contamination, but is ultimately in favor of the public water
supply.
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Durham, Connecticut
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Response to Citizen Comment 8: As a point of note, apart from the one comment above
indicating a general preference to continue using existing well water, EPA did not receive
any comments specifically opposing the alternative water supply options. More specific
comments related to this issue follow. EPA determined that Alternative AWS-2
Connection to Middletown Water Distribution System was the most cost effective of the
remedial alternatives as it meets the threshold criteria and provides the best balance of the
five balancing criteria as described in Section K of the Record of Decision.
Citizen Comment 9: One elected official and one individual requested that the water line
specifically include fire flow capacity.
Response to Citizen Comment 9: Under the Superfund law, EPA is limited to addressing
only the potable water needs of impacted citizens at the Superfund Site. The alternative
analyzed in EPA's Feasibility Study, AWS-2 Connection to the Middletown Water
Distribution System, is limited to providing water service only to the Durham Meadows
Superfund Site for drinking water purposes.
With respect to fire protection, however, Appendix I of the Feasibility Study does
provide a breakout of additional costs that would be required to provide fire protection,
including greater capacity piping as well as the added cost for hydrants. An additional
cost estimate of $70,000 is provided for including the Strong School, located at 191 Main
Street, to the water line. The additional capital costs to provide all additional costs
necessary to provide pipe capacity for fire protection, range from approximately
$200,000 to $600,000. This range is a function of the potential fire flow demands.
Citizen Comment 10: Two individuals asked who would pay for the annual cost of water
provided from the Middletown Water Distribution System.
Response to Citizen Comment 10: Cost estimates for this alternative include all costs
associated with hookup of individual homes and abandonment of on-site private drinking
water wells. EPA's authority does not include providing funding of the actual supply of
water to individual homeowners. EPA expects that this cost would be borne by the
homeowners.
Implementation of this alternative requires the development of administrative and
operation and maintenance functions. Administrative responsibilities will include billing,
as well as customer service, and regulatory compliance. Under alternative AWS-2,
Connection to the Middletown Water Distribution System, administrative agreements
between the City of Middletown and the Town of Durham shall be required to formally
assign these responsibilities. It is expected, therefore, that the City of Middletown and/or
the Town of Durham will determine the cost of water for homeowners.
Citizen Comment 11: An individual asked if the City of Middletown could contribute
money to the Town of Durham if residents have to pay for water.
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Durham, Connecticut
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Response to Citizen Comment 11: The City of Middletown is not a responsible party at
the Durham Meadows Super fund Site, and therefore has no specific obligation to
contribute financially toward this project. As a point of note, the City of Middletown
charges its own residents for their direct water use.
Citizen Comment 12: Four individuals want the connection to the Middletown Water
System to provide a more extensive hookup to residences beyond the Superfund Site. A
few individuals mentioned areas impacted by local gasoline stations. One individual
mentioned the Durham Heights area (due to the use of septic systems on undersized lots)
and an area adjacent to the closed Durham-Middlefield Landfill, and also stated that
water line connection should be designed to include hook-up to the Durham Center Water
System. Last, one individual suggested that cleaning up groundwater is one of the
mandates of Superfund, therefore EPA should meet the spirit of that mandate by hooking
up residences outside of the plume area.
Response to Citizen Comment 12: Under the Superfund law, EPA is limited to
addressing only the potable water needs of citizens at the Superfund Site that are or may
come to be impacted by Site-related contaminants. The alternatives analyzed in EPA's
Feasibility Study are all limited to providing water service only to the Durham Meadows
Superfund Site for drinking water purposes.
EPA understands that there are other areas within the Town of Durham that may
potentially benefit from provision of an alternate supply of water, including the areas
mentioned by the citizens in their comments. Should the Town of Durham or other
officials wish to enter into discussions regarding these other areas (and potentially with
other parties affiliated with these areas) in an attempt to coordinate an effort that is
broader than just the Superfund Site, EPA will participate in these discussions.
Superfund monies cannot, however, be used to directly address areas outside of the
Superfund Site.
Citizen Comment 13: Two individuals specifically commented that areas impacted by
MTBE [methyl tertiary-butyl ether] contamination from gas stations should also be
addressed since the federal government mandated use of MTBE as a gasoline additive. A
third individual suggested that the gas companies participate in funding a water line.
Response to Citizen Comment 13: As previously stated, under the Superfund law, EPA
is limited to addressing only the potable water needs of impacted citizens at the
Superfund Site. MTBE is not a Site-specific contaminant at the Durham Meadows
Superfund Site, and the MTBE contamination in groundwater elsewhere in the Town of
Durham has not commingled with contamination at the Superfund Site. The State of
Connecticut is currently addressing areas impacted by gasoline contamination under the
Underground Storage Tank program.
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Durham, Connecticut
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Citizen Comment 14: One individual wants EPA and elected officials to work together to
expedite the extension of a water main, and expressed frustration that it could take two
years before residents could get public water.
Response to Citizen Comment 14: As previously stated, EPA does understand that there
are other areas within the Town of Durham that may potentially benefit from provision of
an alternate supply of water, and EPA will participate in discussions with the Town of
Durham or other officials, should they wish to explore an effort to bring an alternate
source of water to an area broader than the Superfund Site, Superfund monies cannot,
however, be used to directly address areas outside of the Superfund Site.
With regard to the implementing of a water main extension, it is expected that actual
construction may take approximately six months to complete. Preliminary activities
required prior to construction will add to the amount of time before an alternate water
supply is extended to area residents. EPA typically negotiates with the responsible
parties regarding the performance or financing of implementing the remedy at the Site.
Conducting these negotiations, entering into a legal agreement to finalize the decisions
made during the negotiations, designing the implementation of the alternate water supply
portion of the remedy, and finalizing the administrative agreements required between the
town(s) to administer, operate and maintain the alternate water supply, are expected to
take a minimum of one year. While the amount of time required to implement the legal
and administrative portions of the remedy might be frustrating, it is crucial that these
matters be finalized before actual construction begins.
It is important to note that until the water main extension is complete and operational, the
remedy includes the continued monitoring and maintenance of existing filters, and
provision of bottled water as necessary, to protect public health.
Citizen Comment 15: Regarding the specific source of an alternate water supply, eight
individuals specifically stated a preference between the Middletown Water Distribution
System and an in-town source of water, with five individuals preferring water from
Middletown, and three individuals preferring an in-town source. One individual
suggested that an in-town source of water may result in a savings to taxpayers.
Response to Citizen Comment 15: As outlined in Section K of the Record of Decision,
the City of Middletown Water Distribution System (Middletown) is selected as the source
of alternative water in the first instance, because it is the most cost effective of the
remedial alternatives as it meets the threshold criteria and provides the best balance of the
five balancing criteria. EPA does recognize, however, that an in-town well may be a
viable alternative. A contingency measure of an alternate water supply via development
of and connection to a new groundwater source is retained in the Record of Decision in
the event that a connection to Middletown cannot be implemented for administrative or
other reasons, or cannot be implemented in a timely manner.
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Durham, Connecticut
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Citizen Comment 16: An individual stated that the Connecticut Water Company, instead
of a municipality, should propose a source of water.
Response to Citizen Comment 16: It is EPA's understanding that the Connecticut Water
Company is currently contracted by the Town of Durham to operate its water system.
The Town of Durham, however, is primarily responsible for the Durham Center Water
System, and is currently focused on making the necessary improvements and upgrades to
that system.
The Durham Center Water System was previously owned and operated by AquaSource,
Inc. (AquaSource was also previously affiliated with the Eastern Connecticut Regional
Water Company, which is not the same as the Connecticut Water Company.) In 2002-
2003, the Town of Durham purchased the in-town water systems, and the water service
rights to the town. Since then, the Town of Durham has been investigating other possible
locations for a primary source of water to replace the current system's inadequate water
supply. As part of this effort, the Town of Durham has been working with the
Connecticut Water Company, as well as other entities, including the Connecticut
Department of Public Health, and the Connecticut Department of Environmental
Protection.
Citizen Comment 17: One individual suggested specific wells in town that should be
investigated as a possible source for the Site, including the Durham Center Water
System, and a well source at an elderly housing complex, a reservoir in the Town of
Wallingford which abuts the Town of Durham. Certain other pieces of property located
on Route 17 were also suggested as potential sources of water, although in later
correspondence, the individual indicated that the properties were no longer available for
this use.
Response to Citizen Comment 17: Under Alternative AWS-3, Development of a New
Groundwater Source and Distribution System, a new groundwater source would be
developed in close proximity to the Study Area (presumably within the town boundaries)
and a distribution system would be installed within the Study Area. When EPA
evaluated this alternative in the Feasibility Study, adequate data was not available to
determine a definitive well source in Town, therefore the Feasibility Study presents this
alternative to include installation and development of a new groundwater supply,
assumed to be upgradient to the north and east of the Study Area, although a specific
supply location was not investigated. The cost estimate for this alternative includes costs
related to the installation and development of the supply well.
As outlined in the Proposed Plan, there are a variety of existing well locations that could
possibly be further investigated as potential sources, including but not limited to the
Durham Fairgrounds wells, the DMC cooling water well, a well at the Parsons
Manufacturing Company, or other potential well locations within the Town of Durham.
The Durham Fairgrounds wells to the south west of the Study Area are currently being
investigated by the Town of Durham as a potential source for the Durham Center water
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Durham, Connecticut
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system. The DMC cooling water well (well #2) may have capacity to provide an
adequate source of water for the Study Area, although there is no information available to
confirm this, A well located at the Parsons Manufacturing Company may reportedly
have enough capacity as well. The Parsons and DMC wells are both currently
contaminated, however, and would require treatment prior to distribution for drinking
water purposes. The need for treatment would increase the cost estimate for this
alternative. Federal and state agencies may also prefer clean water supply options over
contaminated sources.
With respect to the specific suggestions for possible sources, the current wells used by
the Durham Center Water System do not have adequate capacity to service the Supcrfund
Site, As mentioned, the Town of Durham is currently investigating the Durham
Fairgrounds wells as a potential source for its own system. The well at the elderly
housing complex suggested by the individual is one of two smaller systems included as
part of the Town of Durham's 2002-2003 acquisition; it is expected that these smaller
systems do not have the capacity to service additional areas. A connection to the Town
of Wallingford's distribution system was initially reviewed, but not pursued as a viable
alternative as the distance to the closest possible connection was much farther away than
the Middletown system. EPA did not conduct independent testing on any other
properties to support their possible use for public water.
Citizen Comment 18: Three individuals stated that the cost of connecting residences to
the Middletown Water Distribution System should be paid for through grant monies or
directly by EPA or CT DEP. One of these individual mentioned financing possibilities of
local bonding, private expenditures and special taxation. Another individual stated that
the towns of Plymouth and Harwinton were able to get state or federal money to deal
with similar situations. A fourth individual stated that the federal government has
provided the Town with money to purchase local property (White's Farm) to use for a
source of water, and that the water main ends close to the Site.
Response to Citizen Comment 18: The cost of connecting residences impacted by the
Superfund Site is part of the selected remedy and shall be borne by the responsible parties
and/or the federal Superfund. Superfund monies cannot, however, be used to directly
address areas outside of the Superfund Site. CT DEP is currently funding a portion of the
monitoring and filtration required at the Site (at homes impacted by the Merriam
Manufacturing Company), but the source of this funding is limited and cannot be used to
connect residences to the Middletown Water Distribution System. Any municipal
bonding or special taxation issues are at the discretion at the Town of Durham.
Regarding the towns of Plymouth and Harwinton, it is EPA's understanding that the State
of Connecticut utilized special funds to extend existing water lines, only after pursuing
the responsible parties involved in each situation.
It is EPA's understanding that the Town of Durham is currently investigating the
possibility of improving and using wells located on the Town's White's Farm property
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Durham, Connecticut
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for the Durham Center Water System, but has not yet made any such connection to these
wells, EPA is also not aware of the funding source (if any) utilized by the Town of
Durham, to secure ownership of this property.
Citizen Comment 19: Two individuals expressed concern that the contaminated
groundwater plume would spread beyond the area EPA currently identifies for alternate
water supply provision. One individual questioned how the flow of the contaminated
groundwater plume might be impacted by shutting off local drinking water wells and
bringing in another source of water, or construction related to the cleanup remedy or
future development at the Durham Manufacturing Company, and whether additional
residents would be able to be hooked up to a water main if the plume spread.
Response to Citizen Comment 19: The distribution zone of the alternative water supply,
whether from the City of Middletown Water Distribution System or from an in-town
source, is sized to provide a permanent source of drinking water to all residences
currently affected by groundwater contamination as well as a buffer zone of residences
located near the contaminated area. It is assumed 85 service connections would be made
to the water mains (38 homes are currently on filters due to Site contamination).
EPA believes that the buffer zone of residences around those currently impacted is
reasonable and conservative based on the nature and extent of the contaminated
groundwater plume, and EPA's expectation regarding how the groundwater plume will
move after local drinking water wells stop pumping and a new source of water is brought
to the area. As part of the Site-wide Groundwater Study Area remedy, EPA will
implement a monitoring well network to determine whether the plume is migrating or
attenuating, and ensure the plume does not migrate to areas that are currently not affected
by groundwater contamination. As a contingency alternative, if it is found that the
plume is migrating, EPA shall require implementation of a groundwater extraction
system to hydraulically contain the contaminated groundwater source and prevent further
migration into areas that are not currently contaminated. Extracted groundwater would
be piped to a centralized treatment system.
The contaminant mass removal that will be accomplished by source control remedies
implemented at the Merriam Manufacturing Company and Durham Manufacturing
Company Study Areas will further reduce the levels of contamination emanating from the
sources. EPA does not expect that construction related to any portion of the cleanup
remedy will cause the groundwater plume to migrate.
Finally, while EPA does not expect any scenario in which contaminated groundwater
migrates into previously uncontaminated areas and affects additional private drinking
water wells, if this does occur, the protection of human health will be of primary
importance to EPA.
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Durham, Connecticut
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Citizen Comment 20: One individual asked if EPA had studied the long term health
impact of contaminants in groundwater, specifically mentioning the presence of 1,4-
dioxane.
Response to Citizen Comment 20: EPA's Baseline Human Health Risk Assessment
Report, dated June 2005, assessed the estimated long term risk to human health posed by
various media in the different Study Areas. Risk from the domestic use of contaminated
groundwater (e.g., ingestion of contaminated drinking water, dermal contact, and vapor
inhalation while showering and bathing), was estimated for current and future residents.
It was determined that there is a risk posed by the use of contaminated groundwater for
household purposes, using EPA's risk assumption of a worst-case scenario in which
residents are drinking untreated (unfiltered) water. EPA's calculation of risk for this site
also includes consideration of health impacts for 1,4-dioxane, as documented in EPA's
Baseline Human Health Risk Assessment Report, dated June 2005.
This report is available in the Site Administrative Record, located at the Durham Public
Library.
Citizen Comment 21: An individual stated that the presence of the Strong Middle
School at the Site should raise the priority of this Site above others. Another individual
expressed concern about the need for testing at Strong School, due to past bus depot and
automotive repair maintenance and classes at that property.
Response to Citizen Comment 21: With regard to drinking water concerns, the EPA
Feasibility Study provides for an additional cost estimate to include hookup of the Strong
School, located at 191 Main Street, to the alternative water supply. While the Strong
School was previously using an on-site well, filtered to remove groundwater
contamination, as of August 2004, the school uses wells at the Coginchaug Regional
High School and the Korn Elementary School that are upgradient of the Durham
Meadows Site.
With respect to soil testing at the Strong School, EPA has no evidence to suggest that
solvent use and disposal at the adjacent DMC Study Area occurred on the Strong School
property. Prior to initiating the RI/FS, EPA reviewed historical data regarding the Strong
School's own activities with respect to the bus maintenance area and automotive repair
shop, and conducted interviews with past students and teachers regarding these activities.
EPA found no information to suggest solvent use or spills, and as such did not conduct
any testing on the Strong School property beyond sampling of the on-site drinking water
well. {Subsequent investigations by the Strong School itself discovered two leaking
underground storage tanks on the property, formerly used to store petroleum products.
The School is currently monitoring this area, but these contaminants are not related to the
Superfund Site and do not appear to be commingled with contaminated groundwater
coming from the Superfund Site.)
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Durham, Connecticut
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Citizen Comment 22: An individual suggested the use of microbes to break down
contaminants in situ, and specifically cited the use of moderate temperature steam
injection.
Response to Citizen Comment 22: EPA's Feasibility Study did evaluate a variety of in-
situ technologies during the initial screening phase (see Tables 3.1-1, 3.2-1, and 3.3-1 in
the Feasibility Study report). In general, most of the in-situ biological or thermal
technologies were screened out, due to the limited effectiveness given the Site
contaminants and/or specific Site conditions. Certain technologies were also screened
out due to limited effectiveness to address Site-specific risks, or the potential to create
additional risks to residents in the area.
Citizen Comment 23: An individual stated that all of the septic systems on Main Street
should be updated, even if it had to be done by the community.
Response to Citizen Comment 23: Under the Superfund law, EPA does not have the
authority to address this issue as part of the Superfund Site.
Citizen Comment 24: Two individuals requested a reduction in property tax due to the
effects of the Site on property values.
Response to Citizen Comment 24: Under the Superfund law, EPA has no ability to
address the economic impact of a Site on property values. Property taxes are levied by
the Town of Durham pursuant to the Town's regulations, requirements, and discretion.
B. SUMMARY OF COMMENTS FROM THE CONNECTICUT DEPARTMENT
OF PUBLIC HEALTH
The Connecticut Department of Public Health (CT DPH) submitted written comments in
a letter dated August 12, 2005. Comments focused primarily on alternative water supply
issues.
CT DPH agreed with EPA that the best option for the provision of public drinking water
to 85 homes is the extension of the City of Middletown Water Department's
(Middletown's) public water system, but identified several permitting requirements and
exclusive service area issues that must be specifically addressed. CT DPH also notes that
the Town of Durham is actively pursuing additional sources of public drinking water
south of Allyn Brook to serve its own system, the Durham Center System, Specific
issues raised by CT DPH are addressed below:
CT DPH Comment 1: "The [Durham Meadows Superfund Site] is within the Town of
Durham's Exclusive Service Area, Therefore, Durham would have to either relinquish a
portion of its exclusive service area to Middletown, or develop an agreement with
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Durham, Connecticut
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[Middletown] for the purchase of excess water pursuant to Connecticut General Statute
(CGS) 22a-358."
Response to CT DPH Comment 1: This is an administrative item that must be addressed
by the Town of Durham and the City of Middletown. EPA will facilitate coordination
between these two municipalities.
CT DPH Comment 2; "Per CGS 22a-358, [Middletown] must be able to demonstrate
that it has water reserves in excess of those required to maintain an abundant supply of
water to the inhabitants of its service area, such system may sell such excess water to any
other public water system upon approval of the Commissioner of Public Health. Such
approval shall be given only after (1) the applicant has clearly established to the
satisfaction of the commissioner that such abundant supplies are in existence and will
continue to be in existence for ten years, and (2) the purchasing community water system
being supplied has agreed to restrict water usage in the same manner as the applicant
when necessary in accordance with the emergency contingency provisions of the
applicant's water supply plan."
Response to CT DPH Comment 2; During development of the Feasibility Study, EPA's
contractor, Metcalf &. Eddy, conducted several telephone conversations with the City of
Middletown*s Water & Sewer Department in which Middletown indicated that adequate
water supply was available to serve the Durham Meadows Superfund Site. The comment
letter received by the City of Middletown's Water & Sewer Department would also seem
to indicate that Middletown is prepared, from a supply perspective, to serve the Durham
Meadows Superfund Site at a minimum. According to CT DPH's letter, Middletown
would need to provide sufficient information to CT DPH to confirm adequate supply and
satisfy the requirements outlined by CT DPH; the Town of Durham would also have to
agree to any Middletown water restrictions as outlined by CT DPH. These administrative
items must be addressed by the Town of Durham and the City of Middletown; EPA will
facilitate coordination between these two municipalities.
CT DPH Comment 3: "If [Middletown] intends to sell water to Durham, they should
perform an analysis to establish that abundant supplies are in existence and will continue
to be in existence for the 10-year period between 2006 and 2016 to ensure compliance
with CGS 22a-358."
Response to CT DPH Comment 3: As mentioned above, this is an administrative item
for the City of Middletown; Middletown would need to provide this analysis to the
satisfaction of CT DPH.
CT DPH Comment 4; "[Middletown] will be required to submit a Water Main
Application for the proposed water main extension. Moreover, [CT DPH] recommends
that the water main be sized to serve additional customers beyond the 85 residences in the
Superfund area in the event additional contamination occurs beyond the present area of
concern. Fire protection needs also be considered."
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Durham, Connecticut
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Response to CT DPH Comment 4: It is assumed that preparation of the Water Main
Application would be completed during the design phase. Sizing infrastructure and
design scope will require coordination between the Town of Durham, the City of
Middletown, EPA and other state agencies, with a clear understanding of cost
responsibilities.
While the Middletown Water Distribution System may also have adequate capacity to
provide water service to other portions of town, as well as fire protection, the alternative
analyzed in the Feasibility Study is limited to providing water service only to the
Superfund Site for drinking water purposes.
With respect to fire protection, Appendix 1 of the Feasibility Study does provide a
breakout of additional costs that would be required to provide fire protection, including
greater capacity piping as well as the added cost for hydrants. An additional cost
estimate is provided for including the Strong School, located at 191 Main Street, to the
water line. While the Strong School was previously using an on-site well, filtered to
remove groundwater contamination, as of August 2004, the Strong School uses wells at
the Coginchaug Regional High School and the Korn Elementary School that are
upgradient of the Durham Meadows Site. The additional capital costs for the Strong
School hookup are approximately $70,000. Capital costs to provide the additional pipe
capacity as well as fire hydrants necessary for fire protection, range from approximately
$200,000 to $600,000. This range is a function of the potential fire flow demands.
CT DPH Comment 5: As stated above, CT DPH notes that the Town of Durham is in the
process of developing a new drinking water source for the Durham Center Water System
to serve approximately 30 customers. Based on an agreement reached with the Durham
Fair Association earlier this year, the Durham Center Water System will connect two
existing sand and gravel wells to a planned treatment station and storage facility that is
expected to go on-line by the end of 2005. Combined pumping capacity of the two wells
is expected to be in the range of 80 to 100 gallons per minute, pending the outcome of an
updated yield test. The Fairground Wells are located approximately 1,500 feet west of
Main Street (Route 17) and about 1,200 feet south along Main Street from the
trichloroethylene isocontour boundary line shown on Figure 4.3-12 in EPA's July 2005
Proposed Plan.
Response to CT DPH Comment 5: EPA is aware that the Town of Durham and CT DPH
are currently investigating the use of the Durham Fairground Wells to service the
Durham Center Water System. The use of a well in the Town of Durham as an alternate
water supply for the Superfund Site was evaluated in the Feasibility Study; this
alternative was presented in EPA's July 2005 Proposed Plan and EPA specifically
solicited comment on this alternative. At the time, adequate testing was not yet available
regarding the potential use of these wells as an alternative to serve, not only the Durham
Center Water System, but also the Superfund Site. EPA consequently presented a
preferred alternative for a connection to the Middletown Water Distribution System.
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Durham, Connecticut
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EPA does recognize, however, that an in-town well may be a viable alternative. The
alternative water supply portion of the remedy as outlined in the Record of Decision
requires a connection from the City of Middletown Water Distribution System to be
implemented in the Site-wide Groundwater Study Area. As a contingency measure,
however, an alternate water supply via development of and connection to a new
groundwater source is retained in the event connection to the City of Middletown Water
Distribution System cannot be implemented for administrative or other reasons, or cannot
be implemented in a timely manner.
CT DPH Comment 6: The Durham Fairground Wells are less than 1,000 feet south of
Allyn Brook, and the straight-line distance from these wells to the inferred Site
trichloroethylene isocontour line is approximately 1,200 feet. Since very little
monitoring data currently exists for any contaminants associated with the Site south of
Allyn Brook, CT DPH recommends that EPA consider placing monitoring wells on the
south side of Allyn Brook or at other sites to ensure that contaminated groundwater is not
migrating towards the Fairground wells and nearby homes south of the brook.
Response to CT DPH Comment 6: As currently envisioned, Alternative DP-6,
Monitoring, is designed to use 8 new monitoring wells and 17 existing wells within the
Site to monitor the source zone and dissolved plume groundwater. The monitoring well
locations are shown on Figure 6.6-4 in the Feasibility Study. Several new monitoring
wells are located generally south - southwest of the current groundwater plume
boundary, and north of Allyn Brook. One monitoring well is planned for a location south
of Allyn Brook. These proposed monitoring well locations assume that the boundary of
the groundwater plume is generally as outlined on figures in the Feasibility Study. If it is
determined that the boundary of the groundwater plume has migrated significantly farther
south of its currently known boundary, or if the groundwater plume migrates in the
future, additional monitoring wells will be required to better define the plume. The
specific goal of this alternative is to ensure that contaminated groundwater does not
migrate beyond its current boundary into areas that are not currently contaminated.
C. SUMMARY OF COMMENTS FROM THE CITY OF MIDDLETOWN
WATER & SEWER DEPARTMENT
The City of Middletown Water & Sewer Department (Middletown) submitted written
comments in a letter dated August 5, 2005, In its letter, Middletown generally supports
the Water Department Service Extension, and states that the City is committed to
assisting the Town of Durham, with the single caveat that current rate payers and the
citizens of the City of Middletown be held harmless (i.e., cost neutral) for any extension
of service to the Town of Durham. Given that assumption, Middletown provides a
number of specific comments related to the cost estimate for Alternative AWS-2,
Connection to the Middletown Water Distribution System, as presented in the Feasibility
Study. Middletown also provides cost estimates and information for its preferred plan of
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Durham, Connecticut
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action, which would include full fire protection and water service for the Town of
Durham. Middletown's estimate of capital/construction cost ranges from approximately
$7,084 million to $ 13.154 million.
EPA responds below to two separate issues. First, EPA responds to Middletown's cost
estimates and suggested improvements to provide the water service extension as outlined
in EPA's Feasibility Study and Proposed Plan, which is only to provide potable water to
the area affected by the Durham Meadows Superfund Site. A second response follows
for Middletown's preferred plan of action for full fire protection and expanded water
service.
In summary, based on EPA's review of the comment letter, it appears that Middletown
does not take issue with the unit costs or the required elements proposed in the Feasibility
Study, with the exception of three additional items:
District Piping $ 428,280 (ranges from $278,880 - $428,280)
Booster Pump Station $ 450,000
Cherry Hill Water Tower $ 760,000
The cost of these three items and the associated design, management and contingency
costs, primarily accounts for the majority of the difference between the Middletown
capital cost estimate of $7,084 million and EPA's capital cost estimate of $4.55 million.
(Both capital cost estimates are for a six-inch water main to service the Superfund Site
without fire protection.)
Middletown states that these three items provide the additional infrastructure required in
order to allow the connection of the Durham Meadows Superfund Site to the Middletown
water distribution system without impacting current rate payers or the citizens of the City
of Middletown. The basis for the additional items comes from both the Fuss & O'Neill
report, dated May 2000, and an updated review by the City of Middletown Water &
Sewer Department staff. The Fuss & O'Neill report was originally commissioned by the
Town of Durham when the Town was investigating a connection to the City of
Middletown's water distribution system to address a number of areas affected by
groundwater contamination, including but not limited to the Superfund Site.
The May 2000 Fuss & O'Neill report does indeed include these elements, however, this
report evaluated the feasibility study for a water system extension that would include a
number of areas within the Towns of Durham and the neighboring Town of Middlefield
beyond just the Durham Meadows Superfund Site. The water system extension
contemplated in that study would also provide fire protection to all service areas.
According to the May 2000 Fuss & O'Neill report, the average daily demand associated
with all of the identified areas within the towns of Durham and Middlefield is
approximately 187,000 gallons. The report recommends the installation of a 950,000
gallon Cherry Hill Water Storage Tank, and a booster pump station in order to fill the
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proposed tank, which appears to be sized to provide service to all areas identified in the
study, as well as fire protection.
The Durham Meadows Superfund Site average daily demand (not including the Strong
School, located at 191 Main Street) is approximately 40,000 gallons, or 21% of the total
daily demand presented in the Fuss & O'Neill report. Additionally, section 7.1.3.4 (page
7-4) of the May 2000 Fuss & O'Neill report includes a presentation of the required
infrastructure to provide water supply only to the Durham Meadows Superfund Site and
the areas impacted by three gas stations located on Route 17. The Cherry Hill Water
Storage Tank, a booster pump station, and district piping are not included. The capital
cost estimate for this smaller service area is $4,080,000, which includes water mains
sized to provide future fire protection at a fire flow of 3,500 gallons per minute. The
EPA Feasibility Study estimate for an eight-inch main with fire protection includes a
capital cost of approximately $4.8 million, which includes hydrants. In accordance with
the U.S. Army Corps of Engineers/U.S. Environmental Protection Agency manual, A
Guide to Developing and Documenting Cost Estimates During the Feasibility Study
(EPA 540-R-00-002), dated July 2000, the accuracy of cost estimates within a Feasibility
Study is expected to be between -30 and +50 percent; the difference between these two
capital cost estimates is within this appropriate range. The cost estimates in EPA's
Feasibility Study are also developed for comparison purposes, and not intended to be
final cost estimates.
EPA's conclusion at this time is that the district piping, the booster pump station, and the
Cherry Hill Water Storage Tank are not required solely to provide potable water to the
Durham Meadows Superfund Site. However, a detailed review, completed in
conjunction with the City, of the existing water distribution system infrastructure in the
area of the proposed connection may be required in order to determine any necessary
improvements. The potential need for this review shall be discussed during the design
phase. If it is determined during the design phase that one or more of these elements is
required, it is expected that the additional costs will still fall within the appropriate cost
estimate range of -30 and +50 percent.
Middletown's comment letter provides a second cost estimate for their preferred plan of
action for full fire protection and expanded water service, the capital cost estimate of
which is approximately $13,154 million. While Middletown acknowledges that "the
charge of EPA is not to solve economic development and/or fire prevention issues in this
central business area of the Town of Durham," it states further, "...it is essential that the
EPA solution does not proceed in a vacuum of these other requirements."
Middletown's comment letter suggests a cooperative action plan between EPA, federal
and state legislators, the Town of Durham, and the City of Middletown Water
Department to provide a more comprehensive solution to a number of water service and
fire protection problems within the Town of Durham. As part of this cooperative action
plan, Middletown encourages EPA and the Town of Durham establish a Town of Durham
Water Development Fund, in which funds will be contributed from EPA and the
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Durham, Connecticut
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Potentially Responsible Parties for the Durham Meadows Superfund Site. Middletown
further suggests that supplemental funds be added from the State of Connecticut
Petroleum Tank Fund, and that the Town of Durham look to federal legislators for
assistance in providing additional funds to provide for improvements and upgrades
needed for long-term fire protection to the Town of Durham's dowhtown area.
Middletown notes that the extension of water, unlike sanitary sewer, will not impact
development density or affect the rural nature of the town.
It is EPA's expectation that further discussions regarding the water service area will be
required between EPA, the City of Middletown's Water & Sewer Department, and the
Town of Durham, EPA is committed to working closely with these parties during the
design of an alternate water supply, and also supports the expansion of these discussions
if the parties determine that the scope of the water service should be broader than what is
currently contemplated in EPA's Feasibility Study for the Superfund Site, The limit of
EPA's authority, however, is to only provide a potable drinking water source to the
Durham Meadows Superfund Site,
D, SUMMARY OF COMMENTS FROM THE CONNECTICUT DEPARTMENT
OF ENVIRONMENTAL PROTECTION
The Connecticut Department of Environmental Protection (CT DEP) submitted written
comments in a letter dated August 11,2005. In this letter, the CT DEP generally
supported EPA's cleanup proposal and concurs with the following bullets as presented in
the Proposed Plan:
• Excavation and off-site disposal at and adjacent to the Merriam Manufacturing
Company, in conjunction with soil vapor extraction (combination of Alternatives
S-3 and SV-3).
• Excavation and off-site disposal of soil at the Durham Manufacturing Company
property (Alternative DMC GW-5).
• Connection to the Middletown Water Distribution System to provide an
alternative source of water to all residences currently affected by groundwater
contamination and additional residences located near the contaminated area
(Alternative AWS-2).
• Monitoring of the overall area of groundwater contamination to ensure no
migration of groundwater beyond its current general boundary (Alternative DP-6),
with a contingency to implement a groundwater extraction system for hydraulic
containment if the contamination spreads (SZ-2).
• Implementation of a waiver of federal and state requirements that would normally
require cleanup of the groundwater to meet drinking water standards, since it is
not technically practicable to clean up the groundwater to such levels in a
reasonable amount of time (included with combined Alternatives DP-6 and SZ-2).
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Durham Meadows Superfund Site
Durham, Connecticut
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Specific comments from CT DEP and EPA's responses are summarized below:
CT PEP Comment 1: CT DEP agrees that institutional controls should be included in the
remedy. CT DEP states that Environmental Land Use Restrictions (ELURs) pursuant to
Section 22a-133q-t of the Regulations of Connecticut State Agencies are permanent and
enforceable, and therefore considered by CT DEP to be the most reliable form of
institutional control available to prevent future use of polluted groundwater, and prevent
inappropriate future use of certain areas of the Site, CT DEP further states that, in some
situations, the remedy will have to include ELURs to comply with the CT Remediation
Standard Regulations (RSRs), which have been identified as applicable requirements
(ARARs).
Response to CT DEP Comment 1; EPA agrees that institutional controls are required for
the remedy, and have specifically mentioned the use of ELURs pursuant to CT RSRs for
the different Study Areas, Where EPA determines that institutional controls should take
the form of a restriction on the deed, including the MMC and DMC Study Areas, EPA
will implement an ELUR.
EPA believes, however, that certain complicating factors may prevent ELURs from being
implemented in all Study Areas, particularly the fact that only the owner of the property
in question may grant and sign the ELUR, For the Site-wide Groundwater Study Area, it
may also be impossible to reasonably request that every owner of residential property in
the Study Area implement ELURs on their individual properties, especially given the
need for subordination agreements from any entity holding an interest in these properties
(e.g., banks holding mortgages and utilities). EPA therefore reserves the right to
investigate other potential forms of an institutional control.
CT DEP Comment 2: CT DEP concurs with the need for further characterization to
assess the potential for VOCs in shallow groundwater to migrate and pose a potential
indoor air risk to areas beyond the MMC and DMC Study Areas. CT DEP states that this
evaluation must include an investigation to determine the extent and degree of VOC
contamination in the shallow groundwater (delineation of the VOC plume in shallow
groundwater) and an evaluation of the concentrations of VOCs in soil vapor beneath any
buildings overlying such shallow groundwater plume, including the soil vapor beneath
the Durham Manufacturing Company building. CT DEP further states that since the
groundwater at this Site has already been found by EPA to pose "actionable risk" due to
the potential for volatilization from shallow groundwater, and the RSRs have been
identified as applicable requirements (ARARs), the new data to be gathered need not be
subject to another risk assessment by EPA. Instead, new data should be compared to the
appropriate volatilization criteria contained in the RSRs (either residential or
industrial/commercial) to determine if action (or additional action) is needed to address
the threat posed by potential migration of unacceptable concentrations of VOCs into
structures.
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Durham Meadows Superfund Site
Durham, Connecticut
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Response to CT PEP Comment 2: For the DMC Study Area, the Record of Decision
requires further delineation of VOCs in soils and VOCs in overburden groundwater
beneath the DMC facility building to occur during pre-design and/or remedial activities.
If it is determined that contaminated soils or contaminants in overburden groundwater
under the DMC facility building are posing an unacceptable risk to current workers inside
the facility, additional measures shall be taken to address this exposure pathway.
EPA has not made any determination that there is a potential risk to human health posed
by vapor migration to indoor air for any properties beyond the MMC and DMC Study
Areas. The only shallow groundwater currently identified anywhere at the Durham
Meadows Superfund Site is located at the DMC Study Area. Further delineation of
shallow groundwater, and characterization of any such shallow groundwater, is indeed
necessary before the agencies can evaluate this potential pathway. EPA cannot agree that
the volatilization criteria pursuant to CT RSRs will apply as an ARAR to properties
beyond the MMC and DMC Study Areas until such time that shallow groundwater or
other data is collected, the delineation of any VOC plume in shallow groundwater has
occurred, and EPA has made a formal determination that there is an unacceptable risk to
human health being posed by the VOCs,
EPA is committed to working very closely with CT DEP and CT DPH during future
characterization of this potential pathway.
CT DEP Comment 3: CT DEP states that, in accordance with EPA's November 2002
Draft Subsurface Vapor Intrusion Guidance, the groundwater at the Site poses an
actionable risk to indoor air, and since CT RSRs have been identified as applicable
ARARs for this Site, the remedy must provide for compliance with CT's more stringent
volatilization criteria. Further, such criteria must apply to the full extent of the shallow
groundwater plume, not just to the portion of the plume that currently exceeds EPA's
acceptable risk range.
Response to CT DEP Comment 3: As stated in response 2, EPA has not made any
determination that there is a potential risk to human health posed by vapor migration to
indoor air for any properties beyond the MMC and DMC Study Areas. EPA does,
however, remain committed to working with the state agencies during future
characterization of areas potentially posing an indoor air risk, including delineation of
shallow groundwater.
E. SUMMARY OF COMMENTS FROM THE DURHAM MANUFACTURING
COMPANY
The Durham Manufacturing Company (DMC) submitted written comments in a letter
dated August 11, 2005. The letter attached a memo from DMC's contractor, GZA
Geoenvironmental, Inc. (GZA), dated August 10,2005. The comments made by GZA on
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behalf of DMC are primarily of a technical nature, EPA has summarized these comments
and its responses as follows:
DMC Comment 1: GZA states that EPA's Remedial Investigation Report (RI)
"acknowledges that the [Merriam Manufacturing Company (MMC)] site is the primary
source of the 1,4-dioxane in the Site-Wide Groundwater Study Area." GZA also states
that 1,4-dioxane is only detected in three wells in the southern half of the Site, including
one well at the DMC property, the Strong School well, and the well at 168 Main Street,
the latter two of which are suspected source areas. Therefore, DMC should not be
responsible for any cost considerations attributable to the presence of 1,4-dioxane in Site-
wide groundwater with respect to the Point of Use Treatment alternative, or if the
presence of 1,4-dioxane was used as a basis for preferring public water.
Response to DMC Comment 1: GZA incorrectly states that the RI acknowledges that
MMC is the "primary" source of 1,4 dioxane in the Site-Wide Groundwater Study Area.
On page 4-39, the RI states "the compound 1,4-dioxane is more prevalent at the MMC
site than at DMC, coincident with [1,1,1 -Trichloroethane (1,1,1-TCA)] concentrations."
Although the compound 1,4-dioxane was detected in only three of the wells on or
downgradient of the DMC facility, this does not necessarily mean that it was not
introduced into the groundwater at DMC, The data presented in the RI show that there
are generally two separate and distinct plumes at Durham Meadows, the MMC plume and
the DMC plume, as illustrated in Figures 4.3-18 and 4.3-21 for 1,4-dioxane. The
compound 1,4-dioxane is generally associated with 1,1,1-TCA contamination, due to its
use as a stabilizer additive. Both the MMC and DMC facilities used 1,1,1-TCA at
various times. The compounds 1,1,1-TCA and 1,4-dioxane were detected in the
groundwater at both the MMC and DMC sites as shown in Figures 4.3.16 and 4.3.20 of
the RI.
There are no bedrock groundwater monitoring wells on the DMC site, between DMC and
Strong School, or between Strong School and 168 Main Street. EPA conducted three
sampling rounds for 1,4-dioxane near DMC, all within a 7 month timeframe (December
2003 - June 2004), making it difficult to conclude that 1,4-dioxane contamination is
"limited" in either concentration and/or extent near DMC without additional sampling to
account for seasonal fluctuations and provide a greater data set.
DMC Comment 2: GZA states their main concern with the RI, FS, and Proposed Plan for
the DMC property relates to the exaggerated and unsubstantiated extent of DNAPL
(Dense Hon-Aqueous Phase Liquid) in overburden and bedrock. GZA states that the
Conceptual Maximum Extent of DNAPL is not supported because it is based only on
theoretical calculations and not on actual field observations
Response to DMC Comment 2: DNAPL is often not physically encountered at DNAPL
sites, and in the absence of physical evidence, standard practice is to employ a lines of
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Durham, Connecticut
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evidence approach. The following are excerpts from two recently published studies used
as current references in the industry:
First reference. USEPA. 2003. The DNAPL Remediation Challenge: Is there a case for
Source Depletion? EPA/600/R-03/143. December 2003.
"EPA analyses suggest that DNAPL is present at approximately 60 percent of
Superftmd Sites where organic chemicals have been detected. However, the
presence of DNAPLs is rarely observed directly, and must be inferred by
comparing the maximum levels detected in soil or groundwater samples to the
effective solubility in water or the residual saturation in soil of the DNAPL
chemical of concern. It is probable, however that DNAPLs are present at many
sites where DNAPL constituents have been detected even with maximum
concentrations in samples taken from groundwater monitoring wells well below
one percent of the effective aqueous solubility."
Second reference. Interstate Technology and Regulatory Council (ITRC). DNAPL
Source Reduction: Facing the challenge. April 2002.
"Thus, investigators usually do not find free-phase DNAPL in soil cores or
accumulating in monitoring wells using conventional characterization methods.
Based on this lack of observable DNAPL, is tempting to conclude that no DNAPL
is present when in fact it may be present in substantial quantities at residual
saturation."
EPA and its contractor, Metcalf & Eddy (M&E), are not aware of any field investigation
of DNAPL using visual methods (e.g., Sudan IV red dye, jar shake test, fluorescence)
having ever been performed at the Site. Section 6.5 of the RI report does identify direct
observation of DNAPL as a data limitation and recommends future DNAPL
investigation, however, it is noted that even if visual methods are applied, chances of
observing DNAPL are still low.
Regardless, there is a substantial amount of data that supports the presence of DNAPL at
DMC. The historic overburden groundwater concentrations at DMC are well above the
1% aqueous phase solubility, and the persistence of contamination in both overburden
and bedrock groundwater is highly indicative of the presence of DNAPL. [See EPA
Remedial Investigation Report, June 2005, Section 4.2.2.5, and EPA Technical
Impracticability Evaluation Report, June 2005, Section 3.3.1.2.]
DMC Comment 3: GZA comments that EPA's "Technical Impracticability Evaluation
Report (TI Report) ... states that 'No samples from any water supply or bedrock
monitoring wells anywhere on the Site have been found to have concentrations of
solvents exceeding or even approaching one percent of the effective solubility.* (The one
percent of effective solubility is one of the criteria for evaluating the potential for
DNAPLs to be present.)"
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Durham, Connecticut
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Date: September 30,2005
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Response to PMC Comment 3: The Remedial Investigation Report (RI) does state that
concentrations well above 1% solubility concentrations are indeed present in the
overburden at the DMC property.
GZA has taken statements from the RI Report (incorrectly identified as being from the
Technical Impracticability Evaluation Report) out of context regarding the fact that no
groundwater samples from bedrock monitoring or supply wells contained concentrations
above the 1% solubility level. The RI statement simply acknowledges that the bedrock
groundwater concentrations are below the 1% solubility criterion, However, the deep
open hole intervals and complex fracture network, significant borehole dilution, as well
as other factors related to DNAPL migration in fractured bedrock, will likely preclude the
detection of concentrations close to 1% solubility. For this reason, the 1% criterion has
limited applicability to existing bedrock wells.
The RI does present evidence supporting the presence of DNAPL in both the overburden
and bedrock, such as: concentrations well above 1% solubility concentrations in the
overburden at DMC, the bedrock plume attachment to the spill/release (source) areas, and
the persistence of contamination for several years in both overburden and bedrock
groundwater. [See EPA Remedial Investigation Report, June 2005, Section 4.2.2.5, and
EPA Technical Impracticability Evaluation Report, June 2005, Section 3.3.1.2.]
DMC Comment 4: GZA comments, "While theoretically there may have been, at one
time, some extremely limited areas (proximate to Monitor Well MW-2 and the original
MW-6) in the overburden on the DMC property where DNAPLs may have existed, both
of these areas have been subject to remediation (the former in the form of an aggressive
and very successful multi-phase extraction system, and the latter by soil removal through
trenching and gravity drainage of overburden groundwater into a drain system installed
for this purpose). Available evidence suggests that it is doubtful that any but very small
and discrete globules of DNAPL exist any where on the DMC property and certainly
nothing resembling the extent depicted on the maps presented by the USEPA,"
Response to DMC Comment 4: EPA's contractor M&E used an approach based on lines
of evidence to evaluate the possible extent of DNAPL and considered other Site factors
that may have exacerbated the DNAPL problem at the Site. In general, due to significant
historic pumping from deep open-hole supply wells in the area, the fractured nature of the
aquifers, and the possibility of sources at DMC, Strong School and 174 and 168 Main
Street, it is conceivable that DNAPL could have migrated to the areas depicted within the
zone of Conceptual Maximum Extent of DNAPL. [See EPA Remedial Investigation
Report, June 2005, Sections 4.2.2.5, 4.3.2.3, and 6.4.2.2. See EPA Technical
Impracticability Evaluation Report, June 2005, Sections 3.3.1.2, 3.3.1.3, and 3.6.]
GZA states that areas on the DMC property where DNAPLs may have been located were
subject to successful remediation. In several letters and messages to DMC in February
2005, EPA repeatedly requested information regarding the on-site remediation systems
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Durham, Connecticut
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Date: September 30, 2005
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that DMC claims to have implemented. Information regarding the perforaiance of the
multi-phase extraction system and the trench drain was never provided to EPA, Without
confirmation of the performance of these systems, the Remedial Investigation and
Feasibility Study Reports (RI/FS) were completed assuming that the systems could be
successful as containment measures at best, but because of the complex hydrogeology
(very tight, fractured till formation and fractured bedrock) and the passive nature of these
remediation systems, significant source depletion would be unlikely,
GZA further states that "available evidence suggests that it is doubtful that any but very
discrete globules of DNAPL exist any where on the DMC property," This evidence has
not been presented to EPA. Data evaluated in the RI suggests that DNAPL could be
more widespread than "discrete globules." Given the Site history and the recalcitrant
nature of the chlorinated solvents released at the Site and the inherent limitations of the
remediation technologies that may have been applied at DMC, in EPA's judgment, it is
not likely that any of the current remediation systems cited by DMC would be successful
in reducing DNAPL at the volume suspected to have been released to a few discrete
globules in the timeframe that they have been operating, based on reports from DMC.
DMC Comment 5: GZA commented that if public water is provided to the Site-wide
Groundwater Study Area, there is much less of a risk driver to compel remediation at the
DMC property. GZA also states that the TI Report [EPA's Technical Impracticability
Evaluation Report, dated June 2005] suggests that source area remediation will not
significantly enhance the overall site remediation and that there are no technologies
currently available to effectively remediate a DNAPL source zone in complex
hydrogeologic environments in a reasonable time frame and at reasonable cost.
Response to DMC Comment 5: Even if public water is provided to the Site-wide
Groundwater Study Area, the excavation at the DMC Study Area will provide important
risk reduction benefits. The overburden groundwater presents a potential threat to a
future construction worker. The soil excavation will mitigate this potential risk by
reducing the levels of contamination in overburden groundwater. Compared to other
alternatives, elimination of hot spot areas through excavation is the alternative that
provides the greatest degree of overall protection of human health that is technically
practicable at this study area. The excavation alternative also provides for a shorter
timeframe for remedial action, which is desired to reduce the potential for human
exposure.
Additionally, removal of the hot spot source zone will mitigate a potential threat to Site-
wide groundwater. EPA acknowledges that sources within fractured bedrock beneath the
overburden sources likely cannot be removed and has chosen to take no remedial action
for the Site-wide Groundwater Study Area (beyond monitoring bedrock groundwater),
with a contingency measure of groundwater extraction for containment purposes should
groundwater contamination migrate. The removal of source zones will minimize the
chances that the contaminated plume will migrate into areas that are not currently
contaminated.
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Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30,2005
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Excavation of the hot spot areas is consistent with EPA guidance recommending that
source areas should be removed to the extent practicable. EPA's Technical
Impracticability Evaluation Report (TI Report) concludes that if it is not practicable to
restore groundwater to drinking water standards in a reasonable amount of time with
existing technologies, a waiver of federal and state applicable or relevant and appropriate
requirements (ARARs) that would normally require cleanup of groundwater to meet
drinking water standards is warranted. A Technical Impracticability waiver, however,
does not preclude the need for source zone depletion. Consistent with EPA's Guidance
for Evaluating the Technical Impracticability of Groundwater Restoration, September,
1993, EPA expects sources of contamination to be removed or controlled to the extent
practicable:
"A demonstration that ground-water restoration is technically impracticable
generally should be accompanied by a demonstration that contaminant sources
have been, or will be, identified and removed or treated to the extent practicable."
"The appropriate level of effort for source removal and remediation must be
evaluated on a site-specific basis, considering the degree of risk reduction and any
other potential benefits that would result from such an action."
The excavation source remedy at the DMC Study Area is consistent with EPA's National
Contingency Plan, which is the regulation governing Superfund cleanups. Where
groundwater ARARs are waived at a Superfund site due to technical impracticability,
EPA's general expectations are to prevent further migration of the contaminated
groundwater plume, prevent exposure to the contaminated groundwater, and evaluate
further risk reduction measures as appropriate (pursuant to the National Contingency
Plan, section 300.430(a)( 1 )(iii)(F)). These expectations should be evaluated along with
the nine remedy selection criteria to determine the most appropriate remedial strategy for
the site; one of the threshold criteria is protection of human health and the environment.
Excavation at the DMC Study Area will also remove any soils exceeding Pollutant
Mobility Criteria (PMC) pursuant to Connecticut Remediation Standard Regulations
(RSRs). These pollutant mobility criteria are designed to protect groundwater from
contaminants leaching through contaminated soil.
Contrary to what GZA suggests, the TI Report does not state that source remediation will
not enhance overall site remediation and that there are no technologies available to
remediate a DNAPL source zone. The technologies discussed in the TI Report are in-situ
technologies that were considered to potentially restore both overburden and bedrock
groundwater to ARARs. The TI Report indicates that the success of these technologies in
restoring aquifers and in source reduction would be limited by the complex hydrogeology
and because the DNAPL may be inaccessible to them. While complete source zone
restoration is not an expected outcome, remedial alternatives addressing source zones in
unsaturated overburden at the MMC Study Area and saturated overburden at the DMC
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Durham, Connecticut
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Study Area were retained primarily because depletion of source zone within these areas
could potentially decrease the mass flux of contaminants to overburden and bedrock
groundwater. Excavation at the DMC Study Area would remove all soils and pooled
and/or residual DNAPL residing within the soil, and therefore potentially result in
significant source depletion.
DMC Comment 6: GZA states that excavation of large portions of the overburden
materials on the DMC property would be ineffective, excessively costly in light of overall
benefits to Site restoration, disruptive to ongoing business operations, and potentially
damaging to the overall site in that actions could mobilize currently isolated
contamination.
Response to DMC Comment 6: EPA's contractor M&E estimates that actual excavation
would likely require 30 days of onsite work based on the proposed area of excavation
(two times the estimated hot spot areas, approximately 5,000 cubic yards). This
assumption includes a period of 10 days to set up and prepare for the excavation (such as
erosion controls, excavation support, and utility locating); a period of 10 days to excavate
the soils (assuming 500 cubic yards per day); and 10 days for backfill and restoration
activities such as paving and reseeding vegetated areas. Disruptions could be minimized
by maintaining access at all times to the parking and delivery areas and by carefully
scheduling utility shut downs if needed. Traffic re-routing may be necessary during this
period. EPA is committed to working very closely with the Durham Manufacturing
Company to ensure as minimal disruption as possible to its ongoing business.
Although the costs of excavation are partly based on volume of material to be handled
and utility/excavation support needs, a major cost is the anticipated disposal fee assuming
the soil requires disposal as a RCRA waste (Resource Conservation and Recovery Act).
If treatment of the soils can be demonstrated, and additional analytical data obtained, it
may be possible to dispose of the soils for lower fees. Additional sampling of the soil
will demonstrate exactly what volume of soil requires excavation. The cost of this
excavation is reasonable given its risk reduction benefits as described in EPA's response
to DMC Comment 5.
The excavation remedy will be designed with precautions to prevent mobilization of
contaminants. Examples of such precautions include excavation in discrete lifts and
continual visual observation and air monitoring during excavation so that if DNAPL is
encountered, it can be removed prior to proceeding with deeper excavation. These
precautions have been applied successfully at other sites to prevent mobilization of
DNAPLs and other contaminants during excavation.
DMC Comment 7: GZA states that the DMC property should not be included in the
Record of Decision and that a supplemental Record of Decision should be developed for
the DMC site. GZA recommends that any decision consist of a flexible remedy and time
frame which refers to ARARs that consist primarily of Connecticut's Remediation
Standard Regulations. Any risk to a future construction worker can be readily mitigated
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Durham, Connecticut
Version: FINAL
Date; September 30, 2005
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through the imposition of a site-wide soil management and health and safety plan. Any
perceived risk of inhalation exposure to future residents on site can be mitigated through
institutional controls that provide for installation of vapor controls under any new
residential structures built on DMC property or an Environmental Land Use Restriction
prohibiting residential development.
Response to DMC Comment 7: As previously stated, in the Response to DMC
Comment 5, as part of the excavation remedy, and as required by EPA's Technical
Impracticability Guidance, excavation will remove source areas to the maximum extent
practicable. The soil contamination at the DMC Study Area exceeds the Pollutant
Mobility Criteria (PMC) established by the Connecticut Remediation Standard
Regulations (RSRs). EPA's action will address these exceedances. It is also anticipated
that an Environmental Land Use Restriction (ELUR) pursuant to Connecticut RSRs will
be implemented to address potential future risk to both a construction worker and future
residents. EPA believes that excavation of the source zones provides a significant risk
reduction measure to mitigate potential human exposure and to eliminate a threat to Site-
wide groundwater that should be implemented in addition to the ELUR. Given the
information developed in the R1 and the FS, there is no reason to develop a supplemental
Record of Decision for the DMC Study Area.
DMC Comment 8: GZA states that there has been no spread of the groundwater plume
and therefore no justification to increasing the number of affected potable supply wells
from 35 to 85.
Response to DMC Comment 8: Some degree of dissolved plume containment within the
Site-Wide Groundwater Study Area is likely achieved by the residential wells currently in
use. Initially, pumping of these wells likely caused migration of the plumes from source
areas causing them to be as widespread as currently shown in the RI. However,
continued operation of the residential wells likely limits further spread of the plume
beyond the wells. If some of the water supply wells closer to the MMC and DMC are
shut off, while other more distant supply wells remain pumping, further spread of the
plume could result. Thus, it is reasonable to extend the public water supply to wells that
could potentially cause future spread of the plume.
In addition, while all of the private wells with groundwater contamination at or
approaching drinking water standards (38 wells total) are currently being filtered and
monitored under state order, a number of wells without filters have groundwater with
trace amounts or low concentrations of contaminants that do not exceed drinking water
standards. It is prudent to include these private wells.
Finally, protection of human health is of primary importance, and thus it is critical to
ensure that all wells that could potentially be impacted by Site contaminants are included
in the alternative water supply. While the groundwater plume location has generally been
very stable, it is reasonable to include a buffer zone of residences located near the
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Durham, Connecticut
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contaminated area to ensure that all drinking water wells that are currently or conceivably
could be impacted by contamination emanating from the Site are included.
PMC Comment 9: GZA states that the assumptions for the Point of Use treatment
alternative (carbon filtration and monitoring) are flawed. There is no justification for
increasing the number of affected potable supply wells from 35 to 85. With the possible
exception of a few wells which contain unusually high concentrations of VOCs, the
frequency of carbon changes in the existing filtration systems is no greater than annually.
There is no basis for expecting that carbon systems will require five changes per year.
There is no justification for including metals treatment on an estimated ten wells in the
southern portion of the Site. There is no evidence to suggest that there are metals
associated with the Site-wide groundwater plume, and the majority of metals detected in
potable supply wells are most likely attributable to plumbing in the systems.
Response to PMC Comment 9: The number of wells included in the Point of Use water
supply is based primarily on the need to ensure protection of human health. It is critical
to ensure that all wells that could potentially be impacted by Site contaminants are
included in the alternative water supply. As previously stated, while the groundwater
plume location has generally been very stable, it is reasonable to include a buffer zone of
residences located near the contaminated area to ensure that all drinking water wells that
are currently or conceivably could be impacted by contamination emanating from the Site
are included. In addition, while all of the private wells with groundwater contamination
at or approaching drinking water standards (38 wells total) are currently being filtered
and monitored under state order, a number of wells without filters have groundwater with
trace amounts or low concentrations of contaminants that do not exceed drinking water
standards. It is prudent to include these private wells. The scope of the Point of Use
water supply alternative matches the service area proposed for the other alternate water
supply alternatives. This includes properties located on both sides of Maple Avenue.
Estimated carbon change frequency is based on conservative estimates of system
performance in relation to a range of anticipated contaminant concentrations. This
includes quarterly changes for the primary filter(s) in each system and annual changes in
the back-up filters. Actual filter media change frequency will be a function of the
characteristics of the influent contaminants. There are several wells in the area that
contain breakdown products, most notably vinyl chloride in the southern half of the site,
which cannot be as readily removed by carbon filters. As primary contaminants continue
to degrade over time, it is prudent to assume that more frequent filter changeouts will be
required for these breakdown products.
Metals, in exceedance of regulatory requirements have been detected in bedrock
groundwater within the Site. Comprehensive sampling for metals has not been
performed, but based on the available data, an estimate of the number of required
treatment systems for metals has been included. Based on the extent of available metals
data, it would be difficult to identify the source of metals contamination. However, it is
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Durham, Connecticut
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clear that metals treatment would be necessary at some locations, and that some of the
metals are not likely due to household plumbing (e.g., arsenic).
PMC Comment 10: GZA notes that a study commissioned by the Town of Durham to
investigate the feasibility of connecting the Durham Meadows Superfund Site to the
[City] of Middletown water system concluded that the cost to maintain the carbon
filtration systems for 50 years would be approximately $3,580,000. The discovery of
1,4-dioxane in a limited number of potable supply wells cannot account for the difference
between this estimate and the EPA estimate of $7.2 million.
Response to PMC Comment 10: The study commissioned by the Town of Durham that
GZA references is a report authored by Fuss & O'Neill, dated December 2000, included
as Appendix I of an Aquasource Feasibility Study also dated December 2000. (This
December 2000 Fuss & O'Neill report should not be confused with the May 2000 Fuss &
O'Neill report referenced earlier; although the reports are similar, the cost estimates
presented in each are not identical.) The Pecember 2000 Fuss & O'Neill report does
present a present worth cost for carbon Filtration systems of $3.58 million. This included
only operation and maintenance costs for a total of 48 point of use treatment systems.
Capital costs were not included in the cost analysis. The present worth cost was
calculated applying a 25% contingency factor and using a 50 year time period with a 6%
discount rate.
The FS included a present worth cost for AWS-4 Point of Use Treatment of
approximately $7.2 million, including approximately $330,000 in capital costs. The cost
analysis included point of use treatment installation, and operation and maintenance for
85 locations. In accordance with the U.S. Army Corps of Engineers/U.S. Environmental
Protection Agency manual, A Guide to Developing and Documenting Cost Estimates
During the Feasibility Study (EPA 540-R-00-002), dated July 2000, the following
contingencies and program cost components were included in the operation and
maintenance costs:
• Cost Contingency: 30%
• Technical Support: 15%
• Project Management: 5%
The AWS-4 Point of Use Treatment cost analysis was also calculated using a 50 year
time period and included a 7% discount rate. Although the presentation of operation and
maintenance cost elements does not exactly match between the two evaluations, the
difference in present worth costs between Alternative AWS-4 and the Fuss & O'Neill
report is due to the number of wells (85 vs. 48), the capital cost element included in the
FS that is not included in the 2000 Durham Study, and the difference in operation and
maintenance contingency and program costs.
PMC Comment 11: GZA notes that a study commissioned by the Town of Durham to
investigate the feasibility of connecting the Purham Meadows Superfund Site to the
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Durham, Connecticut
Version; FINAL
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[City] of Middletown water system concluded that the cost to connect the Superfund Site
to the City of Middletown's water system (8-inch mains without fire protection) would
be, in 2000, approximately $3,440,000, compared with EPA's estimate of $7.0 million.
Response to PMC Comment 11: The study referenced by GZA is the December 2000
report authored by Fuss & O'Neill as described in the previous response, (Again, this
December 2000 Fuss & O'Neill report should not be confused with the May 2000 Fuss &
O'Neill report referenced earlier; although the reports are similar, the cost estimates
presented in each are not identical.) The December 2000 Fuss & O'Neill report
referenced by GZA includes a capital cost of approximately $3,44 million to construct an
eight-inch waterlinc, not including fire protection, to provide service to the Site.
EPA's Feasibility Study provides a variety of cost breakouts for Alternative AWS-2,
Connection to Middletown Water Distribution System, with respect to fire protection.
The EPA estimate of $7.0 million referenced by GZA is for a six-inch main without fire
protection; this estimate includes a capital cost of $4.55 million, and then adds additional
costs for operation and maintenance and other periodic costs incurred over 50 years. The
EPA cost estimate to provide an eight-inch main with fire protection (including hydrants)
includes a capital cost of $4.78 million, plus additional costs for operation and
maintenance and other periodic costs incurred over 50 years.
A major difference in the capital cost estimates provided in the December 2000 Fuss &
O'Neill and in EPA's Feasibility Study related to the contingency, engineering, project
management and construction management factors applied to the base costs. As
mentioned previously, in accordance with the U.S. Army Corps of EngineersAJ.S.
Environmental Protection Agency manual, A Guide to Developing and Documenting
Cost Estimates During the Feasibility Study (EPA 540-R-00-002), dated July 2000, the
following contingencies and program cost components were included in the operation
and maintenance costs:
• Cost Contingency: 30%
• Technical Support: 15%
• Project Management: 5%
Fuss & O'Neill applied similar factors, but in total, the contingency and program cost
components were a smaller percentage than that used by EPA. Eliminating these cost
factors from both the December 2000 Fuss & O'Neill estimate and the estimate in EPA's
Feasibility Study results in base capital cost estimates that are much more similar ($2,548
million for the Fuss & O'Neill evaluation, and $2,909 million for EPA's six-inch
waterline alternative). In addition, the accuracy of cost estimates within a Feasibility
Study is expected to be between -30 and +50 percent [USACE/USEPA, 2000]. The
difference between the base cost estimates ($2,548 million and $2,909 million, not
including cost factors), as well as the total capital cost estimates ($3.44 million and $4.55
million, including all cost factors), is within this range.
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Durham, Connecticut
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ATTACHMENT A: Transcript of Public Hearing (July 28, 2005)
ATTACHMENT B: Written Comments Received During Public Comment Period
(July 13,2005 to August 12, 2005)
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Durham, Connecticut
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Attachment A
Transcript of Public Hearing (July 28, 2005)
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
BOSTON REGION
In the Matter of:
PUBLIC HEARING;
RE; DURHAM MEADOWS SUPERFUND SITE
Durham Public Library
7 Maple Avenue
Durham, Connecticut
Thursday
. July 28, 2005
The above entitled matter came on for hearing,
pursuant to Notice at 8:00 p.m.
BEFORE:
MARY JANE O'DONNELL, Section Chief
ANNI LOUGHLIN, Project Manager
JAMES MURPHY, Community Involvement Coordinator
EPA, Region 1
1 Congress St., Suite 1100
Boston, MA 02114-2023
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PANEL: PAGE
Mary Jane O'Donnell, Section Chief 3
Anni Loughlin, USEPA, Project Manager
Jim Murphy, USEPA, Community Involvement Coordinator
SPEAKERS:
Maryann Boord, First Selectwoman, Town of Durham 4
Allison Dodge, on behalf of Congresswoman Rosa DeLauro 5
Renee J. Primus, Selectwoman, Town of Durham 7
Raymond Kalinowski, State Representative 8
Richard Pramelee, resident of Durham 11
Donia Viola, resident of Durham 16
Richard Grecco, Chairman of Chamber of Commerce 18
Renee Hofer, resident of Durham 19
Bill O'Neal, resident of Durham 22
Hugh Curley, resident of Durham 23
Lee Sawyer, resident of Durham 25
Richard Kellish, resident of Durham 26
Jim McLaughlin, resident of Durham 30
Dan Kellish, resident of Durham 31
Richard Hanley, member of Durham Economic Development
Commission 34
Dian O'Neal, resident of Durham 36
Karen Kean, resident of Durham 36
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{7:00 p.m.)
MS. 0'DONNELL: My name is Mary Jane 0'Donnell.
As Anni mentioned, I'm a Section Chief with the
Environmental Protection Agency in Boston and I will be the
Hearing Officer for this part of the meeting.
Just a couple of introductory points, Anni's
elaborated on how to comment, when to comment, add just a
little bit on why to comment from my prospective.
I work on, beside sites in Connecticut, I also
work on sites in Maine and Vermont, and I can't tell you how
many sites get revisions or whatever with modifications we
have made in terms of revenues and how we approach a site,
based on public comment. So it's very important for us to
get a diversity of prospectives. So if there is some
hesitancy on your part in coming forward, I would strongly
encourage you to come forward and make a comment.
Just as Anni mentioned, in terms of some ground
rules, so to speak, I'd ask you to come forward, come to the
podium, state your name, your association with the site.
And as Anni mentioned, also, because this is a formal public
hearing, we won't be responding to your comments and
questions, but we certainly will be here after the formal
hearing to try to do that.
So with that as background, I'm going to start on
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this side of the room, front to back, and then front to back
on this side.
So is there anyone working on this side that would
like to come forward and make a comment? Again, state your
name, association with the site and your comment.
MS. BOORD: I'm Maryann Boord, the First
Selectwoman of the Town of Durham.
The Board of Selectmen of the Town of Durham
compliments the Environmental Protection Agency on its
comprehensive proposed cleanup plan for the Durham Meadows
Superfund Site. Excavation and off-site disposal of soil at
and adjacent to the responsible parties is essential to
effective cleanup, as well as to putting the residents'
minds at ease once cleanup has been completed. Maximum
attention should be given to minimizing the impact of
cleanup activities on neighboring properties and residences.
Also essential is future monitoring for possible plume
migration.
While institutional controls should be implemented
to protect current and future occupants, we request that you
do not place excessive limitations on future use of the
properties. Please keep in mind our rural character and our
Main Street Historic District.
When you enter into negotiations with the
responsible parties in a spirit of fair mindedness, we
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request that you seriously consider the financial
contributions already made by the Durham Manufacturing
Company. The board supports future connection to the
Middletown Water Distribution System or another alternate
source of public water. Please note that the Town of Durham
has maintained open dialogue with Guy Russo, Director of
Water & Sewer, for the City of Middletown, since that
possibility was first considered many years ago.
The seriousness of the contamination and the,
quote, inconvenience experienced by the residents in the
affected areas these many years cannot be minimized;
however, it appears there is hope on the horizon.
We thank you for your attention to our concerns
for the future of our town and its water supply.
Sincerely, Maryann P. Board, First Selectwoman;
Ernie A. Judson, Selectman; Renee J. Primus, Selectwoman.
MS. 0'DONNELL: Thank you.
Next row, comments. Thank you.
MS. DODGE; My name is Allison Dodge. I'm here on
behalf of Congresswoman Rosa Delauro, who is in Washington
this evening, but asked me to read the statement for this
evening's hearing.
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before the EPA and the Durham community, as you review the
proposed remediation plan for the Durham Meadows Superfund
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Site.
As we are all aware, their remediation plan for
the site has been a long time coming. It is my hope that
the EPA will work diligently to finalize a record of
decision in a timely manner which fully addresses the needs
of the properties and businesses which have been impacted by
the contamination,* and most importantly, protects the health
and safety of the residents of Durham.
There are a number of steps which need to be taken
in order to address soil and groundwater contamination of
the Durham Meadows site. This has already been a lengthy
process, and while I understand that there are statutory
guidelines which must be adhered to, it is my hope that the
EPA will issue a final record of decision as soon as it is
feasibly possible within the limits of the law. Once a
final record of decision has been issued, I would hope that
the EPA will move quickly to alleviate the strain the
superfund designation has put both on business and
residential home owners in the area.
Upon review of the proposed cleanup plan, I
believe that the direction in which the EPA is proceeding
will effectively address necessary human health and
environmental protections. It is my understanding that the
EPA will be balancing these protections with future land use
restrictions for the properties. Although it is expected
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that the Durham Manufacturing Company will continue to use
the property for its current purposes, I believe that it is
important for these restrictions -- that these restrictions
do not indefinitely prohibit the redevelopment of the
Merriam Manufacturing property.
Though I have not been contacted with any
concerns regarding this proposed remediation plan, I urge
the EPA to listen closely to any concerns which may be
raised by local officials, residents, and most importantly,
those individuals who are directly impacted by the selected
remedy. I know that the affected residents have had to
endure many years of hardship. Their unique prospective on
this case must be given full consideration. These are the
individuals who know this area and understand the needs of
the town, its families and businesses.
I appreciate your time and attention to my
comments. I look forward to the expeditious resolution of
this matter.
MS. O'DONNELL: Thank you.
Next row.
Excuse me. Anyone else? Okay. I'd like to go
front to back, if that's possible
MS. PRIMUS: I'm Renee Primus, a member of the
Durham Board of Selectmen, and I also would like to give my
support to the EPA for their proposed cleanup plan.
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I compliment you on the use of data-driven
conclusions to generate the proposed plan, and there are
special considerations that I'd like to be given in the
following four areas.
The first is that due to the extent of the
contamination and the identified constraints, I believe that
connecting to the Middletown public water system should be
the highest priority of this plan.
I also believe that institutional controls over
affected areas should be implemented appropriately for the
protection of current and future occupants and neighbors.
And I request that maximum attention be given to
minimizing the impact of the cleanup activities on
neighboring properties and residents.
And, last, I'd like to request that the
negotiations be fair minded, with special consideration to
Durham Manufacturing Company, who has been actively
servicing the properties of contaminated wells and is
currently the only company servicing these contaminated
wells.
Thank you.
MS. O'DONNELL: Thank you.
Would you like to leave that with the -- thanks.
MR. KALINOWSKI: My name is Raymond Kalinowski. I
am currently the State Representative serving the Town of
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Durham, I'm also a former First Selectman for the Town of
Durham from 1997 to 2001. I am a 32-year resident of the
town and I'm pretty keenly aware of the problem as it
currently exists and I've had many dealings with EPA when I
was First Selectman, and I recently was in contact with your
Boston office regarding my written comments and my
recommendations as to how we should proceed here in the
future.
Early in my first term, I believe it was 1998, I
made some contacts with public officials from the City of
Middletown, which were very productive. I think the
political operatives in Middletown were very receptive and I
think the solution lies in bringing water from Middletown to
Durham.
As was mentioned on the slides by Anni, they do
have a sufficient capacity in Laurel Brook Reservoir for
that particular water to come from. And I think with the
proper funding in place, this would be the solution to the
problem.
When Merriam Manufacturing burned down in 1998, we
also found a need at that time for a possible fire flow
capacity and the ability to fight fires in the area on Main
Street, because that was a huge fire and we had to truck,
shuttle water in from various locations nearby, and it was a
very difficult time.
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So with a proper water main constructed, coming
Middletown to Durham, I think not only will it solve the
water contamination problem, but have the ability to have
fire flow capacity, also.
I would like to mention and I did mention this in
my correspondence recently to EPA that the potential
responsible parties -- namely, Middletown and Durham
Manufacturing -- have different capacities of cooperation
over the years. And Durham Manufacturing also deserves
special mention because they always have been very
cooperative, and I think that should be taken into account
when the actual negotiations take place, and they should be
viewed in that particular light.
I know there were consultations made in EPA in
Washington, I believe last week, I don't know the results of
that, but I think the ongoing process, and when this
particular decision is finally reached, I think they can
probably come to a fair and reasonable method of determining
responsibility and what funding mechanism will be put in
place to solve it.
As a State Representative, I will do my part in
Hartford to get the parties together for further discussions
on funding for this particular main, if indeed it does come
to pass.
And so, again, I want to thank EPA for the
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presentation made tonight, and I'm also always available,
along with our First Selectwoman and the next administration
for further consultation.
Thank you.
MS. O'DONNELL; Thank you.
Comments on this side of the room. I'll change
the sequence here. Okay, front to back, I guess, I won't
change my sequence.
MR. PRAMELEE: My name is Richard Pramelee. I'm a
resident of Durham, relatively new resident, I guess.
I wasn't aware of this meeting until I got home
and saw it in the paper tonight at 6:30. And I have some
very serious concerns about the source of water, and
probably the biggest thing I learned here tonight was
there's no source of funding, and X consider that a very
significant component. Very significant.
It's hard to make a decision on which way we're
going to go if we don't know where the money is coming from.
I'm not interested in running anyone out of business. We
have a very responsible member of the community, the Durham
Company has been here a long time, they've acted in a very
responsible manner.
Prior to this situation with the water, I know
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payroll, the staff at the factory was diminished during the
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day, when they went out on these calls, and the Durham
Company allowed this to go on. And they've done many other
things probably that I don't even know about.
Apparently the other party has decided the remedy
to their obligation would be to give us the property. I was
overwhelmed with the gift. I don't need gifts like that.
I have some concerns about public health outside
of what you apparently mentioned here tonight, and when
Mr. Kellish, Dan and his brother both spoke, they're one of
the few residences that I know of on Main Street that
updated their septic systems. There's been very few others,
to my knowledge. By observation, I know that theirs was
done. And I think that this, before we start, we should
address that issue, also, even if we have to do it as a
community.
You mentioned shallow depths. You showed a
cross-section, but you mentioned no depths, so I guess
you're going to have to go back and look at the CD.
The town has bought properties over the years and
the White Farm down here, when we purchased that property,
we had federal money to buy that property with, and the
stipulation was -- and I went over this with the selectmen
when they were looking for sources of water.
The principal source of that money from the
federal government was for future use of water. That's
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principally how we got the money. We wanted to buy the
land. Okay? And we did. And there's restrictions on what
we could do with it, even though we let farmers use the
land, including the farmers that owned it prior. They had
limitations on it. And when they were thinking about do
something about water here, they seemed to make a big deal
out of the fact that the local agency, the Conservation
Commission, was going to let them do something over there.
Well, I don't think they really had any choice.
That's ours. The federal government gave us money and that
was a big pretense of what that money was to be used for.
The wells down there belong to the Town of Durham.
That's on town property. You can call them Durham federal
wells, you can call them anything you want. We own that
property. I was there when that system was put in.
Physically present.
I can tell you where the main ends up here by the
house where the State Police Resident Trooper has his
office. That's how close it comes. When I mentioned it to
them, when you were looking for a source for water, they
pooh-poohed me. Know what I mean? Or now I guess we're
going to go there.
But as far as I can see, I don't want to be
particularly intrusive and I don't like to see -- I'm in the
construction business. I do it every day, on somewhat large
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scale, probably, to a certain degree. I don't want to see
everything all dug off. I don't know what you're proposing.
You're talking about cleaning up the soils on all these
properties and I don't know how intrusive it is going to be
to the property owners that are actively engaged in
business. And, you know, if it's not going to completely
cure the problem, and maybe the point of use is the real
decision.
And, I don't -- Dan, I don't consider your
comments sarcastic at all. I think if you've been waiting
for 35 years, you deserve some answers.
And funding is very important. I personally am
not too excited about getting tied-up with Middletown. We
already have an agreement with the Connecticut Water Company
and I'd like to see a proposal come forth from those people.
It's a private sector company, they're very effective,
they're very knowledgeable, they're very efficient.
Municipalities are not. I've seen municipalities operate
and they're not efficient, they're not very profitable,
because they have deep pockets and just pass the taxes onto
us.
And like I said, I don't want to see these
companies run out of business. I know one party will act in
a responsible manner. I can't address what the other party
may do. But I would like to see the on-site disposal
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systems in the area are looked into, so that we're not just
bringing clean water in while we still have some problems
earlier.
And I think we ought to be fair to the businesses
at hand you're addressing as responsible parties, because
it's -- I believe it was at the time they weren't
particularly out of compliance with anything at that time.
So we can't make them, you know, liable in that sense. I
believe they probably were living within the framework of
what guidelines there were, if there were any. And there
were probably none. Well, it was none when Durham
Manufacturing started. And none when Merriam started,
because they go back even farther. So they're not
necessarily out of compliance when some of this was coming
on.
You know, times change and all of sudden you're
out of compliance, and I think we've got to be fair in the
way we address things and not, if we want to point fingers
and point blame, we ought to be able to say that at the time
that this was going on, either they were or they were not in
compliance. And I don't believe personally that they were
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So I think we should, be fair with any comments of
a negative nature that might come up, to the businesses,
both of them.
But I'm very concerned about the money and I want
to know where it's coming from. I am a taxpayer. I lived
here for a while and I am concerned. And federal money is
still my money. And by the same token, I'm not interested
in running these companies out of business, but I want to
know where the money is coming from. That is important.
Thank you.
MS. O'DONNELL: Anyone else on this side that
would like to make a comment?
Next row.
MS. VIOLA: Good evening. My name is Donia Viola,
and I live here in Durham, not on Main Street, but
nonetheless very much involved and concerned about what is
going on to residents here that, quite frankly, should have
the luxury and affordability of clean water, whether it
comes from a well or an outside source.
Relevant to this discussion, I would just like to
start off and say that since the informational hearing held
on July 15th this year, concern was raised by another woman
resident and myself as to testing being done in the
immediate of Strong School, because of the school's history
as to having a bus depot there until the early Seventies,
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and an instructional program in automotive maintenance and
repair, as well, when it was Durham High School.
I would hope there has been some kind of action
taken to address this, because these might possibly have
contributed to the pollution, also.
It's a negative situation. Moneys paid by Durham
Manufacturing, I think also included a fine of $25,000. And
I am aware that the company has helped with filters for
properties affected, but the bottom line is the majority of
the pollution seems to come from Durham Manufacturing and
Merriam Manufacturing. They are the principal parties that
have been identified, which caused this problem, and perhaps
even Regional School District 13 with Strong School site.
I have talked again with Mrs. Delmyer, whose
residence is on Route 17. Unfortunately, with her kennel
business, I guess she wasn't able to make it tonight,
because she did say she planned to attend if she could.
Well, her property abuts the village shops and her
and her husband, Fred, also own substantial amount of
property across the way from the Time Out Tavern abutting
Route 77, and who were also approached by Aqua Source when
they were in business here. But that, of course, went down
the tubes because we took over our own water company to,
suffice to say, address our serious issues.
I would hope that she be given consideration for
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the possible location of the well, which might serve and be
substantial for the residents in need and those that are in
with the plume effect.
Imagine the cost could be lower with the same
results. Durham currently has, as I said, their own water
company, Connecticut Water Company. And rather than have
another water company, especially if there is another clean
local source for clear and potable groundwater, I would
encourage and support from our own natural resources within
our own town borders.
Thank you for your time.
MS. O'DONNELL: Thank you.
MR. GRECCO: My name is Richard Grecco. I'm the
local Chairman of the Chamber of Commerce in town here, I'm
also a local businessman here,
Basically, I'm here in support for the Chamber to
support Durham Manufacturing. They've been a very good
corporate citizen and they've come forward and done
everything possible to correct the cleanup site, and it will
be a tragedy if we were to impose on them too much and drive
them out of business.
Durham Manufacturing has been severely impacted by
the process. They've spent, people have talked about how
much money, $4 million already into this, and it's cost them
60 jobs to fulfill their requirements already. And with any
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more demands placed by the EPA, they possibly could go out
of business.
Since they are, I believe, the largest taxpayer in
town, that is a major concern to you people as taxpayers,
also. They do want to compete in the business environment,
they do want to go forward and add jobs, but under the
current rules, they do need some help.
Also, the last thing I'd like to say is that they
have done their fair share to help the town with the
situation and I think a little bit more pressure should be
put on Merriam.
Thank you very much.
MS. 0'DONNELL: Thank you.
Next row.
MS. HOFER: Hello. My name is Renee Hofer, I live
at 63 Maiden Lane, which is on the east side of Ball Brook,
close to the Durham Manufacturing area.
I just wanted to stop in tonight and put in a
couple of concerns or comments that I have. Based on my
understanding from the presentation that we attended at the
high school, we have a couple of givens regarding the fact
that we have fractured bedrock and that this DNAPL is a bit
unpredictable as far as how it travels through the bedrock.
Because I'm currently outside of the plumes, but
very closely outside of the plumes, I think it's very
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important that we take into consideration how this remedy is
going to impact the plumes and their location.
I have concerns regarding the impact of digging to
produce this water system and bring it in and what impact
that that is going to have on this DNAPL and the fractured
bedrock.
I have serious concerns about the future
development on the site or the sites surrounding it. Most
particularly, not too far in the recent past, there have
been some discussions regarding developing the property on
the east side of Ball Brook, and I'm concerned as to how
that would impact the bedrock, when you start digging and
start adding traffic and additional pressures, what that
will -- how that will impact that area and the health of the
town, in general.
With regards to the water system going on there,
one of the first questions, again going back to how this
contamination of the plumes may spread, it was mentioned
that if we turn off all the wells, which is what would
happen when we put in this water system, again, how is that
going to impact these plumes and the direction or the flow?
So moving forward from that point, if after you've
gone and installed this new water system, whether it's to
Middletown or to some other source, and that plume then
spreads, how does this contingency plan or whatever work and
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how would that impact the situation that may have to extend
that water system or to take care of those residents who
might then be affected by it?
I also have some concerns regarding how the
agreement with Middletown is going to be reached and how we
are going to pay for it every year. I'm sure that
Middletown is not going to provide us with water without an
annual expense and annual cost that will extend forward from
that time forward. Who pays for that, and do we happily do
it, or is there some sort of remedy included in that?
The other additional point that I would like to
make, I think it's very important to recognize that Durham
Manufacturing has been a responsible citizen. We appreciate
that. But I do think it's important to keep in mind that
they are, in fact, responsible in an extent to it, and I
hope that they will approach these negotiations and
appreciate --or take it in the same responsibility or same
spirit of understanding that these are the costs have been
impacted on us.
I purchased my property in 1997 and I wasn't a
part of causing the problem, so I'm a little concerned about
making sure that other people know that I'm not real happy
about paying to clean it up.
I also agree with Mr. Grecco on the fact that I
think more pressure should be put on Merriam Manufacturing
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or the estate of anyone involved on that, so that they will
also take part in the costs.
And the last point is, is also to take into
consideration, if we choose Middletown as a future water
source, that how the development of that city will impact
the future of the water supply, I mean, if Middletown
continues to expand at its present rate or it continues to
grow from that point, how will that impact the supply of
water in the grand future?
Thank you very much, and I do appreciate having an
opportunity to make the comment.
MS. O'DONNELL: Thank you.
Next row.
MR. O'NEAL; I'm Bill O'Neal, 271 Main Street.
After 35 years, I think it's time to end the what
ifs and maybes and what abouts and all of this baloney.
Clearly, in terms of the groundwater problem,
there is only practical solution and that is to connect with
Middletown. Anything else is just a dodge, a phantom well
here, a Connecticut Water Supply Company there, will do
nothing more than prolong this problem, and after 35 years,
it's really time to get on with it. There's only one
solution.
Thank you.
MS. O'DONNELL; I guess now the next row.
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MR. CURLEY: Hi, good evening. I'm Hugh Curley
from 715 Haddan Quarter Road in Durham.
Previously I lived actually in the house
immediately south of the Merriam Manufacturing site from
1983 to '85, when that was rented by Notre Dame Church as
their meeting house.
Just a couple of things I did want to say before I
raise questions about the concern over the financing, and
I'll get to that in a second. But I am glad to see this is
done at this point.
I've been involved in various points, from my
involvement as Vice-President of the Middletown Chamber for
years, and I am a business development specialist today, and
that's why I'm concerned about the finance side.
The question of the water, I am in favor of trying
to connect the water with Middletown. It does make the most
sense, and it was actually really on the table since '93,
that I remember, at one of the meetings with Hank Robinson,
when he was First Selectman, back in that time. So it is
time to get on with this.
The question of potential impact to the community
that was brought forward in this study, I found to be light
on recognizing the importance of Durham Manufacturing to the
community itself. It makes no mention of one of the impacts
could be an adverse one on that company, the company that
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does provide daytime responders for our fires. It does
provide a lot of things and it is an integral part of our
community, and that's really riot recognized in here.
I'd like to see that somehow addressed, if there
are any revisions to this. But I would like to see that
somehow that is connected.
On that side of their impact, I guess one of the
things that has impressed me more than -- and I think I had
asked this questions at one of the superfund meetings or one
of those meetings we've had with EPA over the years, is to
how many sites have there been where a party stepped up to
the table and had three or four different additions on to
their facility while it was identified as a superfund site?
And the answer came back, as far as I know, there
were none; that this company has committed to trying to do
the right things along, and I think that's putting their
money where their mouth was ? that when they had options to
move different places or options to do things, they
recommitted and recommitted and recommitted to not only
fixing the problem that they have, but also to continuing
their expansion of their business within Durham.
So I guess I'd like to see more of that on the
economic and social impact side and when we get to the reuse
assessments, it is saying that it's expected that the
property would be used that way, but that is something that
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is going to be contingent upon how financial negotiations
are worked out. And I do hope that everything that Durham
Manufacturing has put towards this so far will be counted
towards that as part of their responsxbx 1 xty«
So thank you again for this opportunity.
MS. O'DONNELL: Next row.
Yes, sir.
MR. SAWYER: Hi. My name is Lee Sawyer, I reside
at 267 Main Street.
I wanted to express my support for the proposed
80 U.S. 2, which is the connection to the Middletown Public
Water System, but I also wanted to suggest that the EPA
maintain an open dialogue with the community and with town
leaders in order to facilitate a more extensive connection
to the Middletown Water System extending beyond just those
immediate Main Street locations that are affected by the
plume.
In your impracticability waiver request, you state
that it would be essentially impossible to actually clean up
the groundwater to usable levels, which is the mandate of
the superfund that -- the EPA Superfund Mandate.
Basically, the spirit of that mandate to restore
those drinking -- the drinking usable levels could
essentially be followed through upon by connecting those
locations outside of the immediate plume to the water system
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that are --we have properties outside of the plume that are
still affected by pollution that would then have usable
drinking water.
So I would encourage the EPA to be as generous as
possible and look for resources to assist the town in
connecting the residences outside of the plume to that
system, as well, because that will probably be something
that will need to be done down the road, anyway. And in
doing so, make sure that we can maintain an open dialogue
between the EPA, the community and the town leaders, because
really, according to the mandate, the EPA is really only
responsible for the super -- what's going on within the
borders of the superfund site.
And there's a lot of us here who are asking for
public water or to be connected to Middletown's Public Water
System. That doesn't necessarily have a lot of relevance to
the mandate of the EPA and the superfund site, but it can
and it should. And I hope that we can continue to have a
nrintrDrcj^h i nn ah/Mit* noftAf* *1 aTfinnffdl" f-hp fliTPP
vUilVvX bCtwJLUll CliJU U. U diiU ClUlwilM O L- uilv vv
parties, the community members, the community leaders and
the EPA, including probably the Connecticut EPA to come up
with a plan and some funding to make this happen.
Thank you.
MS. O'DONNELL: Yes, sir.
MR. KELLISH: I would have spoke earlier if I knew
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it didn't mean anything, so I'm just going to just touch
base a little bit here.
My name is Richard Kellish. And, again, I am one
that's for us going into Middletown and bringing the water
down from Middletown.
So like I said before, if there's some young kids
are drinking this water right now and taking a shower or
anything, you know what happens to kids in a bathtub and a
shower, could be drinking the water. And if it's got dioxin
in it, there's no way you're going to get it out with the
charcoal filters.
My house is on 227-227A Main Street, it's a rental
property. I would like a few questions answered. I know
you're not going to answer them tonight, but I would like to
know who paid for Plymouth, Connecticut. Took them six
years, they had trichloroethylene, I think somebody went
bankrupt, and I heard that the state paid for it.
There's another one going on right now, another
town. I don't if it's Harwinton or where it is, I
understand the state is paying for it. There's no reason
why the state or the environmental protection cannot pay for
Durham.
If anybody could be mad at Durham Manufacturing,
it could be me. The state told Durham Manufacturing to
drill high-yield wells, to try to get trichloroethylene out
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of the wells. They pumped my well dry, they pumped Pigner's
well dry, and it's cost me now $11,000 out of my pocket,
because I had to go another 200 feet in my well, so I'm down
400 feet now, had to put new pumps in, I had to put an
ultraviolet light in. So right now it's close to $11,000
out of my pocket. There's no reimbursement for that.
But I think it's time that we laid off these
businesses. They're a manufacturer, employs a lot of
people, brings a lot of money, pays a lot of taxes. They
pay $4 million now,
I think it's time that --we have taxpayers here.
There's -- Jim McLaughlin just brought up something.
There's something like $26 million a year going into the
federal government from this town. It's about time they
used some of that money and brought it to Durham.
I would like to thank the EPA, but now I think
it's time, we've talked long enough, and it's time that you
people sit down and make a decision. It's a very important
decision. There's a lot of people in this town that could
be drinking this bad water.
Now they talk about the wells down at the
fairgrounds. We have MBTEs coming down Maple Avenue now.
It's in Maple Avenue. Charcoal filters will not take MBTEs
out of the water.
How long is it before they start going down into
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the fairgrounds if we do go into that wells? Has anybody
thought of that? Is there any way MBTEs or dioxin can get
down to the fairgrounds and go into those wells? And if it
can, we're just wasting our money going that way. There's
only one way to go. Yes, it's going to cost us money.
We're going to have to pay for water.
Somebody asked -- I don't know if she's still
here. Of course, you're going to have to pay for water. We
own property over at Lake Beseck, we're paying for sewerage
over there, but we don't have to worry about septic systems
any more. So we're going to have to pay for water.
As far as Merriam Manufacturing goes, I think --
now I don't -- don't quote me, but they -- the state was
supplying water to me on Main Street because the people will
not drink the water now. Okay? Because they got sent the
notice that there's a trace of dioxin in our well.
Well, if you people or you people got a letter
saying there's a trace of dioxin in the well, would you ever
drink that water again? Even though I have my filters and
stuff in there, I am now supplying the water to my tenants.
That's out of my pocket, because the state took over from
Merriam and now they tell me that they will not supply the
water any more, so I am supplying the water.
So I think that Merriam is, now, everything is
being paid for by the state. I'm not positive. But that's
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what they told me, that they are taking care of what Merriam
took care of.
Thank you very much.
MS. 0'DONNELL: Yes, sir.
MR. MCLAUGHLIN: My name is Jim McLaughlin and I
live at 308 Main Street, in the first house north of the
plume. So I do hope that whatever you decide, you decide to
keep on testing houses outside the plume, because if I end
up with the problem that some of my neighbors have, I'm
going to be looking to you for a solution to it.
I would like to add, too, that Durham is kind of a
special town and I don't think you could find a better
corporate citizen then Durham Manufacturing. They didn't
break any laws. The laws were made up after the damage was
done. So I think you have to give them a whole lot of
consideration because they're everything everybody said they
were here. They're our biggest taxpayer, they're one of our
best corporate citizens without question. Many of their
employees leave their work the minute the siren goes off and
they've done that for generations and I suspect they will do
it soon.
I would suggest that you enter into negotiations.
When you go into the negotiations on trying to find the
money to solve this, you remember that what Dick Kelly said
was just a quick calculation. There's 2600 households in
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Durham with an average annual income of $75,000. And even
if they get off with paying $10,000 a year in taxes, you're
talking about $26 million a year. Take that over the last
15 years that this has been a problem, and I think there was
enough money going down to Washington that maybe we could
get some back from the EPA,
So I think when you sit down to negotiate,
negotiate with the man that has the money in EPA and see
what they can kick in to solve this problem.
Thank you very much.
MS. 0'DONNELL; Thank you.
This side, the gentleman in the back.
MR. KELLISH: My name is Dan Kellish and I'm the
other half of the ownership on the house on 227-227A Main
Street.
And I know the EPA well, because I've spent a lot
of time on the phone and a lot of frustration. I wanted to
add one other thing, that the MBTE that's starting to go
down Main Street was supported by environmental agencies in
this country. There was an article recently where Valero,
which is the largest refinery in the United States right
now, they have a gas station up here, but they own over
5,000 stations, and they don't -- they're fit to be tied.
They're one of the wealthiest refineries in the world. They
were told they should use the MBTE because it was more
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efficient.
Well, a few years later they found out it was
contaminating the groundwater. So here we're blaming
industry, Durham Manufacturing, for something they didn't
realize that they were doing wrong. I guess the EPA didn't
know what they were doing, either, or these environmental
groups that supported an additive that makes the fuel burn
better, but when it gets down in the water, you cannot
separate it from the water.
And we have another source of income for this
sewer system, which sits right here where those gas stations
are. You've got the one where the Durham station was,
across the street. They say it's not part of the superfund.
It doesn't have to be.
What I believe in this country, I constantly read
the Wall Street Journal, a lot of Barons investment papers,
and we have a country that's the greatest country on earth,
and the reason it's succeeded is because industry, workers,
the government is supposed to work together, not fight each
other and go on endlessly.
And like I say, we've owned the house for -- or
we've been involved in this for 24 years. And my brother
cited our $11,000 expenditure for drilling the well deeper
when Durham was told by the state that they had to pump
100 gallons a minute. Well, they created a plume, a reverse
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plume, there was no water at all.
So I tend to ramble, but basically X think it's
time that we support the move by Middletown. I live in
Berlin and in Berlin we have a public water supply, and it's
a lot better than worrying every day about whether your well
is going to get polluted. And that's what we got in Durham.
It could get steadily much worse. And this dioxin is a
chemical that can't be stopped with the filters.
And if anybody wants to see the filters we have in
Durham, it's quite an elaborate system. And so -- and I
also think that Merriam, they exist. They're still in
Middletown. They're down in the North End of Middletown,
down there. The state apparently can't find them. Well,
there's a lot of people that I know know exactly where the
company is still operating. So that's a big joke in itself.
So basically I think it's time to promote this
system. Durham has suffered enough. And the future of this
town, what everybody forgets is the economic value of
getting a water supply. You don't have to -- all the
property on Main Street is going to go up and the rest of it
in Durham, because somebody here had mentioned that, how do
you know how far this is going to spread?
MBTE mixes with water and it was discovered in
Alaska in the logging camps that it was no good. A lot of
the rural areas of America banned it before it got out of
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control, but the governmental agencies kept pushing it to
save fuel and polluted. — they say in some areas of the
country one-third of all the water is polluted by MBTE, an
additive to make fuel burn better.
So nobody is really to blame. Our technology is
moving forward and I'd love to see this thing get solved. I
think it's possible.
And like Anni said, that it'd be two years before
a decision was made or before we could get water. That's
unacceptable. Why should it take two years? Let's just get
going with the project. And I'm sure between all the
political people like Ray and the Governor and the right
negotiations, I think we can solve this problem and make
Durham have a good future instead of an uncertain existence.
I thank the EPA for coming and putting up with me
calling them, and I intend to continue to call, but that's
all I have to say. But I think this is a solvable problem
and it's time to do something.
I thank you.
MS. O'DONNELL: Thank you.
I saw a hand raised in the back.
MR. HANLEY: I'm Richard Hanley. I'm on the
Durham Economic Development Commission. I am not speaking
for the Commission tonight, but as a member. I live at
111 Johnson Lane.
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I wanted to make a few comments regarding economic
development in Durham. It's been a difficult process to try
to balance development here, and tonight I think I find
myself in a position of economic preservation. The talk of
Durham Manufacturing being the largest employer in town is
also the largest taxpayer in town. And in the time of
corporate Enrons and scandals, to find a corporate citizen
who has been, I think, as responsible as Durham
Manufacturing, I think it would be a crime to place an undue
burden on them because of the fact that they are one of the
last set of deep pockets around.
I would hope that the EPA and the powers that will
decide this matter will consider that in their final
decision.
I also come here with a personal observation. One
of the ladies here tonight mentioned where we rank in the
listing of priorities. I would refer you back to the maps
of the plumes. And in one of the plumes sits Strong School.
Strong School sees every seventh and eighth grade student in
this town in public school. I have a ten-year old who will
be there in two years. So I would hope that that would
raise the priority.
Finally, I think that if there is precedent for
public water in Durham, I have a neighbor who has been here
or his family has been here since -- many, many years. And
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I believe that he can trace back that there was once a
public water supply in Durham with wood staved pipes that
was fed from Middletown, It was cleaned, I am told, by eels
to keep the pipes clean. I would also hope that the EPA
does not identify eels as being something that shouldn't be
in the water supply.
Thank you.
MS. O'NEAL: Dian O'Neal, 271 Main Street.
I'd just like to reiterate the situation with the
MBTE. MBTE was mandated by the federal government. We
didn't have a choice. Unfortunately, in their wisdom, they
forgot to test the tanks, the holding tanks. The MBTE
leaked from all the tanks. This is a source, as Mr. Kellish
said, should be investigated, and they do have the money.
Thank you.
MS. O'DONNELL: Thank you.
Any other comments? Yes, ma'am.
MS. KEAN: I'm Karen Kean. I live at 289 Main
Street, directly north of Merriam Manufacturing's property.
Merriam Manufacturing is no longer there.
I'm very concerned about the water situation,
also. I have two carbon filters in my cellar and last
spring or last fall, I think I talked to Mike Beskin when
the word came down about the dioxin and asked him if I could
have bottled water. He got back to me and said, no, that
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that wasn't going to be paid for. So I buy my own bottled
water, like Mr. Kellish does, I'm concerned about drinking
Everybody seems to think tonight that the best
solution is Middletown, I don't know. This is the first
time I've heard about White's Farm and the possible well
there or Mrs. Domyer's water. I don't know if that's worth
looking into to see if it would be less expensive than
Middletown. Middletown is close. The other wells are in
Durham. Would it be cheaper?
Mr. Kellish's point about the chemical coming down
Main Street and then coming down onto Maple Avenue, that's a
concern.
I also work in Strong School. I do drink the
water there. I believe it's filtered. This is unusual,
though, I mean, I drink the water there, but I don't drink
the water at home. I have more faith in their carbon
filters, I guess.
I'm concerned about the cost. I don't make nearly
77,000. I don't make anywhere near that. I support myself.
I would hope there would be some funding coming from
someplace. I like the idea about our taxes. Mr. Curley
said maybe our taxes should be reduced. I think they should
be reduced. That's a great idea, because our property
values are going down with this water situation, at least
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Attachment B
Written Comments Received During Public
Comment Period (July 13, 2005 to August 12, 2005)
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Deb Hoyt
07/21/2005 09:34 AM
cc
bee
Subject Durham Resident Comment
To Anni Loughlin/R1/USEPA/US@EPA
Hi Anni,
Our home at 97 Maple Ave., Durham is one of the impacted properties re: the Durham Manufacturing
superfund site. We purchased the property in 1993 from John Patterson, a family member of Durham
Manufacturing owners, who built the house for his own family on property deeded to him as a wedding
present from ancestors (ironic).
I thought that I'd share our perspective as impacted homeowners,
1. We purchased the house and continue to live here because we love the property, location, and quality
of life in Durham despite the knowledge that there are serious issues with the well water. We feel this way
because we have confidence and trust in the continual testing process and filter effectiveness. John
Neigrich of Durham Manufacturing has been a positive interface between homeowners and the testing lab,
2. As a mother of 2 young boys, I have felt more comfortable and confident drinking and cooking with our
own well water (due to the filter and "clean" lab results), than I would if I was a neighbor just outside the
"zone" without a filter system, I actually prefer the taste and have more confidence in our well water than I
do in some "public water" systems.
3. While we would like to see the contamination eliminated, we realize the complexity and cost involved.
Our greatest concern is to continue to be able to have clean, contamination-free water. We would be in
favor of having a public water supply built as an alternative/corrective solution to the use of well water.
4. Our long-range plans do Include relocating out of the area and selling our home. A public water
system would ensure peace of mind of a potential buyer and maintain our property value.
Thank you for your efforts in addressing this problem. My husband and I are planning to attend the public
hearing on July 28 to learn more.
Deborah Hoyt
debhovt@comcast.net
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Town of Durham
OFFICE OF THE FIRST SELECTWOMAN
PRIDE in the Past, Maryann P. Boord
FAITH in the future. First Selectvroman
July 28, 2005
Anni Loughlin
EPA New England
1 Congress Street
Suite 1100 (HBT)
Boston, MA 02114-2023
Dear Anni,
The Board of Selectmen of the Town of Durham compliments the Environmental Protection
Agency on its comprehensive Proposed Cleanup Plan for the Durham Meadows Superfund Site.
Excavation and off-site disposal of soil at and adjacent to the responsible parties is essential to
effective cleanup as well as to putting the residents' minds at ease once cleanup has been
completed. Maximum attention should be given to minimizing the impact of cleanup activities
on neighboring properties and residents. Also essential is future monitoring for possible plume
migration.
While institutional controls should be implemented to protect current and future occupants, we
request that you do not place excessive limitations on future use of the properties. Please keep in
mind our rural character and our Main Street Historic District.
When you enter into negotiations with the responsible parties in a spirit of fair-mindedness, we
request that you seriously consider the financial contributions already made by the Durham
Manufacturing Company.
The Board supports future connection to the Middletown Water Distribution System or another
alternative source of public water. Please note that the Town of Durham has maintained open
dialogue with Guy Russo, Director of Water and Sewer for the City of the Middletown, since
that possibility was first considered many years ago.
TOWN HALL • 30 Town House Road
P.O. Box 428 • Durham, Connecticut 06422
Telephone: (860) 34-9-3625 » Fax: (860) 349-8391
-------
The seriousness of the contamination and the "inconvenience" experienced by the residents in
the affected areas these many years cannot be minimized. However, it appears there is hope on
the horizon.
We thank you for your attention to our concerns for the future of our town and its water supply.
Sincerely,
i P. Bdord, First Selectwoman
aryann P. Bdord, First Selectwoman cniie K. >n. Selectman
Renee
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Statement of the Honorable Rosa L. DeLauro
EPA Hearing Durham Meadows Superfund Site
July 28,2005
I am pleased to have this opportunity to speak before the EPA and the Durham
community as you review the proposed remediation plan for the Durham Meadows
Superfund Site. As we are all aware, the remediation plan for this site has been a
long time coming. It is my hope that the EPA will work diligently to finalize a
Record of Decision in a timely manner which fully addresses the needs of the
properties and businesses which have been impacted by the contamination and,
most importantly, protects the health and safety of the residents of Durham.
There are a number of steps which need to be taken in order to address soil and
groundwater contamination of the Durham Meadows Site. This has already been a
lengthy process and, while I understand that there are statutory guidelines which
must be adhered to, it is my hope that the EPA will issue a Final Record of Decision
as soon as it is feasibly possible within the limits of the law. Once a final Record of
Decision has been issued, I would hope that the EPA will move quickly to alleviate
the strains the Superfund designation has put both on business and residential home
owners in the area.
Upon review of the proposed clean-up plan, I believe that the direction in which the
EPA is proceeding will effectively address necessary human health and
environmental protections. It is my understanding that the EPA will be balancing
these protections with future land-use restrictions for the properties. While it is
expected that the Durham Manufacturing Company will continue to use the
property for its current purposes, I believe that it is important that these restrictions
do not indefinitely prohibit the redevelopment of the Merriam Manufacturing
property.
Though I have not been contacted with any concerns regarding this proposed
remediation plan, I urge the EPA to listen closely to any concerns which may be
raised by local officials, residents, and most importantly, those individuals who are
directly impacted by the selected remedy. I know that the affected residents have
bad to endure many years of hardship. Their unique perspective on this case must
be given full consideration. These are the individuals who know this area and
understand the needs of the Town, its families and businesses.
I appreciate your time and attention to my comments. I look forward to the
expeditious resolution of this matter.
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Public Hearing: July 28,2005
I support the EPA proposed Cleanup Plan. Special consideration should be given to the
following:
• Due to identified constraints, obtaining a Technical Impracticability Waiver and
connecting to the Middletown public water system should be the highest priorities
of this plan.
• Institutional controls over affected areas should be implemented to the fullest
extent as required to protect current and future occupants and neighbors.
• I request that maximum attention be given to minimizing the impact of clean-up
activities on neighboring properties and residents.
• I request that negotiation activities be fair-minded with special consideration to
DMC, who is the only company currently servicing properties of contaminated
wells.
Signed
Renee Primus
Durham Selectman
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Lisa Larsen
08/04/2005 12:33 PM
To Anni Loughlin/R1/USEPA/US@EPA
cc
bcc
Subject Durham Superfund Site
History:
£> This message has been replied to.
I am one of the residents in the Durham Superfund Site
and I'm not very excited at the prospect of going on
Middletown's water. The reason? I'm an independent
soul and like having my own. My family has lived in
this house since 1955 and I hate to see it go on "city
water".
That said, It looks like the Middletown water will be
coming our way anyway. I've read the report you all so
carefully prepared and I really appreiate your work.
Just a couple of questions.
1, How can Merriam Manufacturing just stop the water
testing in the houses along the street? This was the
outcome of a lawsuit and they are obligated to
continue the services. Perhaps the fire changed
things? Seems a shame when Durham MC keeps holdng up
their end! Whine whine whine
2. I understand that the superfund will pay for
bringing Middletown water down the street and pay for
the hookups to each house. Will each resident then be
responsible for monthly water payments to Middletown?
If not, then that's great. I've always loved having my
own water and not having to pay for it.
3.If we must pay, then Durham should get some kind of
monies from Middletown don't you think?
4. Has Middletown been approached about this idea or
is it too early?
5. Our house was on the very old(and tiny) aqueduct
water system and then switched over to wells when the
aqueduct was compromised. I understand that dioxane
and his friends are definitely nasty.Has thought been
given or study been done considering the long term
health impact for people?
Thanks for listening to my concerns and questions.
Lisa Larsen, 246 Main St Durham 860-349-8236
Start your day with Yahoo! - make it your home page
http://www.yahoo.com/r/hs
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City of Middletown
WATER 8 SEWER DEPARTMENT
62 Berlin Street
Middletown, CT 06457
TEL: (860) 343-8085
FAX; (860) 343-8091
August 5,2005
Anni Louglin
EPA
New England
1 Congress Street
Suite 1100 (HBT)
Boston, MA 02114-2023
Re: Durham Meadows Super Fund Site, Durham, CT
Dear Ms, Loughlin;
I am providing you with these written comments regarding the City of
Middletown Water Department Service Extension as recommended in the EPA Proposed
Plan for the Durham Meadows Superfiind Site. Let me first thank you and your staff at
the EPA for their close liaison with the City of Middletown in the development of EPA's
alternatives and options with regards to remedying the current problems in the Town of
Durham, Connecticut, As I have stated to you, and publicly on behalf of the City of
Middletown Water Department and our Water Pollution Control Authority, the City of
Middletown remains prepared to assist the Town of Durham with the extension of the
City of Middletown water service into Durham,
While the City of Middletown remains committed to assisting our sister
community, to the south, the single caveat in doing so has always been the requirement
that the current rate payers and the citizens of the City of Middletown be held harmless
(cost neutral) for any extension of service to the Town of Durham. I, along with staff,
have reviewed the Metcalf & Eddy EPA Proposed Plan for the extension of water to the
Town of Durham and would like to offer several comments, not only on the proposed
EPA Plan but some alternatives that we would strongly suggest that the EPA endorse.
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Anni Louglin
EPA
August 5,2005
Page 2
Metealf & Eddy Plan - EPA Option
In reviewing the work of Metealf & Eddy, the City has identified some additional
costs that have not been included within the initial capitalization of the plan which
Metealf & Eddy has detailed to the EPA. The first item, which needs to be drawn to the
surface, is the need for additional water quantity in order to service the Town of Durham,
In preparation of this report, I understand that Metealf & Eddy did contact our staff
regarding the hydraulic grade line (HGL) of the City of Middletown's system in close
proximity to the Durham border. The correct answer to this question was 500 feet
NGVD 29. While the City maintains sufficient head for the purposes of supplying the
Town of Durham, there is insufficient flow available to supply the additional customers
that would be added. This small section of Middletown, in the Talcott Ridge area, is
serviced by two hydro-pneumatic pumps that pump on demand, much like a residential
well system. Because of the size of these pumps, and the availability of district piping in
Middletown. it would not be possible to supply Durham with the additional water
required unless there was an upgrading to the hydro-pneumatic pump station and an
improvement to district piping to the Durham town line.
Our preferred option in this matter has always been the establishment of the
Cherry Hill Water Tower, The Cherry Hill Water Tower, along with district piping and
improvements to the hydro-pneumatic pump station, to a full booster pump station, would
allow for ample water quantity to service the expansion of the Middletown system in a
southerly direction through the downtown area of the Town of Durham.
In our initial review, following the public hearing, we understood that the $7.0
million dollar number that was discussed at the initiation meeting on July 12, 2005 was a
capitalization number. Further investigation into the Metealf & Eddy report has indicated
that this was a compilation of both capital and on-going O & M. And while at the
initiation meeting, I did not raise the $7.0 million dollar number as a problem. It was
only because I had anticipated that the $7.0 million dollars was a capital number which in
fact included refurbishment of the pump station, district piping, and funding for the
Cherry Hill Water Tower, I will state again clearly, these three items would be essential
for the City of Middletown to supply the Town of Durham, in the quantity that is needed,
without imposing an economic hardship to the citizens of the City of Middletown,
Fuss & O'Neill Plan - City of Middletown Option
Previous to the EPA's establishment of the proposed plan, the City of Middletown
Water Department, cooperatively with the DEP and the Town of Durham, had worked
extensively on developing preferred options for the expansion of water service to the
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Anni Louglin
EPA
August 5, 2005
Page 3
Town of Durham. The preferred option is captured in the codified documents which
support the EPA Proposed Plan, and we believe it addresses all of Durham's current and
long-term needs. The Fuss & O'Neill report recommended a rehabilitation of the current
pump station, district piping, and the establishment of a Cherry Hill Water Tower on land
currently owned by the City of Middletown Water Department. Additionally, the Fuss &
O'Neill report detailed the extension of large diameter water mains to the Middletown
Town Line and onward through the Main Street area of Durham, terminating at the
intersection of Routes 17 and 79. The large diameter water mains would allow for
transmission of water through the downtown area and would allow for fire protection to
most all public buildings important to the residents of the Town of Durham.
The City of Middletown Water Department understands that the charge of EPA is
not to solve economic development and/or fire prevention issues in this central business
area of the Town of Durham. However, it is essential that the EPA solution does not
proceed in a vacuum of these other requirements. Therefore, the City of Middletown is
encouraging the EPA along with area legislators, both Federal and State, to consider the
establishment of a Water Development Fund to which the EPA portion from the
Potentially Responsibility Parties (PRP's) will be contributed in a full capitalization of
the actual costs to achieve the EPA recommended solution.
Analysis
For the purposes of detailing the relative costs of each of these proposals, I have
asked my staff to take the Metcalf & Eddy Proposal, on behalf of the EPA, and add to it a
set aside based on our best engineering estimate for rehabilitation of the hydro-pneumatic
pump station to a booster pump station. Also, the improvements to district piping
towards the Durham Town Line and the establishment of a set aside for the Cherry Hill
Water Tower. The attached worksheet (Table 1) captures these costs in tabular form and
is the true cost of capitalization of this project, so as not to financially impact the
residents of the City of Middletown. The cost of this construction is estimated at
$7,084,294.00. It is this cost that EPA should seek to provide water as it is
recommending.
On the Table 2, which is attached, I directed my staff to take the original Fuss &
O'Neill estimate from the year 2000 and update the unit pricing based on the Metcalf &
Eddy pricing, where available, and then for other units, which were not available, give a
best estimate of construction for those items which are not detailed within the Metcalf &
Eddy report. Additionally, and utilizing the same estimates, they have added to the Fuss
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Anni Louglin
EPA
August 5, 2005
Page 4
& O'Neill report the rehabilitation of the hydro-pneumatic pump station to a full booster
pump station and improvements to district piping. I would note that the Fuss & O'Neill
report did include contribution for the Cherry Hill Water Tower and also large diameter
piping improvements from the proposed Cherry Hill Water Tank to the town line. The
total cost estimate based, on our review to complete the Fuss & O'Neill full
redundant service area with ample fire protection for the Town of Durham, and also
providing elements to the City of Middletown to keep this extension cost neutral to
the residents of the City of Middletown, is $13,151,416.00.
Action Plan
The City of Middletown Water Department is suggesting a cooperative action
plan between EPA, Federal and State Legislators, the Town of Durham, and the City of
Middletown Water Department. Noting that the difference between the true cost neutral
impact to the City of Middletown of imposing the EPA Plan is $7,084,294.00 verses the
Fuss & O'Neill-City of Middletown preferred plan for full fire protection/redundant
water service for the Town of Durham is $13,151,416.00. There is a funding gap which
exists of $6,067,122.00.
The City of Middletown is encouraging the Town of Durham and the EPA to
establish a Town of Durham Water Development Fund, in which funds will be
contributed from the EPA and the Potentially Responsible Parties (PRP's) for the
Durham Meadows Superfund Site. It would be our strong recommendation that added to
these funds would be supplemental funds, which should be made available from the State
of Connecticut for Petroleum Tank Fund Sites, of which two exist in close proximity to
the service area and along the route of the proposed water main extension, and that the
Town of Durham look towards Federal legislators for assistance in providing additional
funds to provide for the large diameter water main improvements, and fire hydrants and
pressure reducing stations that would be necessary to provide long-term fire protection to
the Durham downtown area.
Within my ten-years as Director of the Water and Sewer Department, I have
looked on while the Merriam Manufacturing Plant has burned in the Durham downtown
area, as well as the Time Out Tavern just this previous spring. As an outsider, but
someone with life-long and intimate knowledge of the Town of Durham, it appears to
make sense that the center core be offered fire protection for the long-term health and
viability of the Town of Durham. The Main Street corridor houses almost all of the
important public buildings of the town including schools, the public library, town hall,
fire department, post office, and churches, as well as the numerous businesses which have
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Anni Louglin
EPA
August 5,2005
Page 5
given, and maintain, the bucolic character of Durham. I would note that the extension of
water, unlike sanitary sewer, will not impact development density in Durham. Therefore,
the extension of water, even in more ample quantities to address fire protection, will not
increase the density of development in the Town of Durham and, therefore, will not affect
the rural flavor and nature of this town.
I would like this response to serve as a call for action in the aggregation of
funding for the Town of Durham, such that a long-term and vital solution can be sought
for the downtown area of Durham for both potable water for its residents, impacted by
the Superfund Site, and also for the Town of Durham to maintain their long-term viability
by way of fire protection and enhanced business development.
I would like again to thank the EPA for allowing this opportunity for public
comment and should the EPA have further inquiry of me or my staff regarding the
development of our costs or the proposals and recommendations that have been made
within this formal submittal, we remain ready to answer questions and expand on these
ideas.
GPR:dmm
cc: Mayor Domenique S. Thornton
Senator Christopher Dodd
Senator Joseph Liberman
Congresswoman Rosa DeLauro, Third District
State Senator Eileen M, Dailey
State Senator Edward Myer
State Representative Ray Kalinowski
First Selectwoman Maryann Board
WPCA
Sincerest regards always,
Guy P. Russo
Director of Water & Sewer Dept.
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Table 1
Met calf & Eddy - EPA Preferred Option
Connection to Middletown Water Distribution System
6 inch Watermain without Fire Protection Option
Item Description
Units
Estimated
Quantity
i ii •. o_! I Totoal Estimated
Unit Price H _ ,
I I Price
Notes
Mobilization/Demobilization
LS
1
$20,000
$20,000
Allowance
Erosion and Sediment Control Systems
LS
1
$15,000
$15,000
Allowance
Maintenance & Protection of Traffic
LS
1
$100,000
$100,000
Allowance
Test Pits
EA
26
$250
$6,500
Estimate 2 per intersection
Rock Removal
CY
1,200
$60
$72,000
Assumes 20% of route @3 feet deep
6" DIP Water Main
LF.
7,900
$63
$497,700
Includes excavation and backfill
6" DIP Water Main-Extension from Middletown
L.F.
7,500
$63
$472,500
Includes excavation and backfill
Wedge Blowoff
EA
3
$1,000
$3,000
Previous bid information
6" Gate Valve & Box
EA
54
$1,150
$62,100
Previous bid information
1" Copper Water Service Connection
EA
80
$815
$65,200
RS Means
2" Copper Water Service Connection
EA
5
$1,300
$6,500
RS Means
1" Supply from property line to house
L.F,
6,500
$28
$182,000
RS Means
2" Supply from property tine to house
L.F,
650
$30
$19,500
RS Means
Potable Well Abandonment
EA
85
$1,800
$153,000
Remove 8 Return point of use systems
EA
S3
$350
$18,550
Allowance
1" Water meter
EA
80
$250
$20,000
2005 National Construction Estimator
2* Water meter
EA
5
$1,200
$6,000
2005 National Construction Estimator
Sidewalk, Repaint
SY
4,000
$4
$16,000
2005 National Construction Estimator
Dewaterinu
LS
$15,000
$15,000
Allowance
Stream Crossing
EA
3
$12,000
$36,000
Allowance
Sawcutting Bituminous Pavement
LF
27,000
$2
$58,050
ConnDOT Pricing Information
Removal of Bituminous Pavement
SY
5.300
$2
$10,600
ConnDOT Pricing Information
Sawcutting Concrete Pavement
LF
14,100
$6
$86,715
ConnDOT Pricing Information
Removal of Concrete Pavement (Route 17)
SY
2.400
$5
$11,040
ConnDOT Pricing Information
Replacement of Concrete Pavement with Bituminous
SY
2.400
$54
$129,600
Assume 6" thick
Temporary Pavement Repair (Local Road)
SY
1.400
$15
$21,000
Previous bid information
Permanent Pavement Repair (Local Road)
SY
2,400
$24
$57,600
Previous bid information
Temporary Pavement Repair (State Road)
SY
2,400
$15
$36,000
Previous bid information
Permanent Pavement Repair (Mill & Overlay)
SY
23,000
$14
$322,000
Assume 3" Depth and 24' Width
Driveway Repair/Replacement
SY
2.700
$9
$23,220
Pavement Markings
LF
18.000
$0.30
$5,400
Turf Establishment
SY
24,800
$10
$248,000
Includes new topsoil
Uniform Police (State Road Work)
Day
220
$400
$88,000
Assumes 2 police for 30 days @$55/hr
Disinfection of water main
LS
1
$15,000
$15,000
Allowance
Pressure and leakage tests
LS
1
$10,000
$10,000
District Piping
LS
1
$428,280
$428,280
Provided by City of Middletown
Booster Pump Station
LS
1
$450,000
$450,000
Provided by City of Middletown
Cherry Hill Water Tower
LS
1
$760,000
$760,000
Provided by City of Middletown
Subtotal
Construction contingency (bid & scope)
Subtotal (Remedy implementation)
Project Management
Remedial Design
Construction Management
Institutional Controls
Total Capital Cost
30% of capital cost estimate
5% of capital cost estimate
8% of capital cost estimate
6% of capital cost estimate
IS 1
$4,547,065
11,364.11?
$5,911,172
$295,559
$472,894
$354,670
$50,000
$7,064,294
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Table 2
Fuss & O'Neill - Middletown Water Department
Preferred Option
Item No:
Item Description
Units
Estimated
Quantity
Fuss &
Marc
Unit Price ]
O'Neill, Inc.
h 8, 2000
Estimated Price
City of
Augu
Unit Price
Middletown
st 3, 2005
Estimated Price
1
16* DIP Water Main
L.F. | 14,000
$80
$1,120,000
$104
$1,453,942
2
12" DIP Water Main
LF.
5,100
$60
$306,000
$98
$499,800
3
8" DIP Water Main
L.F,
26,000
$50
$1,300,000
$70
$1,820,000
4
6" DIP Water Main
L.F,
900
$45
$40,500
$63
$56,700
5
Fittings
LBS
100,000
$3
$250,000
$3
$324,541
6
6" Hydrants
EA
90
$1,800
$162,000
$2,337
$210,302
7
6" Gate Valve & Box
EA
90
$560
$50,400
$1,150
$103,500
8
8" Gate Valve & Box
EA
30
$800
$24,000
$1,400
$42,000
9
12" Gate Valve & Box
EA
5
$1,300
$6,500
$1,900
$9,500
10
16" Butterfly Valve & Box
EA
26
$2,300
$59,800
$2,986
$77,630
11
1" Copper Water Service Connection
L.F.
8,000
$25
$200,000
$32
$259,632
12
Direct Drill or Open Cut 1" Copper WSC
EA
60
$2,500
$150,000
$3,245
$194,724
13
1" Corporation
EA
325
$160
$52,000
$208
$67,504
14
1" Corporation Stop
EA
325
$160
$52,000
$208
$67,504
15
Provide Water Serv. To Contam. Property
a. Potable Well Abandonment
EA
75
$1,500
$112,500
$1,800
$135,000
b. Remove & Return Filter Systems
EA
75
$250
$18,750
$350
$26,250
c. Meter Setter, Jumper Prep & Connect
EA
75
$300
$22,500
$389
$29,209
d. Check Valves & PRVs
EA
75
$200
$15,000
$260
$19,472
e. 1" Copper WSC from Prop, Line to House
LF.
6,000
$25
$150,000
$28
$168,000
16
Allowance for Sidewalk Replacement
S.F.
16,000
$4
$64,000
$5
$83,082
17
Temporary Pavement Repair
L.F.
34,000
$12
$408,000
$15
$510,000
18
Permanent Pavement Repair
L.F,
34,000
$14
$476,000
$24
$816,000
19
State Road Crossing (Pipe Only)
EA
8
$7,500
$60,000
$9,736
$77,890
20
Temporary Pavement Repair State Road
LF.
500
$14
$7,000
$15
$7,500
21
Permanent Pavement Repair State Road
S.Y.
800
$45
$36,000
$58
$46,734
22
State Road Driveway Apron Overlay
S.Y.
5,000
$15
$75,000
$19
$97,362
23
Allowance for Rock Excavation
C.Y.
4,000
$35
$140,000
$60
$240,000
24
Maintenance & Protection of Traffic
LS
1
$250,000
$250,000
$324,541
$324,541
25
Uniformed Officers
DAY
500
$640
$320,000
$831
$415,412
26
16" PRV with Vault
EA
1
$30,000
$30,000
$38,945
$38,945
27
12" PRV with Vault
EA
1
$25,000
$25,000
$32,454
$32,454
28
Cherry Hill Water Storage Tank
LS
1
$760,000
$760,000
$760,000
$760,000
29
District Piping
LS
1
$278,880
$278,880
30
Booster Pump Station
LS
1
$450,000
$450,000
Subtotal $6,742,950 $9,744,012
Engineering/
Administration 25% $1,685,738 $2,436,003
Contingency 10% $674,295 $974,401
Total $9,102,983 $13,154,416
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PViola3453@aoI.com
08/10/2005 05:39 FM
cc
bcc
Subject Fwd: Durham Meadows Superfund Site, Durham, CT
To Anni Loughlin/R1/USEPA/US@EPA
-— Message from PVtoIa3453@aol.com on Wed, 3 Aug 2005 17:23:25 EDT -—
To; www.loughlm.anni@epa.gov
Subject: Durham Meadows Superfund Site, Durham, CT
Dear Anni,
Although I have already made public various comments for the record
regarding the subject of the Durham Meadows Superfund Site at the formal
hearing held
on July 2 8th of this year, I would like to hereby submit additional
information which may be helpful before actual acceptance is decided for any
proposed
plan to address this environmental issue. First, however, I would like to
stress the importance of having the soil tested at the Strong School location
because of the activity that took place there over the years when it was first
Durham High School (the subject of auto maintenance and instruction in auto
repair was part of the curriculum) and the site itself was the bus depot for
many
years for Regional District #13 up until the early 70's. (Maggie Peterson of
Maiden Lane is the name of the other woman, beside myself, who reported her
concern about this situation at the preliminary hearing on July 12th, 2005.)
New remarks I would like to make are the following: I feel that there is a
real possibility for the water supply needed to rectify the problem faced by
the residents and businesses might be met from either one of the well sources
in existence locally that currently serve the elderly housing (Trinity complex
off Higganum Road) and the Main Street occupants and, perhaps, even part of
Cherry Lane. I am aware that since Durham took over ownership for a water
company here, and The Connecticut Water Company manages it, there have been
extensive improvements made to the existing wells in order to adequately serve
the
users. I admit that I do not know at this time if the monitoring done on the
properties affected indicate a need for another source or whether it can be
controlled with what is effectively in place. With that in mind now, I would
offer the suggestion as to investigating the likelihood of an alternative
source
within the town of Durham's borders in proximity to the contaminated area, but
outside of it, of course. This way, the town once again would take the lead
and have control over implementing the remedy and, with the oversight of not
only your organization, the Federal Eniveronmental Protection Agency, The
Connecticut Water Company and the health director, Dr. Brad Wilkenson, would
be
able to achieve a satisfactory outcome. It may even mean a substantial
savings
for the taxpayers, and those of us on fixed incomes would appreciate a lesser
cost if that were a result!
I realize this is an opportunity to assist our neighbors who deserve a
thorough analysis of everything that has gone on for a lot of years, and it
must
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be resolved within a reasonable time frame knowing that the studies on this
are
now almost complete. Inasmuchas it appears there will be added consideration
and action on a new or other item as a direct outcome of this communication
and others offered, I am looking forward to a responsible and accountable
solution.
In closing, I regret to say that I have once again contacted Mrs. Fred
Dahlmayer (Margie) of New Haven Road, Durham, and in doing so, have learned
that
she and her husband choose not to offer their land for a possible water
source.
What she and I talked over in the past led to a misunderstanding on my part,
and I apologize for causing any confusion.
Thank you for your continued interest in this project and, hopefully, the
ultimate benefits for our community which will become obvious in the near
future.
Sincerely,
Donia Viola
Durham
PViola3453@aol.com
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PViola3453@aol.com
08/11/2005 11:08 AM
ce
bcc
Subject Durham Meadows Superfund Site, Durham, CT
To Anni Loughlin/R1/USEPA/US@EPA
Dear Anni,
As mentioned in our telephone conversation of this morning, August 11,
2005, I am herewith forwarding additional comments I would like to register
for
the record pertinent to the subject of the Durham Meadows Superfund Site,
Durham, CT,
Having given further consideration to the proposal submitted by the
Environmental Protection Agency (hereafter known as EPA), I would like to ask
for the
cooperation of the 1PA and all the Durham parties involved to seriously
contemplate the possible use of the Wallingford reservoir which abuts Durham
in the
Tri- Mountain Road area. I am aware that the City of Wallingford would have
to be approached, as would any other property owner even within the Town of
Durham's borders in order to participate in the search for a safe, reasonable
and, maybe, a more affordable solution. Without any comparisons for the work
which needs to be done to effectively remedy and manage the pollution which
has
persisted and encumbered so many, I feel a fair outcome will not result. In
order to achieve a satisfactory solution there is a real need to look beyond
the only offer of having the City of Middletown deliver their water. Cost i
also a huge factor and it is reasonable to expect a savings if there were
other
sources competing. Distance is another factor in engineering any plan since
the measure of pipe, actual labor and construction all impact time and cost.
1 would naturally be more than willing to support a local source and keep the
revenues distributed within my own town. Yet, another "outside" source, like
Wallingford, or an "in-town" source may bring healthy competition with less
spending necessary. Further, whenever the final decision is agreed upon, I
trust that it will also be acceptable because of the quality of the water to
be
supplied and not just the quantity available.
The primary contributors to the contamination found on the Durham Meadows
Superfund Site should be held fully accountable in making restitution for thi
problem. With the prospects of grants and even EPA funding, I feel that
people might be fooled into thinking they are not actually paying for this
remedial
effort when, in fact, such monies are available due to the very taxes
collected from them which make such grants and funding possible.
Thank you again for your attention to this correspondence and to
recognizing all the concerns on this matter.
Sincerely,
Mrs. Donia Viola
Durham, CT
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PViola34 53®aol.com
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Henry A. Robinson
First Selectman, Town of Durham, Connecticut, (1993 thru 1997)
546 R Haddam Quarter Road, Durham, CT 06422-1707
E-mail; Henry A Robinson@sbcglobal.net
Phone & Fax: 860.349,3232, Cell 860.985.7680
Anni Loughlin (HBT) August 11, 2005
Remedial Project Manager
Durham Meadows Superfund Site
One Congress Street
Boston, MA, 02114
Dear Anni;
It's hard to believe that over 10 years has gone by since I was First Selectman and we
worked together on trying to find a permanent solution to the Durham Meadows
Superfund Site problems,
I am sorry I was not able to get to your public meeting but I am pleased to see that the
EPA, with concurrence of the Connecticut DEP, have come to the conclusion that
bringing public water into Durham from Middletown is the logical solution. I am only
sorry that it took the "process" ten years and cost so many taxpayer and business dollars
to get to the solution that common sense dictated ten years ago.
I have downloaded your presentation and find it supports your conclusions. I would like
to remind you that Durham really has four (4) other areas that need to be addressed in the
design of a public water system as well as the Superfund Site. They are;
1.) Water System Components -
Durham Heights -
There is a real need to bring public water to the Durham Height area, Austin Road,
Edwards Road etc. The one-quarter acre lots that were developed prior to Durham
Adopting Zoning and Subdivision regulations are marginal at best for supporting on site
wells and septic systems. Public water would go a long way to mitigate future problems.
Even if the local mains and residential connections are postponed until a future date, the
system must be sized to accommodate their needs.
Durham Center Water System -
The flow requirements to incorporate the Durham Center water system into public water
brought from Middletown should be a part of the design. While there are concerns that
water main pressures from a gravity feed system from Middletown would over pressurize
the plastic mains in the Durham Center Water System, I am sure that pressure regulators
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First - Design and installation of storage tankage and water mains to provide water flows
to cover the Superfund Requirements, lire flows, Durham Heights requirements, and the
potential needs of the area adjacent to the closed Durham Middlefield landfill.
I would urge that the EPA work closely with local and state officials to identify grant
moneys to cover this component of the system.
Second - The cost of hook ups to the water system for the public facilities, businesses and
residences whose private water supplies have been polluted should be borne by Durham
manufacturing and Merriam Manufacturing, Obviously each company would pay for the
required soil remediation on their own properties. A special tax assessment would allow
municipal bonding to be paid off by these companies over an extended period of time.
Third - Providing public water to the Durham Heights area is a local problem and could
be financed by a combination of local bonding, private expenditures and special taxation.
Similar financing could be used to incorporate the Durham Center Water System into the
system, another local issue.
Summary -
Originally Durham looked to the EPA and the Superfund Program for help in defining
and solving the water pollution problems on and adjacent to our Main Street. You have
the opportunity to validate our faith in the fact that you are there to help us.
Your support in obtaining the funding for a complete solution is critical at this juncture.
In the overall picture of Federal and State projects this is a minor one. To Durham it is an
expenditure only rivaled by the costs of our school system and one of great importance
to the health and welfare of our community.
I implore you to take Durham Manufacturing's exemplary corporate citizenship into
consideration in allocating financial responsibility. They are a critical element in
Durham's tax base. Their future corporate health and membership in our community is of
key importance.
Sincerely,
Henry A. Robinson
-------
Hank Robinson
To Anni Loughlin/R1/USEPA/US@EPA
cc
bcc
08/11/2005 02:43 PM
Please respond to
ienry_A_Robinson@sbcglobal
.net
Subject Durham Meadows Superfund Site
Anni Loughlin
Remedial project Manager
Durham meadows Superfund Site
EPA
One Congress Street
Boston, MA 02114
Dear Anni:
Attached is a Word 2000 file containing my comments
and recommendations relative to the Durham meadows
Superfund Site.
Sincerely
Henry A. Robinson
First Selectman, Town of Durham {1993 through 1997)
Comments on Durham Meadows Superfund Site.doc
-------
08/12/05 12:41 FAX 860 424 4000
PEP ffASTE BUREAU CHIEF
US002
STATE OF CONNECTICUT
% J DEPARTMENT of environmental protection
August 11,2005
Ms. Mary Jane CDoimell
EPA New England
1 Congress Street
Suite 1100 (HBT)
Boston MA 02114-2023
Subject: Comments on the Proposed Plan for the Durham Meadows NPL Site, Durham, CT
Dear Ms. QDormell,
The Connecticut Department of Environmental Protection has reviewed the July 2005 Proposed Cleanup
Plan for the Durham Meadows Superftrad Site, and offers the following general and specific comments:
In general, the CT DEP supports EPA's cleanup proposal, and concurs with the first five bullets of "The
Cleanup Proposal At A Glance" beading on page 1 of the Proposed Plan, as described below;
• Excavation and offsite disposal of soil at and adjacent to the Merriam Manufacturing
Company property, in conjunction with soil vapor extraction (combination of Alternatives S-
3 and SV-3.)
• Excavation and offsite disposal of soil at the Durham Manufacturing Company property
(Alternative DMC GW-5).
• Connection to the Middletown Water Distribution System to provide an alternative source of
water to all residences currently affected by groundwater contamination and additional
residences located near the contaminated area (Alternative AWS-2).
¦ Monitoring of the overall area of ground water contamination to ensure no migration of
groundwater beyond its current general boundary (Alternative DP-6), with a contingency to
implement a groundwater extraction system for hydraulic containment syst em if the
contamination spreads (SZ-2).
• Implementation of a waiver of federal and state requirements that would normally require
cleanup of the groundwater to meet drinking water standards, since it is not technically
practicable to clean up the groundwater to such levels in a reasonable amount of time
(included with combined Alternatives DP-6 and SZ-2).
Institutional Controls
DEP agrees that institutional controls should be included in this remedy. For the institutional controls (as
described in the sixth bullet on page 1 of the July 2005 Proposed Plan), Environmental Land Use
Restrictions (ELURs) pursuant to Section 22a-133q-l of the Regulations of Connecticut State Agencies
are permanent and enforceable, and are therefore considered by DEP to be the most reliable form of
institutional control available to prevent future use of polluted groundwater, and prevent inappropriate
future use of certain areas of the site. In some situations, the remedy will have to include ELURs to
comply with the Remediation Standard Regulations, which have been identified as appliqable
requirements (ARARs).
( Primed un Recycled Paper)
79 Blm Street » Hartford. CT 06106-5127
An Equal Opportunity Employer
-------
08/12/05 12:41 FAX 880 414 4060
PEP WASTE BUREAU CHTBR
@003
Proposed Pino Comments-Durham Meadows NPL Site
August 11,2005
Further Characterization
DEP also agrees that further characterization (as described in the last bullet on page 1 of the My 2005
Proposed Plan) is necessary to assess the potential for VOCs in shallow groundwater to migrate from
groundwater into soil -vapor and then into overlying structures, resulting in unacceptable risk in indoor air.
Any farther evaluation must include an investigation to determine the extent and degree ofVOC
contamination in the shallow groundwater (delineation of the VOC plume in shallow groundwater) and an
evaluation of the concentrations of VOCs in soil vapor beneath any buildings overlying such shallow
groundwater plume, including the soil vapor beneath the Durham Manufacturing Company building.
The groundwater at this site has already been found by EPA to pose "actionable risk" due to the potential
for volatilization from shallow groundwater, and the RSRs have been identified as applicable
requirements ARARs, Therefore, the new data gathered as a result of this further characterization effort
should not be subjected to another risk assessment by EPA. When additional data has been gathered, the
data must be compared to the appropriate volatilization criteria contained in the RSRs to determine if
action (or additional action) is needed to address the threat posed by potential migration of unacceptable
concentrations of VOCs into structures, Concentrations of VOCs in groundwater and VOCs in soil vapor
beneath buildings over the shallow groundwater plume should be compared to the appropriate
volatilization criteria (either residential or industrial/commercial) in the RSRs to determine if additional
action should be taken.
Compliance With ARARs
In accordance with EPA's November 2002 Draft Subsurface Vapor Intrusion Guidance, the groundwater
at the site poses an actionable risk to indoor air. As noted above, Connecticut's Remediation Standard
Regulations have been identified as applicable ARARs for this Bite, Therefore the remedy selected for this
site must provide for compliance with CTs more stringent volatilization criteria. Further, such criteria
must apply to the full extent of the shallow QW plume, not just to the portion of the plume that currently
exceeds EPA's acceptable risk range.
We want to thank you for the opportunity to comment on the proposed plan. We look forward to the
implementation of this plan. If you have any questions on the content of this comment letter, please
contact Christine Lacas at (860) 424-3766.
Sincerely,
Michael J. Harder, Chief
Bureau of Waste Management
CT Department of Environmental Protection
-------
SQuRHAM'
Established in 1922
The Durham Manufacturing Company * 201 Main
August 11, 2005
• P.O. Box 230 • Durham, Connecticut 06422-0230
TEL: 860-349-3427/800-243-3774
FAX: 860-349-S572/800-782-5499
www,durhammfg.com, www.hodgediv.com
e-mail: inlo@durhammfg.com
Ms, Anni Loughlin
U.S. Environmental Protection Agency
1 Congress Street
Suite 1100 (HBT)
Boston, MA 02114-2023
RE: Durham Manufacturing
Dear Anni,
The Durham Manufacturing Company (Durham) was understandably disappointed that the USEPA elected to withdraw from the AOC
which allowed Durham to prepare the RI/FS. This Is especially true after Durham spent a great amount of time and money to develop
the RI/FS and was on track to provide the same to EPA on time.
Considering the past efforts that have been undertaken and expenses incurred by Durham, the company is no longer in a position to
spend additional time or money participating in a new process or providing detailed comments on new documents.
Therefore, we have asked our environmental consultant to indicate some of it's most critical concerns, These will fall into several primary
categories:
1. Public Water - to the extent public water is the preferred alternative, Durham does not wish to stand in the way of a public works
project, but does wish to draw attention to certain issues. However, Durham believes that the technical and financial analysis related
to and financial justification of the public water system alternative is flawed,
2. That the remedy analysis specifically related to The Durham Manufacturing Company site is both technically and financially flawed,
3. That the remedial approach to The Durham Manufacturing Company site should be guided by the Connecticut Remediation
Standards Regulation and the alternatives provided therein.
This document and the attached submission by our consultant should not be construed as the willingness or the ability of The Durham
Manufacturing Company to further participate in this process which has impacted Durham Manufacturing Company's competitive position
in a global and local marketplace.
Thank you for your attention.
Sincerely,
Richard H. Patterson
President/CEO
cc: Earl W. Phillips, Jr. Esq., Robinson & Cole
RP/jlg
End.
BiiiH fougft Since t936
¦^FRICK'
GALLAGHER
A Srftftd
-------
Etginurf and
GeoEnvironmental, Inc. Scuntisu
August 10,2005
File No. 05,0043007.00
The Durham Manufacturing Company
201 Main Street, P.O. Box 230
Durham, CT 06422-0230
Attention; Mr. Richard Patterson
1( Stxtnwn Court
Faif field
Conottficor 06430
203-15S.J016
FAX 203-25<-S193
hKp^www.pa.net
27 Noelc Read
Vernon
ConftecEicut 06066-3965
U0-S7S-76SS
FAX 860.g7i.24lt
hrtp:/'www.gzi,nrt
Re: Comments on the Remedial Investigation/Feasibility Study
Durham Meadows Superfund Site
Durham, Connecticut
Dear Attorney Phillips:
At your request and in accordance with Durham Manufacturing Company's (DMC) limited
resources, we have briefly reviewed the Remedial Investigation and Feasibility Study
(Rl/FS) for the Durham Meadows Superfund Site (DMSS), as well as the Proposed Plan
issued by the United States Environmental Protection Agency (USEPA), dated July 2005,
which presents their preferred remedies for the Merriam Manufacturing Company (MMC)
property, the DMC property and the Site-Wide Groundwater Study Area. While we have
not had time to read and examine the documents in detail, and do not have the time to
conduct independent studies, equations and cost estimating, we nevertheless have some
serious concerns about the technical basis for some of the conclusions reached by the
USEPA and about the remedy selection. Our major concerns are presented below, but we
would also appreciate the opportunity to study the documents in more detail and to conduct
independent evaluations of the remedial alternatives to provide more concrete evidence
concerning the flaws in the remedy selection.
MMC Property
In view of the limited time and resources available to review and comment on the stated
documents, we have not spent much time on the MMC aspects of the Rl/FS or remedy
selection. However, we note that the RI acknowledges that the MMC site is the primary
source of the 1,4 dioxane in the Site-Wide Groundwater Study Area. In fact, the
occurrence of this compound in the southern half of the DMSS appears to be limited to; (1)
the Strong School well (which has also been a suspected source area) which is no longer in
use, (2) one well on the DMC property, which is not used for potable purposes, and (3) one
well at 168 Main Street, which we contend may be due to activities on that property. To
the extent that the cost of the Point of Use Treatment alternative is much higher than it
would be if 1,4 dioxane were not present, we believe that DMC should not be liable for
any cost considerations that may be attributable to the presence of 1,4 dioxane in the site-
Ac Equal Oppomvify EmMff/V/H
-------
The Durham Manufacturing Company
File Mo. 05.0043007.00
August 10,2005
Page 2 of 5
wide groundwater. Similarly, should USEPA consider using the presence of 1,4 dioxane
as a basis for preferring public water, DMC should no be looked to for increased costs.
DMC Property
Our biggest concern with the RI» the FS and the Proposed Plan for the DMC property
'"Vl u centers on the greatly exaggerated and unsubstantiated areas described as "Conceptual
^w\// Maximum Extent of DNAPL [Dense Non-Aqueous Phase Liquid] Source Area in
/ Overburden" and "Conceptual Maximum Extent of DNAPL Source Area in Bedrock" as
shown on Figure 3.3-14 of the Proposed Plan. These areas are based on theoretical
calculations and absolutely no field observations, as is readily and repeatedly stated in the
source documents (the RI and FS). Especially as concerns the bedrock aquifer, the Draft
Final Technical Impracticability Evaluation Report (TI Report) prepared by the USEPA's
contractor Metcalf & Eddy states that "No samples from any water supply or bedrock
monitoring wells anywhere on the Site have been found to have concentrations of solvents
exceeding or even approaching one percent of the effective solubility." (The one percent
of effective solubility is one of the criteria for evaluating the potential for DNAPLs to be
present.) The report also states "Another factor specific to the Durham Meadows
Superfund Site is the difficulty in locating DNAPL, Although converging lines of
evidence suggest the presence of DNAPL source zones, DNAPL has never been observed
at the site."
While theoretically there may have been, at one time, some extremely limited areas
(proximate to Monitor Well MW-2 and the original MW-6) in the overburden on the DMC
property where DNAPLs may have existed, both of these areas have been subject to
remediation (the former in the foim of an aggressive and very successful multi-phase
extraction system, and the latter by soil removal through trenching and gravity drainage of
overburden groundwater into a drain system installed for this purpose). Available
evidence suggests that it is doubtful that any but very small and discrete globules of
DNAPL exist any where on the DMC property and certainly nothing resembling the extent
depicted on the maps presented by die USEPA. Despite this, it is clear that USEPA
considers this to be an important aspect of remedy selection, on the other hand, the
insistence on the widespread occurrence of DNAPL makes the remedy selection for the
DMC property inconsistent with the TI Report.
The remedy preferred to reduce risk of exposure to contaminated groundwater in the Site-
Wide Groundwater Study Area is to provide public water to the affected community. With
the risk of exposure to the poundwater eliminated, there is much less of a risk driver to
compel the remediation of a speculative source area in such an aggressive manner as
excavation of large areas of the DMC plant property, as recommended in the Proposed
Plan. Furthermore, the TI Report, suggests that source area remediation will not
significantly enhance the overall site remediation. Specifically, the report states, "There
are several factors specifically related to the Durham Meadows Superfiind Site that would
limit the effectiveness of remedial technologies, and potentially render the attempted
remediation of a source zone and its associated dissolved-phase plume a futile endeavor."
-------
The Durham Manufacturing Company
File No. 05.0043007.00
August 10,2005
Page 3 of 5
This report also contains the following passage: "Also, there is very limited success
reported for remediation of DNAPL using available technologies. In a USEPA publication
titled "The DNAPL Remediation Challenge: Is There a Case for Source Depletion?"
[USEPA, 2003] it is stated that "if the RAO in the source zone is complete restoration (i.e.,
background levels of the DNAPL constituents), or MCLs, it is unlikely that any of the
technologies currently available will be successful, except in situations involving small
spills of DNAPL in relatively homogeneous saturated zones." The Durham Meadows
Superfiutd Site is an example of a site...which is not amenable to restoration in a
reasonable time frame."
The TI Report concludes with the following; "In summary, there are no technologies
currently available that are known to effectively remediate a DNAPL source zone in
complex hydrogeologic environments to MCLs or background concentrations in a
reasonable time frame and at reasonable cost at this site. While source zone remediation
is impracticable in a reasonable time frame with available technologies, depletion of
DNAPL mass is possible using available technologies and some technologies such as
ISCO and electrical resistivity may be more effective than others. However, in a complex
heterogeneous hydrogeologic environment (particularly fractured bedrock) where it is
difficult to accurately locate DNAPL and where some of the DNAPL is likely inaccessible
to available technologies, there would be limited benefit realized by implementing a
costly technology specifically for source zone depletion." (Emphasis added).
Leaving aside the potential for severe, debilitating and damaging business disruptions
associated with this aspect of USEPA's remedy, it is our considered opinion that the
excavation of large portions of the overburden materials on the DMC property would be
ineffective, as stated in USEPA's own documents; would be excessively costly in light of
the overall benefits to the site restoration; would be extremely disruptive to the ongoing
operations of this active facility; and, would be potentially damaging to the overall site in
that the actions could mobilize currently isolated contamination.
It is clear that the USEPA supporting documents for the DMSS were hastily put together
and that the remedy selection for the DMC site has not been fully developed or evaluated.
Note that Metcalf & Eddy stated that they had not evaluated the effectiveness of the multi-
phase extraction system. We believe that the DMC property should not (as drafted) be
included in the Record of Decision for the DMSS, and that a supplemental Record of
Decision should be developed for the DMC site.
If the DMC site must be included in the Record of Decision (though we can think of no
technical basis for doing so at this time), it is only logical that the decision consist of a
flexible remedy and time ftame which refers to the Applicable and Relevant and
Appropriate Requirements (ARARs) which consist primarily of Connecticut's
Remediation Standard Regulations. Remedial Action Objectives would logically focus on
reduction of risk. To the extent there is risk on the DMC site it is to the future construction
worker. This risk can be readily mitigated through the imposition of a site-wide soil
management and health and safety plan to be in effect for every excavation on the site.
-------
The Duiham Manufacturing Company
File No. 05.0043007.00
August 10,2005
Page 4 of 5
There is also a perceived risk of inhalation exposure to future residents on the site. This
risk can also be readily mitigated through institutional controls that provide for the
installation of vapor controls under any new residential structures built on the DMC
property. Such institutional controls can also consist of Environmental Land Use
Restrictions prohibiting residential development.
Site-Wide Groundwater Study Area
DMC understands that providing public water to the portions of the Town of Durham that
are included in the Durham Meadows Superfund Site is a long-term and permanent
solution to the risks associated with exposure to contaminated groundwater throughout the
DMSS and, for that matter, the Town of Durham. However, we believe that the supporting
documentation to justify this solution to the problem is flawed and inaccurate. The extent
of the contamination evident in the site-wide groundwater in the DMSS has been
monitored since 1982 and in the intervening 23 years there has been no spread of the
plume.
There is, therefore, no justification to increasing the number of affected potable supply
wells from 35 to 85. Furthermore, actual operating data developed over the last 20 years
has shown that, with the possible exception of a few wells which contain unusually high
concentrations of volatile organic compounds, the frequency of carbon changes in the
existing filtration systems is no greater than annually. There is no experiential or technical
basis for expecting that the carbon systems will require five changes per year. In addition,
the evaluation of the Point of Use alternative for the DMSS includes metals treatment for
ten wells. There is absolutely no justification for this inclusion. None of the supporting
documents suggest that there are metals associated with the site-wide groundwater plume
nor has there been any attempt to link any individual site-related metals to the potable
supply wells. The majority of metals detected in the potable supply wells are most likely
attributable to the plumbing in the systems, not from occurrences in groundwater,
Frankly, the entire evaluation of, and therefore the cost projection for, the Point of Use
option is greatly inflated. It appears obvious that this was done to make it (the Point of Use
option) appear less cost competitive compared to the public water option. In addition, we
note that a study commissioned by the Town of Durham to investigate the feasibility and
cost of connecting the DMSS to the Town of Middletown water system concluded that the
cost to maintain the carbon filtration systems for 50 years would be approximately
$3,580,000. While the discovery of 1,4 dioxane in a limited number of potable supply
wells would constitute an additional cost to this option, it cannot explain the difference
between the prior study estimates and the USEPA estimate for the Proposed Plan of
$7,200,000. White DMC may not care to actively oppose provision of public water to the
affected area, we believe that the USEPA's flawed evaluation of this alternative should be
redone and that more realistic cost estimates be developed based on actual operating
experience.
-------
The Durham Manufacturing Company
File No. 05,0043007.00
August 10, 2005
Page 5 of 5
In addition, we note that a study commissioned by the Town of Durham to investigate the
feasibility and cost of connecting the DMSS to the Town of Middletown water system (8-
inch mains without fire protection) concluded that the cost would be, in 2000,
approximately $3,440,000, compared with the USEPA estimate of $7,000,000.
After review of the documents provided to us by the USEPA we conclude the following:
• The occurrence of 1,4 dioxane in the DMSS site-wide groundwater is almost
entirely attributable to the source area on the MMC site, and any cost
considerations associated with this compound should not be bome by DMC,
• The suggested remedial action for the DMC site is excessive in scope and cost,
would result in insufficient benefit to the site-wide groundwater quality in
comparison to the cost, and would be extremely disruptive to this active
manufacturing operation.
• The DMC property should not be included in the currently envisioned Record of
Decision, but should be covered in a separate Record of Decision. In any event, any
remedial action decisions for the DMC property be based on reduction of on site
risks and be consistent with the Remediation Standard Regulations.
• The technical and financial evaluation of the remedial options for the site-wide
groundwater are flawed and biased and should be re-evaluated prior to being
finalized in the Record of Decision.
Thank you for the opportunity to comment on the documents supporting the Proposed Plan
for the Record of Decision for the DMSS. Please feel free to call and discuss these
comments with us at your convenience. As stated in this letter, we would appreciate the
time to more fully study and comment on the documentation.
Very truly yours,
Summary
GZA GEOENVIRONMENTAL, INC.
Robert Lamonica, LEP, CPG
Associate Principal
Cc
Earl Phillips
John Gowac
Z:UOBS\Duiti«m Minu&ctaring'Comments an Remedy Selcction.doc
-------
JJFHoran@webtv.net (John
Horan)
08/12/2005 11:06 AM
To Anni Loughlin/R1/USEPA/US@EPA
cc phorari@webtv.nel
bcc
Subject EPA plan for Durham, CT
The plan doesn't include use of microbes to break down the offending
chemicals in
situ. Some years ago, I read of the use
of moderate temperature steam injection
around the plume of contaminants. The
story was of several orders of magnitude
of organic depletion within two years.
My attempts to resurrect the documentation were unsuccessful. Only
recently did I uncover a promising site.
It was a large international conference on contamination mitigation.
The 682 papers
and abstracts are contained in a CD for
$295. by Battelle Press Online Bookstore,
ISBN:1-57477-145-0. The contents are
surveyed on
http://www.battelle.org/bclscrpt/Bookstore/2 0 04chlorinated.cfm
No. I haven't purchased it. I am not personally that deep into the
subj ect.
Perhaps titles or authors may mean something to you. Or, you know of
promising techniques that didn't actually
pan out. This isn't nanotech but merely
microbial use.
John Horan
164 Partite lee Hill Road
Durham, CT 06422
(660) 349-9714
-------
State of Connect/cut Department of Public Health
Drinking Water Division
410 Capitol Avenue - MS# 51 WAT
P.O. Box 340308 Hartford, CT 06134
rift Cuii/ievliiul HcaJihy
August 12, 2005
Ms. Anni Loughlin
U.S. EPA New England
One Congress St., Suite 1100 (HBT)
Boston, MA, 02114-2023
RE: EPA's Proposed Plan - Durham Meadows Superfund Site
Dear Ms. Loughlin:
Thank you for the opportunity to provide comments on the proposed plan to provide public drinking water to the
contaminated areas within the Town of Durham. We find that the best option for the provision of public drinking
water to 85 homes is the extension of the City of Middletown Water Department's (MWD) public water system.
An obstacle to the otherwise excellent solution is the issue of MWD having an abundant supply of water in
existence for the next ten years as required in order for MWD to sell water to the town of Durham. The City of
Middletown Water Department is presently moving to increase their public water system safe daily yield, With
these planned increases, the MDW would have sufficient supplies to meet the projected water demands of the 85
homes within the Town of Durham.
The attached report outlines a number of permitting requirements and identifies exclusive services area issues that
need to be specifically addressed between the MWD and the Town of Durham. The Drinking Water Section
encourages the Town of Durham and MWD to discuss these concerns and work together to address these
identified items. It is also recognized that the Town of Durham town center system is actively pursuing additional
sources of public drinking water located south of Allyn Brook. It is envisioned that the Town of Durham Center
System would eventually interconnect with the water system mains north of Allyn Brook to provide a cohesive
public drinking water system throughout the developed corridor of the Town of Durham. This type of
interconnected system would provide dual sources of supply for the Durham customers as well as fire protection.
Again, thank you for the opportunity to provide comments. We offer our technical assistance to your agency as it
concerns the provision of public drinking water to Durham. Please do not hesitate to contact me directly
concerning any of the above comments.
Lori J. Mathieu, Supervisor
Source Water Protection Unit
Drinking Water Section
cc; Dr, Gerald I wan, Chief DWS
Honorable Maryann Board, First Selectman Town of Durham
Guy Kusso, Director of Public Works Town of Middletown
Michael Hage, DWS Section Supervisor Compliance
Steve Messer, DWS
Betsey Wingfeld, DEP
Martin Beskind, DEP
Dr. Bradford Wilkinson, Acting Director of Health Middletown
Dr. Joseph A, Havlicek, Director of Health Durham
Sincerely,
-------
Subject: Review of USEPA Proposed Plan
Durham Meadows Superfund Site
From: Darrelt B. Smith
Date: August 10, 2005
A review of USEPA's proposed plan dated July 2005 for the Durham Meadows Superfund Site
in Durham, CT highlights the following preferred alternatives for addressing present and future
environmental conditions and the provision of drinking water to residences in the affected area:
• Connection with the Middletown Water Department (MWD) for approximately 85
residences in the affected area. The homes to be connected include a buffer zone
containing 50 homes beyond the current 35 residences with contaminated groundwater,
• Soil excavation with off-site disposal in and around the Merriam Manufacturing
Company property including soil vapor extraction at the Merriam site;
• Soil excavation with off-site disposal at the Durham Manufacturing Company property;
• Continued monitoring of the overall affected area to ensure that the migration of
contaminated groundwater beyond its current general boundary is not occurring;
• Implementation of a Technical Impracticability Waiver for the superfund site because the
bedrock geology indicates that groundwater remediation in a reasonable timeframe is
impracticable and because of current technological limitations;
• Establishment of institutional controls, such as by-laws, deed restrictions, or some other
mechanism, that would prevent unrestricted future use of certain areas of the superfund
site area or contaminated groundwater;
• Further characterization of areas posing potential indoor air risks with additional actions
to be taken as deemed necessary.
Connection of the affected homes to the MWD system via a main extension appears to be a
reasonable and prudent approach, however, it should be recognized that:
1, The superfund site is within the Town of Durham's Exclusive Service Area,
Therefore, Durham would have to either relinquish a portion of its exclusive
service area to Middletown or develop an agreement with the MWD for the
purchase of excess water pursuant to Connecticut General Statute (CGS) 22a-358;
2, Per CGS 22a-358, MWD must be able to demonstrate that it has water reserves in
excess of those required to maintain an abundant supply of water to the
inhabitants of its service area, such system may sell such excess water to any
other public water system upon approval of the Commissioner of Public Health.
Such approval shall be given only after (1) the applicant has clearly established to
the satisfaction of the commissioner that such abundant supplies are in existence
and will continue to be in existence for ten years, and (2) the purchasing
community water system being supplied has agreed to restrict water usage in the
same manner as the applicant when necessary in accordance with the emergency
contingency provisions of the applicant's water supply plan.
3, If MWD intends to sell water to Durham, they should perform an analysis to
establish that abundant supplies are in existence and will continue to be in
-------
Durham Meadows Superfund Site
August 10,2005
Page 2
existence for the 10-year period between 2006 and 2016 to ensure compliance
with CGS 22a-358.
4, The MWD will be required to submit a Water Main Application for the proposed
water main extension. Moreover, DWS recommends that the water main be sized
to serve additional customers beyond the 85 residences in the superfund area in
the event additional contamination occurs beyond the present area of concern.
Fire protection needs also be considered .
It should also be recognized that the Town of Durham is in the process of developing a new
drinking water source for the Durham Center Water System (DCW) to serve approximately 30
customers. Based on an agreement reached with the Durham Fair Association earlier this year,
the DCW system will connect two existing sand and gravel wells to a planned treatment station
and storage facility that is expected to go on-line by the end of 2005. Combined pumping
capacity of the two wells is expected to be in the range of 80 to 100 gallons per minute (gpm)
pending the outcome of an updated yield test. The Fairground Wells are located approximately
1,500 feet west of Main Street (RT 17) within the Durham Meadows and about 1,200 feet south
along Main Street from the trichloroethylene isocontour boundary line shown on Figure 4.3-12 in
the USEPA's July 2005 Proposed Plan.
It should be noted that the Fairground wells are also <1,000 feet south of Allyn Brook.
Moreover, the straight-line distance from the Fairground wells to the inferred trichloroethylene
isocontour line shown on Figure 4.3-12is approximately 1,200 feet. This isocontour line crosses
Maple Avenue northeast of the Fairground wells near its intersection with Old Cemetery Road,
Since very little monitoring data currently exists for the contaminants associated with the
superfund sites south of Allyn Brook, the DWS recommends that the USEPA consider the
placement of monitor wells on the south side of Allyn Brook, or at other more-appropriate sites,
to ensure that contaminated groundwater is not migrating towards the Fairground wells and
nearby homes south of the brook.
S:\SWP UnitYWell Siting'Durham' Durham SuperFuml_Comments_08_ 10 05.doc
-------
Record of Decision
Appendices
Appendix E
Glossary of Acronyms
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30, 2005
Appendices
-------
Record of Decision
Appendices
Acronyms:
1.1-DCE 1,1-Dichloroethene
1.2-DCE 1,2-Diehloroethene
1,1,1 -TCA 1,1,1 -trichloroeihane
AOC Administrative Order by Consent
ARAR Applicable or Relevant and Appropriate Requirements
bgs Below ground surface
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
of 1980
cis-1,2-DCE Cis-1,2-Dichloroethene
COC Chemicals of Concern
COPC Contaminant of Potential Concern
CSM Conceptual Site Model
CSF Cancer Slope Factors
CT DEP Connecticut Department of Environmental Protection
CT RSR Connecticut Remediation Standard Regulations
DEC Direct Exposure Criteria
1.1-DCE 1,1-Dichloroethene
1.2-DCE 1,2-Dichloroethene
DMC Durham Manufacturing Company
DNAPL Dense Non-aqueous Phase Liquid
EDI Estimated Daily Intake
ELUR Environmental Land Use Restriction
EPC Exposure Point Concentration
EPA United States Environmental Protection Agency
ETPH Ex tractable Total Petroleum Hydrocarbons
FS Feasibility Study
HI Hazard Index
HQ Hazard Quotient
KoC Organic Carbon Partition Coefficient
LB&G Leggette, Brashears & Graham
M&E Metcalf & Eddy
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goals
MMC Merriam Manufacturing Company
O&M Operation and Maintenance
NCP National Oil and Hazardous Substances Pollution Contingency Plan
ORNL Oak Ridge National Laboratory
PAH Polycyclic Aromatic Hydrocarbons
PCB Polychlorinated Biphenyls
PCE Tetrachlorocthene (or tetrachloroethylene or perchloroethylene)
ppb Parts per billion
PMC Pollutant Mobility Criteria
PND Cooling Water Pond
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version; FINAL
Date; September 30, 2005
Appendices
-------
Record of Decision
Appendices
PRP
RAO
RBG
RCRA
RfC
RfD
RI
RI/FS
ROD
RME
RSR
SLERA
SPLP
SWPC
SVE
svoc
TCA
TCE
TRV
UF
USGS
UST
VC
VOC
Potentially Responsible Party
Response Action Objectives
Risk-Based Goals
Resource Conservation and Recovery Act
Reference Concentrations
Reference Doses
Remedial Investigation
Remedial Investigation and Feasibility Study
Record of Decision
Reasonable Maximum Exposure
Remediation Standard Regulations
Screening-Level Ecological Risk Assessment
Synthetic Precipitation Leaching Procedure
Surface Water Protection Criteria
Soil Vapor Extraction
Semi-Volatile Organic Compound
1,1,1 -Trichloroethane
Trichloroethene (or trichloroethylene)
Toxicity Reference Value
Uptake Factors
United States Geological Survey
Underground Storage Tank
Volatilization Criteria
Volatile Organic Compound
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version; FINAL
Date; September 30,2005
Appendices
-------
Record of Decision
Appendices
Appendix F
ARARs Tables
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version; FINAL
Date: September 30, 2005
Appendices
-------
Table F-1
Chemical Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Authority
Medium
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Federal
Groundwater
Safe Drinking
Water Act
(SDWA)
Maximum
Contaminant
Levels
40CFR
§141.11-
141.16
Relevant
and
Appropriate
Maximum Contaminant
Levels (MCLs) have been
promulgated for a number of
common organic and
inorganic chemicals. These
levels regulate the
concentration of these
chemicals in public drinking
water supplies, but may also
be considered relevant and
appropriate for groundwater
aquifers used for drinking
water.
Groundwater impacted by the
Site is a current drinking water
source, with private wells in
use. Contaminants are present
in groundwater in
concentrations that exceed
MCLs. Remedial action to
provide an alternative water
supply will be implemented with
the goal of meeting MCLs.
The presence of NAPL,
however, makes it technically
impracticable to reduce
contaminant concentration in
groundwater to MCLs in the "Tl
Zone" for Site-wide
groundwater. The Tl Zone is
shown on Figure 1-1 of the
Record of Decision.
Federal
Groundwater
and Soil
EPA Risk
Reference
Doses (RfDs)
To Be
Considered
RfDs are dose levels
developed in estimating non-
carcinogenic effects of
exposures to toxic
substances.
Non-carcinogenic risks from
exposure to Site contaminants
of concern were evaluated and
used to help determine the
need for remedial action and
develop preliminary
remediation goals where
necessary.
Page 1 of 4
-------
Table F-1
Chemical Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Authority
Medium
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Federal
Groundwater
and Soil
EPA
Carcinogenicity
Slope Factor
To Be
Considered
Slope factors are developed
by EPA from health effects
assessments. Carcinogenic
effects present the most up-
to-date information on cancer
risk potency. Potency factors
are developed by EPA from
Health Effects Assessments
of evaluation by the
Carcinogenic Assessment
Group.
Risks due to carcinogens as
assessed with slope factors
were used to help determine
the need for remedial action
and develop preliminary
remediation goals, where
necessary.
Page 2 of4
-------
Table F-1
Chemical Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Authority
Medium
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
State
Groundwater
Connecticut
Remediation
Standards
Regulations
(RSRs)
RCSA
§§22a-133k
(Appendices
C and D)
Applicable
These standards establish
remediation standards for
groundwater and surface
water.
Contaminants are present in
groundwater in concentrations
that exceed RSRs applicable to
GA areas.
The presence of NAPL, makes
it technically impracticable to
meet RSRs in the "Tl Zone" for
Site-wide groundwater, and
therefore, no active engineering
remedy will be implemented.
The TI Zone is shown on Figure
1-1 of the Record of Decision.
A monitoring well network will
better define the outer extent of
the TI Zone and confirm that
the plume does not migrate to
areas not currently affected by
groundwater contamination.
Excavation of soli from the
most contaminated areas of the
MMC and DMC Study Areas
will eliminate an ongoing
source of groundwater
contamination.
Page 3 of4
-------
Table F-1
Chemical Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Authority
Medium
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
State
Soil
Connecticut
Remediation
Standards
Regulations
{RSRs)
RCSA
§§22a-133k
(Appendices
A and B)
Varies
These standards establish
remediation standards for
soil.
Contaminants are present in
Site soil in concentrations that
exceed direct exposure ("DEC")
and/or pollutant mobility criteria
("PMC").
At the MMC Study Area, the
DECs and the PMCs are
applicable The selected
remedy for the MMC Study
Area involves treatment of
VOCs in soil and soil vapor by
soil vapor extraction along with
excavation of soil with
remaining contamination
(metals, PAHs, VOCs).
At the DMC Study Area the
DECs are not ARARs because
there is no direct contact risk to
soils. At the DMC Study Area
the PMCs are neither
applicable nor appropriate
because there is no direct
contact risk from soil and
cleanup of the groundwater is
technically impracticable.
Excavation from the most
contaminated areas of the DMC
Study Area will remove all soils
exceeding DECs and PMCs,
however.
Page 4 of 4
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Federal
USEPA
Memorandum,
"Policy ori
Floodplains and
Wetland
Assessments for
CERCLA
Actions"
Aug. 6, 1985
To Be
Considered
The memorandum details
situations that would require
preparation of floodplains or
wetlands assessments and the
factors which should be
considered in preparing an
assessment for actions taken
under 104 or 106 of CERCLA,
Design of excavation remedies for
the MMG and DMC Study Areas
will need to consider the potential
for disturbance of the wetland or
floodplains bordering the study
areas to the east, and mitigate
any disturbance accordingly. A
habitat and floodplain assessment
will be conducted as part of pre-
remedial design studies to
determine if resource areas are
impacted.
Page 1 of 6
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Federal Clean
Water Act (CWA)
Regulations
governing dredge
and fill activities
in wetlands—
Section 404
33 USC 1344
40 CFR Part 230
33 CFR Parts 320-
323
Applicable
Discharge of dredged or fill
material is prohibited to wetlands
or other US waters if there is a
practical alternative which would
have less adverse impact to the
aquatic ecosystem, as long as the
alternative does not have other
significant impacts.
Design of excavation remedies for
the MMC and DMC Study Areas
will need to consider potential for
disturbance of the wetland
bordering the study areas to the
east, and mitigate any disturbance
accordingly. Filling of potential
wetland areas to the east of the
MMC Study Area is not
anticipated. Any removal of
contaminated wetland soil at the
DMC Study Area will need to
comply with the substantive
requirements of the CWA permit
process for discharge of fill
material to a wetland, A habitat
assessment will be conducted as
part of pre-remedial design
studies if resource areas are
impacted. Due to the high levels
of contamination, there may be no
practicable alternative to
disturbing wetlands. If wetlands
disturbance occurs, compensatory
measures will be required.
Fish and Wildlife
Coordination Act
16 U.S.C. 661
Applicable
This order protects fish and
wildlife when federal actions result
in control or structural modification
of a natural stream or body of
water.
If the construction of the water
main extension or alternative
water source has the potential to
modify a stream or potentially
affect fish or wildlife, the U.S. Fish
and Wildlife Service will be
consulted.
Page 2 of 6
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Floodplain
Management
Executive Order
E.O, 11988
Relevant and
Appropriate
Federal agencies are required to
avoid any action in floodplains if
there Is a practicable alternative.
Design of excavation remedies for
the MMC and DMC Study Areas
will need to consider the potential
for disturbance of floodplains.
Due to high levels of
contamination, there may be no
practicable alternative to taking
action in floodplains. Any work in
floodplains will comply with the
substantive provisions of the
Executive Order. Compensatory
flood storage will be provided if
necessary.
Page 3 of 6
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Protection of
Wetlands
Executive Order
E.O.11990
Relevant and
Appropriate
Federal agencies are required to
avoid construction in wetlands is
there is a practicable alternative.
Design of excavation alternatives
for the MMC and DMG Study
Areas will need to consider
potential for disturbance of the
wetland bordering the study areas
to the east, and mitigate any
disturbance accordingly. Filling of
potential wetland areas to the east
of the MMC Study Area is not
anticipated. Any removal of
contaminated wetland soil at the
DMC Study Area will need to
comply with the substantive
requirements of the Executive
Order. A habitat assessment will
be conducted as part of pre-
remediat design studies if
resource areas are impacted.
Due to the high levels of
contamination, there may be no
practicable alternative to
disturbing wetlands. If wetlands
disturbance occurs, compensatory
measures will be required.
Page 4 of 6
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
National Historic
Preservation Act
arid Regulations
16 USC 470f
36 CFG Part 800
Relevant and
Appropriate if
there is a
potential for
historic
properties
Adoption of prudent and feasible
measures to eliminate, minimize,
and mitigate impacts on historic
properties.
Prior to any disturbance or
excavation, a review of potential
impacts to historic properties will
be conducted, including any
engineering controls to mitigate
indoor air risks in residences.
State
Inland Wetland
and
Watercourses Act
and Inland
Wetlands and
Watercourses
Regulations
CGS §§22a-36
through 45
RGSA §§22a-39-1
to 15
Applicable
These statutes and regulations
regulate any operation in or
affecting an inland wetland or
watercourse involving removal or
deposition of material or any
obstruction, construction,
alteration or pollution of such
wetlands. Consult local wetlands
regulations for substantive
requirements.
Design of excavation remedies for
the MMC and DMC Study Areas
will need to consider potential for
disturbance of the wetland
bordering the study areas to the
east, and mitigate any disturbance
accordingly. Filling of potential
wetland areas to the east of the
MMC Study Area is not
anticipated. Any removal of
contaminated wetland soil at the
DMC Study Area will need to
comply with the substantive
requirements of this act. Local
wetland regulations would be
consulted for any alternative
involving potential disturbance of
the wetland east of the MMC and
DMC study areas.
Page 5 of 6
-------
Table F-2
Location Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of Requirement
Action Taken to Attain ARAR
Flood
Management
Regulations
RCSA §§25-68h-1
through 25-68h-3
Applicable
These regulations govern
activities in flood plains to
minimize flood risk and prevent
flood hazards.
Design of excavation remedies for
the MMC and DMC Study Areas
will need to consider the potential
for disturbance of floodplains.
Any work in flood plains will
comply with the substantive
provisions of the regulations.
Compensatory flood storage will
be provided if necessary.
Page 6 of 6
-------
Table F-3
Action Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of
Requirement
Action Taken To Attain ARAR
Federal Clean Air Act National
Emissions Standards for
Hazardous Air Pollutants
(NESHAPs)
40 CFR 61
Relevant and
Appropriate
Establishes point source
standards for eight pollutants:
mercury, asbestos, beryllium,
vinyl chloride, benzene,
arsenic, radionuclides, and
Radon 222.
The SVE system will include emissions control
in the form of vapor-phase granular activated
carbon. Monitoring will be performed to verify
effectiveness of carbon for removal of VOCs
from the air.
Federal RCRA Air Emissions
Standards for Process Vents
40 CFR 264 Subpart
AA
Applicable
if threshold
levels are
met.
These regulations specify air
discharge levels for certain
organic treatment processes
(e.g. SVE systems).
The SVE system will include emissions
control in the form of vapor-phase granular
activated carbon. Monitoring will be
performed to verify effectiveness of carbon for
removal of VOCs from the air.
Federal RCRA Air Emission
Standards for Equipment Leaks
40 CFR 264 subpart
BB
Applicable
if threshold
levels are
met.
Standards for air emissions
for equipment that contains
or contacts hazardous
substances with organic
concentrations of at least
10% by weight.
The SVE system will include emissions
control in the form of vapor-phase granular
activated carbon. Monitoring will be
performed to verify effectiveness of carbon for
removal of VOCs from the air.
Federal RCRA Air Emission
Standards for Tanks
40 CFR 264 subpart
CC
Relevant
and
Appropriate
if threshold
levels are
met
Standards for air emissions
from tanks that manage
certain levels of hazardous
substances.
The SVE system will include emissions
control in the form of vapor-phase granular
activated carbon. Monitoring will be
performed to verify effectiveness of carbon for
removal of VOCs from the air.
Page 1 of 4
-------
Table F-3
Action Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of
Requirement
Action Taken To Attain ARAR
Clean Water Act NPDES
Regulations (Stormwater
Discharges)
40CFR
122.26(c)(ii)(C)
40CFR 122.44(k)
40CFR 125.100- .104
Applicable
Discharges of stormwater
associated with construction
activities are required to
implement measures,
including best management
practices, to control
pollutants in stormwater
discharges during and after
construction activities.
Remedial construction (e.g., soil excavation,
water main installation, SVE system
installation) will be designed and
implemented to comply with these
requirements, such as best management
practices.
Connecticut Soil Vapor
Remediation Standards
Regulations (RSRs)
RCSA §§22a-133k-
3(c)
Applicable
These standards establish
volitalizatlon criteria to
address volatile organic
substances in groundwater
and soil vapor.
For areas where data show the potential for
an unacceptable indoor inhalation risk,
remedial actions (e.g., sub-slab
depressurization systems) will be applied, as
needed, so as to comply with the substantive
provisions of these regulations.
Proposed Revisions -
Connecticut's Remediation
Standard Regulations
Volatilization Criteria, March
2003
Proposed Revisions to
portions of RCSA
§§22a-133k-1 through
3
To Be
Considered
These revisions detail how
volatilization criteria are
calculated and how revised
transport models, updated
risk information, and
volatilization criteria are
applied. These proposed
standards also establish
revised target indoor air
concentrations and revised
volatilization criteria for
groundwater and soil vapor
for many volatile
contaminants.
These proposed criteria were considered, in
conjunction with the site-specific risk
assessment that includes the vapor intrusion
pathway, in evaluating the need for remedial
action and in setting target cleanup levels for
contaminants in Site groundwater. These
standards are used to help develop target
cleanup levels for the design of remedial
alternatives for soil vapor. These standards
will be considered in future evaluations of
vapor intrusion.
Page 2 of 4
-------
Table F-3
Action Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
Status
Synopsis of
Requirement
Action Taken To Attain ARAR
Comparison Value
Determination for 1,4-Dioxane in
Drinking Water
CT Dept. of Public
Health,
Division of Environ-
mental & Occupational
Health Assessment
March 2004
To Be
Considered
This document establishes a
drinking water comparison
value of 20 ug/L for 1,4-
dioxane. This interim value
will be re-visited by USEPA's
IRIS review of this
compound.
This value was considered in evaluating the
need for remedial action. Remedial action to
provide an alternative water supply from
Middletown will be implemented with the goal
of attaining this value in drinking water.
Connecticut Air Pollution Control
Regulations
RCSA22a-174
Sections 3a, 18b, 20,
23,29
Applicable
This section requires permits
to construct and operate
stationary sources of
emissions, and requires
those sources to meet
specified standards. Pollution
abatement controls may be
required. Specific standards
are listed for many pollutants.
Active gas collection systems
with emissions controls may
be required.
The SVE system will include emissions
control in the form of vapor-phase granular
activated carbon. Monitoring will be
performed to verify effectiveness of carbon for
removal of VOCs from the air. The
substantive requirements of the permit
process would be met. Storage of VOCs will
meet the provisions of Section 20 if a storage
tank of 250 gallons or greater is used, or the
VOC has a vapor pressure of 1.5 psi or
greater.
Hazardous Waste Management:
Generator & Handler
Requirements- General
Standards, Listing &
Identification
RCSA 22a-449(c) 100-
101
Applicable
These sections establish
standards for listing and
identification of hazardous
waste. The standards of 40
CFR §§260-261 are
incorporated by reference.
Chromium is not exempted
from listing as a hazardous
waste.
Wastes that may be generated during
implementation of an alternative (e.g., spent
carbon, recovered NAPL) will undergo testing
for RCRA characteristics to determine
appropriate the waste classification and
disposal options.
Page 3 of 4
-------
Table F-3
Action Specific ARARs for Remedial Actions
Durham Meadows Superfund Site
Requirement
Citation
*5tsitu^s
Synopsis of
Requirement
Action Taken To Attain ARAR
Hazardous Waste Management:
Generator Standards
RCSA 22a-449(c) 102
Applicable
This section establishes
standards for various classes
of generators. The standards
of 40 CFR §262 are
incorporated by reference.
Storage requirements given
at 40 CFR §265.15 are also
included.
On-site storage of wastes determined to be
RCRA hazardous (listed or characteristic) will
comply with these requirements. This
alternative applies to excavated solvent-
contaminated soil and to treatment residuals
determined to be RCRA hazardous.
Control of Noise
RCSA §22a- 69-1 to
69-7,4
Applicable
These regulations establish
allowable noise levels; and
would apply to construction
activities at the site
All remedial construction activities will comply
with these regulations.
CT Guidelines for Soil Erosion
and Sediment Control (May
2002)
adopted pursuant to
CGS22a-328
To Be
Considered
The Guidelines provide
technical and administrative
guidance for the
development, adoption and
implementation of erosion
and sediment control
program.
Remedial construction (e.g., soil excavation,
water main installation, SVE system
installation) will be designed and
implemented to comply with these guidelines.
Page 4 of 4
-------
Record of Decision
Appendices
Appendix G
Administrative Record Index
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30,2005
Appendices
-------
Durham Meadows
NPL Site Administrative Record
Record of Decision (ROD)
Index
September 2005
Prepared by
EPA New England
Office of Site Remediation & Restoration
-------
Introduction to the Collection
This is the Administrative Record for the Durham Meadows Superfund site, Durham, CT, Entire
Site, Record of Decision (ROD), released September 2005. The file contains site-specific
documents and a list of guidance documents used by EPA staff in selecting a response action at
the site.
This file replaces the Proposed Plan for Record of Decision Administrative Record released in
July 2005.
The administrative record file is available for review at:
Durham Public Library
7 Maple Avenue
Durham, CT 06422
(860)349-9544 (phone)
(860) 349-9853 (fax)
http://www.lioninc.org/durham/
EPA New England Superfund Records & Information Center
1 Congress Street, Suite 1100 (HSC)
Boston, MA 02114 (by appointment)
617-918-1440 (phone)
617-918-1223 (fax)
http://www.epa.gov/region01/superfund/resource/records.htm
Questions about this administrative record file should be directed to the EPA New England site
manager.
An administrative record file is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
Instructions about PDF
The documents in this collection are available as a Portable Document Format (PDF) file. The
PDF process maintains the look and presentation of the original document. To view PDF files,
you will need Adobe Acrobat Reader software loaded on your computer. This software is
available, free of charge, from Adobe Software [this is a link to http://www.adobe.com1. To
ensure you will be able to see a PDF file in its entirety, please obtain the most recent version of
the free Adobe Reader from the Adobe Web site.
(http://www.adobe.com/products/acrobat/readstep.htmn
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 1 of 33
03: REMEDIAL INVESTIGATION (RI)
67293 EVALUATION AND IN-DEPTH STUDY OF FRANK W STRING SCHOOL CONDITIONS (03/22/99
NOTIFICATION LETTER ATTACHED)
Author: CHARLES J NAFIE & ASSOCIATES
Addressee: DURHAM (CT) TOWN OF
Doc Type: REPORT
Doc Date: 01/01/0001
File Break: 03.01
67269 PRELIMINARY HEALTH ASSESSMENT
Author: US AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR)
Addressee:
Doc Type: REPORT
Doc Date: 06/01/1990
File Break: 03.09
67277 LETTER REGARDING 11/01/90 SAMPLING AND ANALYSIS RESULTS AT MERRIAM MANUFACTURING
COMPANY (MAP AND SUMMARY TABLE ATTACHED)
Author: CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee:
Doc Type: LETTER
Doc Date: 12/04/1990
File Break: 03 .02
67294 DATA SUMMARY REPORT START INITIATIVE
Author: METCALF AND EDDY, INC Doc Date: 04/01/1994
Addressee: US EPA REGION 1 File Break: 03.04
Doc Type: REPORT
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 2 of 33
03: REMEDIAL INVESTIGATION (RI)
67281 WATER-RESOURCES INVESTIGATIONS REPORT - GEOHYDROLOGY AND WATER QUALITY OF
DURHAM CENTER AREA, DURHAM, CONNECTICUT
Author: US GEOLOGICAL SURVEY
Addressee:
Doc Date: 01/01/1995
File Break: 03 .06
Doc Type: REPORT
67261 HEALTH CONSULTATION
Author: CT DEPT OF PUBLIC HEALTH
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 04/19/1995
File Break: 03.09
67262 HEALTH CONSULTATION
Author: US AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR)
Addressee: us EpA REGION 1
Doc Type: REPORT
Doc Date: 09/29/1995
File Break: 03.09
67265 DRAFT, WORK PLAN FOR CONDUCTING REMEDIAL INVESTIGATION AND FEASIBILITY STUDY (RI/FS)
Author: LEGGETTE BRASHEARS & GRAHAM INC
Addressee:
DURHAM MANUFACTURING CO
Doc Type: WORK PLAN
Doc Date: 09/01/1997
File Break: 03 .07
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 3 of 33
03: REMEDIAL INVESTIGATION (RI)
67257 SAMPLING DATA FOR PUMP TEST AT DURHAM FAIRGROUNDS (LETTER AND 06/17/05 FAX
TRANSMITTAL ATTACHED)
Author: HYDRO DYNAMIC ENGINEERING
Addressee:
SIMA DRILLING CO INC
Doc Type: SAMPLING & ANALYSIS DATA
Doc Date: 05/10/1999
File Break: 03.01
67266 DRAFT DATA REPORT
Author: LEGGETTE BRASHEARS & GRAHAM INC
Addressee:
DURHAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 08/01/1999
File Break: 03 .02
67259 DRAFT, DURHAM WATER SYSTEM EXTENSION FEASIBILITY STUDY (FS)
Author: FUSS & ONEILL INC
Addressee: DURHAM (CT) TOWN OF
Doc Type: REPORT
Doc Date: 05/01/2000
File Break: 03.01
67283 DRAFT, PRELIMINARY WATER SYSTEM STUDY-DURHAM CENTER SYSTEM
Author: FUSS & ONEILL INC
Addressee:
Doc Type: REPORT
Doc Date: 05/09/2002
File Break: 03.01
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10/5/2005
Page 4 of 33
03: REMEDIAL INVESTIGATION (RI)
67270 REQUEST FOR PUBLIC HEALTH REVIEW
Author: US EPA REGION 1
Addressee: us AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR)
Doc Type: MEMO
67278 PLAN OF CONSERVATION AND DEVELOPMENT
Author: DURHAM (CT) TOWN OF
Addressee:
Doc Type: REPORT
233866 DRAFT, REUSE ASSESSMENT
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
67282 HEALTH ASSESSMENT - COMPARISON VALUE DETERMINATION FOR 1,4-DIOXANE IN DRINKING
WATER
Author: CT DEPT OF PUBLIC HEALTH
Addressee:
Doc Type: REPORT
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 01/06/2003
File Break: 03.09
Doc Date: 03/01/2003
File Break: 03.01
Doc Date: 09/30/2003
File Break: 03 .04
Doc Date: 03/01/2004
File Break: 03.09
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 5 of 33
03: REMEDIAL INVESTIGATION (RI)
67267 REMEDIAL INVESTIGATION (RI) REPORT
Author: LEGGETTE BRASHEARS & GRAHAM INC
Addressee:
DURHAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 01/01/2005
File Break: 03 .06
67251 2004 ANNUAL GROUND WATER AND SOIL VAPOR QUARTERLY MONITORING REPORT (03/17/05
TRANSMITTAL LETTER ATTACHED)
Author: ADVANCED ENVIRONMENTAL INTERFACE INC
Addressee: REGIONAL SCHOOL DISTRICT # 13 (DURHAM, CT)
Doc Type: REPORT
Doc Date: 02/01/2005
File Break: 03.01
67279 DURHAM ZONING REGULATIONS
Author: DURHAM (CT) TOWN OF
Addressee:
Doc Type: REPORT
Doc Date: 02/01/2005
File Break: 03.01
67284 DRAFT FINAL BASELINE HUMAN HEALTH RISK ASSESSMENT REPORT
Author: METCALF & EDDY
Addressee:
Doc Type: REPORT
Doc Date: 06/01/2005
File Break: 03.09
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10/5/2005
Page 6 of 33
03: REMEDIAL INVESTIGATION (RI)
67310 DRAFT FINAL REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 2
Author: METCALF & EDDY
Addressee:
Doc Type: REPORT
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 06/01/2005
File Break: 03 .06
67311 DRAFT FINAL TECHNICAL IMPRACTICABILITY EVALUATION REPORT
Author: METCALF & EDDY Doc Date: 06/01/2005
File Break: 04.06
Addressee: us EpA REGION 1
Doc Type: REPORT
67312 DRAFT FINAL REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 1
Author: METCALF & EDDY
Addressee:
Doc Type: REPORT
Doc Date: 06/01/2005
File Break: 03 .06
67316 GROUND WATER USE AND VALUE DETERMINATION (07/06/05 TRANSMITTAL LETTER, 07/05/05
CONCLUSIONS AND RECOMMENDATIONS, MAPS ATTACHED)
Author: CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee:
Doc Type: REPORT
Doc Date: 06/30/2005
File Break: 03 .04
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
03: REMEDIAL INVESTIGATION (RI)
67325 SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT
Author: US EPA REGION 1 Doc Date: 06/30/2005
Addressee:
File Break: 03.10
Doc Type: REPORT
236700 FINAL REPORT INDOOR AIR SAMPLING STUDY, MAY 2005, APPENDIX A, LABORATORY ANALYTICAL
REPORT
Author: US EPA REGION 1 Doc Date: 06/30/2005
Addressee:
File Break: 03 .04
Doc Type: REPORT
238274 DRAFT FINAL REMEDIAL INVESTIGATION REPORT, APPENDIX D-3, ADDENDUM, WATER SUPPLY WELL
DATA
Author: METCALF & EDDY Doc Date: 09/21/2005
Addressee: US EPA REGION 1 File Break: 03.06
Doc Type: REPORT
238275 CLARIFICATION REGARDING APPENDIX D-3 ADDENDUM TO THE DRAFT FINAL REMEDIAL
INVESTIGATION REPORT
Author: ANNI LOUGHLIN US EPA REGION 1 j>oc Date; 09/27/2005
Addressee:
File Break: 03 .06
Doc Type: MEMO
10/5/2005
Page 7 of 33
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AR Collection: 3710 10/5/2005
ROD ADMIN RECORD FOR DURHAM Page 8 of 33
AR Collection QA Report
***For External Use***
04: FEASIBILITY STUDY (FS)
67323 WORK PLAN AMENDMENT AND COST TO COMPLETE ANALYSIS FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) OVERSIGHT
Author: METCALF & EDDY Doc Date: 04/01/2003
Addressee:
File Break: 04.07
Doc Type: REPORT
67322 SAMPLING AND ANALYSIS PLAN (FIELD SAMPLING PLAN AND QUALITY ASSURANCE PROJECT PLAN
(QAPP)) FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
Author: METCALF & EDDY Doc Date: 06/01/2004
Addressee:
File Break: 04.04
Doc Type: REPORT
67313 DRAFT FINAL FEASIBILITY STUDY (FS) REPORT
Author: METCALF & EDDY
Addressee:
Doc Type: REPORT
Doc Date: 06/01/2005
File Break: 04.06
67309 MEMO REGARDING DETAILED EVALUATION OF COMBINATIONS OF SPECIFIC REMEDIAL
ALTERNATIVES (TABLES ATTACHED)
Author: METCALF & EDDY Doc Date: 06/29/2005
Addressee: US EPA REGION 1 File Break: 04.02
Doc Type: MEMO
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10/5/2005
Page 9 of 33
04: FEASIBILITY STUDY (FS)
67326 PROPOSED PLAN
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
237193 TRANSMITTAL OF PROPOSED PLAN ON CD-ROM
Author: ANNI LOUGHLIN US EPA REGION 1
Addressee: RICHARD H PATTERSON DURHAM MANUFACTURING CO
Doc Type: TETTER
237194 TRANSMITTAL OF PROPOSED PLAN ON CD-ROM
Author: ANNI TOUGHTIN US EPA REGION 1
Addressee: CAROTYN ADAMS ATTAN E ADAMS, ESTATE OF
MERRIAM MANUFACTURING CO
Doc Type: TETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/01/2005
File Break: 04.09
Doc Date: 07/13/2005
File Break: 04.01
Doc Date: 07/13/2005
File Break: 04.01
-------
10/5/2005
Page 10 of 33
05: RECORD OF DECISION (ROD)
237251 E-MAIL CONTAINING COMMENTS ON THE PROPOSED PLAN
Author: DEBORAH R HOYT DURHAM (CT) RESIDENT
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237248 COMMENTS MADE AT THE MEETING ON THE PROPOSED PLAN
Author: ROSA DELAURO US HOUSE OF REPRESENTATIVES
Addressee:
Doc Type: PUBLIC MEETING RECORD
237249 COMMENTS ON THE PROPOSED PLAN
Author: RENEE PRIMUS DURHAM (CT) TOWN OF
Addressee:
Doc Type: PUBLIC MEETING RECORD
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/21/2005
File Break: 05.03
Doc Date: 07/28/2005
File Break: 05.03
Doc Date: 07/28/2005
File Break: 05.03
-------
10/5/2005
Page 11 of 33
05: RECORD OF DECISION (ROD)
237250 COMMENTS ON THE PROPOSED PLAN
Author: MARYANN P BOORD DURHAM (CT) TOWN OF
Addressee: ERNIE A JUDSON DURHAM (CT) TOWN OF
RENEE PRIMUS DURHAM (CT) TOWN OF
ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237247 E-MAIL CONTAINING COMMENTS ON THE PROPOSED PLAN
Author: LISA LARSEN DURHAM (CT) RESIDENT
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: MEMO
237246 COMMENTS ON THE PROPOSED PLAN
Author: GUY P RUSSO MIDDLETOWN (CT) CITY OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/28/2005
File Break: 05.03
Doc Date: 08/04/2005
File Break: 05.03
Doc Date: 08/05/2005
File Break: 05.03
-------
10/5/2005
Page 12 of 33
05: RECORD OF DECISION (ROD)
237236 COMMENTS ON THE RI/FS AND PROPOSED PLAN
Author: KATHLEEN A CYR GZA GEOENVIRONMENTAL INC
Addressee: RICHARD LAMONICA GZA GEOENVIRONMENTAL INC
RICHARD H PATTERSON DURHAM MANUFACTURING CO
Doc Type: LETTER
237237 COMMENTS ON THE PROPOSED PLAN
Author: LORRAINE ETHERIDGE DURHAM (CT) RESIDENT
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237239 COMMENTS ON THE PROPOSED PLAN
Author: DARRELL B SMITH
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: MEMO
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 08/10/2005
File Break: 05.03
Doc Date: 08/10/2005
File Break: 05.03
Doc Date: 08/10/2005
File Break: 05.03
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Page 13 of 33
05: RECORD OF DECISION (ROD)
237245 E-MAIL CONTAINING COMMENTS ON THE PROPOSED PLAN
Author: DONIA VIOLA DURHAM (CT) TOWN OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: MEMO
237235 COMMENTS ON THE PROPOSED PLAN
Author: RICHARD H PATTERSON DURHAM MANUFACTURING CO
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237240 COMMENTS ON THE PROPOSED PLAN
Author: HENRY A ROBINSON DURHAM (CT) TOWN OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237241 E-MAIL TRANSMITTING ELECTRONIC VERSION OF COMMENTS ON THE PROPOSED PLAN
Author: HENRY A ROBINSON DURHAM (CT) TOWN OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 08/10/2005
File Break: 05.03
Doc Date: 08/11/2005
File Break: 05.03
Doc Date: 08/11/2005
File Break: 05.03
Doc Date: 08/11/2005
File Break: 05.03
-------
10/5/2005
Page 14 of 33
05: RECORD OF DECISION (ROD)
237242 STATE'S COMMENTS ON THE PROPOSED PLAN
Author: MICHAEL J HARDER CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee: mary JANE ODONNELL US EPA REGION 1
Doc Type: LETTER
237244 E-MAIL CONTAINING ADDITIONAL COMMENTS ON THE PROPOSED PLAN
Author: DONIA VIOLA DURHAM (CT) TOWN OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: MEMO
237238 COMMENTS ON THE PROPOSED PLAN
Author: LORI MATHIEU CT DEPT OF PUBLIC HEALTH
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: LETTER
237243 E-MAIL CONTAINING COMMENTS ON THE PROPOSED PLAN
Author: JOHN J HORAN DURHAM (CT) TOWN OF
Addressee: ANNI LOUGHLIN US EPA REGION 1
Doc Type: MEMO
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 08/11/2005
File Break: 05.03
Doc Date: 08/11/2005
File Break: 05.03
Doc Date: 08/12/2005
File Break: 05.03
Doc Date: 08/12/2005
File Break: 05.03
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Page 15 of 33
05: RECORD OF DECISION (ROD)
238284 RECORD OF DECISION
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
Doc Type: RECORD OF DECISION
10: ENFORCEMENT/NEGOTIATION
7309 ADMINISTRATIVE ORDER BY CONSENT FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY AND
OTHER WORK DOCKET NO. 1-97-1033
Author: US EPA REGION 1
Addressee:
Doc Type: LITIGATION
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 09/30/2005
File Break: 05 .04
Doc Date: 06/30/1997
File Break: 10.07
11: POTENTIALLY RESPONSIBLE PARTY
67263 SUMMARY OF GROUND-WATER QUALITY INVESTIGATION
Author: LEGGETTE BRASHEARS & GRAHAM INC Doc Date: 10/01/1982
Addressee: DURHAM MANUFACTURING CO File Break- 11.09
Doc Type: REPORT
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 16 of 33
11: POTENTIALLY RESPONSIBLE PARTY
67272 GROUND-WATER INVESTIGATION
Author: ROUX ASSOCIATES
Addressee:
MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 01/01/1983
File Break: 11 09
67264 SUMMARY OF SUBSURFACE INVESTIGATIONS DURING 1982-1993 AT DURHAM MANUFACTURING
COMPANY (06/30/92 LETTER WITH APPENDICES ATTACHED)
Author: LEGGETTE BRASHEARS & GRAHAM INC
Addressee:
DURHAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 01/07/1984
File Break: 11 09
67273 DRAFT, SITE INVESTIGATION (SI) REPORT
Author: ROUX ASSOCIATES
Addressee: MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 09/23/1988
File Break: 11 09
67274 PHASE 2 SITE INVESTIGATION (SI) REPORT, VOLUME 1
Author: ROUX ASSOCIATES
Addressee:
MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 01/22/1990
File Break: 11 09
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 17 of 33
11: POTENTIALLY RESPONSIBLE PARTY
67275 PHASE 2 SITE INVESTIGATION (SI) REPORT, VOLUME 2-APPENDICES
Author: ROUX ASSOCIATES
Addressee:
MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 01/22/1990
File Break: 11 09
67276 ADDENDUM TO PHASE 2 SITE INVESTIGATION (SI) REPORT
Author: ROUX ASSOCIATES
Addressee:
MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 06/20/1990
File Break: 11 09
67285 SOIL GAS SURVEY REPORT
Author: ROUX ASSOCIATES
Addressee: MERRIAM MANUFACTURING CO
Doc Type: REPORT
Doc Date: 10/17/1990
File Break: 11 09
67260 SAMPLING RESULTS FROM MERRIAM MANUFACTURING PROPERTY (09/10/92 TRANSMITTAL LETTER
ATTACHED)
Author: MERRIAM MANUFACTURING CO
Addressee: DURHAM (CT) TOWN OF
Doc Date: 09/01/1992
File Break: 11 09
Doc Type: SAMPLING & ANALYSIS DATA
-------
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
11: POTENTIALLY RESPONSIBLE PARTY
67271 104E INFORMATION REQUEST RESPONSE (PARTIAL RESPONSES ATTACHED)
Author: ROBINSON & COLE LLP Doc Date: 01/07/1994
Addressee: US EPA REGION 1 File Break: 11.09
Doc Type: LETTER
13: COMMUNITY RELATIONS
67320 NOTIFICATION OF PUBLIC INFORMATION MEETING FOR PROPOSED CLEANUP PLAN
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 01/01/0001
File Break: 13.03
67321 MEETING FLYER ANNOUNCEMENT OF PUBLIC INFORMATION MEETING FOR PROPOSED CLEANUP
PLAN
Author: US EPA REGION 1 Doc Date: 01/01/0001
Addressee: , _ _ _
File Break: 13.03
Doc Type: PRESS RELEASE
10/5/2005
Page 18 of 33
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10/5/2005
Page 19 of 33
13: COMMUNITY RELATIONS
67258 FACT SHEET
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
67254 COMMUNITY UPDATE: 1,4 - DIOXANE
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
67255 COMMUNITY UPDATE: EPA TO BEGIN WORK AT FORMER LOCATION OF MERRIAM MANUFACTURING
COMPANY
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
67253 COMMUNITY UPDATE: 1,4 - DIOXANE
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 01/01/1998
File Break: 13.03
Doc Date: 03/01/2004
File Break: 13.03
Doc Date: 05/01/2004
File Break: 13.03
Doc Date: 06/01/2004
File Break: 13.03
-------
10/5/2005
Page 20 of 33
13: COMMUNITY RELATIONS
67256 FACT SHEET (08/15/95 TRANSMITTAL MEMO AND 04/1993 ATSDR FACT SHEET ATTACHED)
Author: CT DEPT OF PUBLIC HEALTH
Addressee:
Doc Type: FACT SHEET
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 08/01/2004
File Break: 13.03
67252 COMMUNITY UPDATE: EPA TO EVALUATE SOIL GAS AND INDOOR AIR
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
Doc Date: 04/01/2005
File Break: 13.03
233373 TRANSMITTAL OF RECORD OF DECISION (ROD) PROPOSED PLAN ADMINISTRATIVE RECORD FILE TO
TOWN REPOSITORY
Author: US EPA REGION 1 Doc Date: 07/01/2005
Addressee: DURHAM (CT) PUBLIC LIBRARY File Break- 13.01
Doc Type: LETTER
237192 TRANSMITTAL OF DOCUMENTS FOR THE PUBLIC INFORMATION REPOSITORY
Author: ANNI LOUGHLIN US EPA REGION 1
Addressee: VALERIE KILMARTIN DURHAM (CT) PUBLIC LIBRARY
Doc Type: LETTER
Doc Date: 07/01/2005
File Break: 13.01
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Page 21 of 33
13: COMMUNITY RELATIONS
67319 PRESS RELEASE: COMPREHENSIVE CLEANUP PLAN PROPOSED
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
237208 COMPREHENSIVE CLEANUP PLAN PROPOSED FOR DURHAM MEADOWS SUPERFUND SITE
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
237212 NOTICE OF PUBLIC MEETING IN MIDDLETOWN PRESS
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
237213 NOTICE OF PUBLIC MEE TING
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/07/2005
File Break: 13.03
Doc Date: 07/07/2005
File Break: 13.03
Doc Date: 07/09/2005
File Break: 13.03
Doc Date: 07/09/2005
File Break: 13.04
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Page 22 of 33
13: COMMUNITY RELATIONS
237207 EPA PLAN GOES PUBLIC
Author: AMY L ZITKA MIDDLETOWN PRESS
Addressee:
Doc Type: NEWS CLIPPING
237211 PUBLIC MEETING HANDOUT
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
237206 EPA: CLEANUP COSTLY; OFFICIALS OUTLINE OPTIONS FOR SUPERFUND SITE
Author: PETER DOWNS HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
237203 SELECTMEN TO PONDER GIFT OF CONTAMINATED LAND
Author: AMY L ZITKA MIDDLETOWN PRESS
Addressee:
Doc Type: NEWS CLIPPING
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/10/2005
File Break: 13.03
Doc Date: 07/12/2005
File Break: 13.04
Doc Date: 07/13/2005
File Break: 13.03
Doc Date: 07/15/2005
File Break: 13.03
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Page 23 of 33
13: COMMUNITY RELATIONS
237204 LAND GIFT STUMPS TOWN
Author: BENJAMIN ALEXANDER-BLOCH HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
237205 EPA OUTLINES PLAN FOR WATER CLEANUP
Author: ROB GLIDDEN TOWN TIMES
Addressee:
Doc Type: NEWS CLIPPING
237201 DURHAM OFFICIALS REJECT PROPERTY GIFT
Author: AMY L ZITKA MIDDLETOWN PRESS
Addressee:
Doc Type: NEWS CLIPPING
237202 LAND OFFER TURNED DOWN; SELECTMEN SAW TOO MANY RISKS
Author: BENJAMIN ALEXANDER-BLOCH HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/15/2005
File Break: 13.03
Doc Date: 07/15/2005
File Break: 13.03
Doc Date: 07/16/2005
File Break: 13.03
Doc Date: 07/16/2005
File Break: 13.03
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13: COMMUNITY RELATIONS
237200 TOWN OF DURHAM BEQUEATHED 281 MAIN STREET
Author: MARYANN P BOORD DURHAM (CT) TOWN OF
Addressee:
Doc Type: NEWS CLIPPING
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/21/2005
File Break: 13.03
237199 EPA TO HOLD PUBLIC HEARING ON CLEAN-UP PLAN FOR THE DURHAM MEADOWS SUPERFUND SITE
IN DURHAM, CT
Author: JODIE RIZZUTO US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
237209 PUBLIC HEARING TRANSCRIPT
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
237210 PUBLIC HEARING HANDOUT
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
Doc Date: 07/26/2005
File Break: 13.03
Doc Date: 07/28/2005
File Break: 13.04
Doc Date: 07/28/2005
File Break: 13.04
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Page 25 of 33
13: COMMUNITY RELATIONS
237196 CORRECTION TO 7/15/2005 REPORT ON PUBLIC COMMENT PROCESS
Author: TOWN TIMES
Addressee:
Doc Type: NEWS CTIPPING
237197 EPA GETS INPUT ON MEADOWS CLEAN-UP PLAN
Author: AMY T ZITKA MIDDTETOWN PRESS
Addressee:
Doc Type: NEWS CTIPPING
237198 AID FOR POLLUTION WORK SOUGHT
Author: PETER DOWNS HARTTORD COURANT
Addressee:
Doc Type: NEWS CTIPPING
237195 PUBLIC HEARING ATTENDEES ASK: 'WHERE'S THE MONEY?'
Author: ROB GTIDDEN TOWN TIMES
Addressee:
Doc Type: NEWS CTIPPING
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/29/2005
File Break: 13.03
Doc Date: 07/29/2005
File Break: 13.03
Doc Date: 07/29/2005
File Break: 13.03
Doc Date: 08/04/2005
File Break: 13.03
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14: CONGRESSIONAL RELATIONS
237228 EPA TAKEOVER OF REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
Author: MARY SANDERSON US EPA REGION 1
Addressee: RICHARD H PATTERSON DURHAM MANUFACTURING CO
Doc Type: LETTER
237252 RESPONSE TO AN E-MAIL DATED 2/9/05, CONCERNING EPA'S TAKING OVER THE RI
Author: MARY SANDERSON US EPA REGION 1
Addressee: RICHARD H PATTERSON DURHAM MANUFACTURING CO
Doc Type: LETTER
237227 DOCUMENTATION OF WHAT EPA HAS RECEIVED FROM DURHAM MANUFACTURING AND IT'S
CONTRACTOR IN RESPONSE TO A REQUEST FOR INFORMATION DATED 2/24/05
Author: MARY SANDERSON US EPA REGION 1
Addressee: RICHARD H PATTERSON DURHAM MANUFACTURING CO
Doc Type: LETTER
237226 PROPOSALS TO ACCELERATE THE CLEANUP PROCESS AND PROVIDE A MORE EQUITABLE SOLUTION
Author: RAYMOND C KALINOWSKI CT HOUSE OF REPRESENTATIVES
Addressee: ROBERT W VARNEY US EPA REGION 1
Doc Type: LETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 02/04/2005
File Break: 14.01
Doc Date: 02/15/2005
File Break: 14.01
Doc Date: 03/04/2005
File Break: 14.01
Doc Date: 04/11/2005
File Break: 14.01
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10/5/2005
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14: CONGRESSIONAL RELATIONS
237224 BACKGROUND ON THE DURHAM MEADOWS SITE AND PROPOSED SOLUTIONS
Author: LARRY MCHUGH MIDDLESEX COUNTY (CT) CHAMBER OF COMMERC
Addressee: ROBERT W VARNEY US EPA REGION 1
Doc Type: LETTER
237225 RESPONSE TO SPECIFIC PROPOSALS IN 4/11/05 LETTER CONCERNING DURHAM MEADOWS SITE
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: RAYMOND C KALINOWSKI CT HOUSE OF REPRESENTATIVES
Doc Type: LETTER
237222 REQUEST FOR EPA REVIEW OF THE DURHAM MEADOWS CASE
Author: ROSA DELAURO US HOUSE OF REPRESENTATIVES Doc Date: 05/12/2005
Addressee: CHRISTOPHER J DODD US SENATE
File Break: 14.01
JOSEPH I LIEBERMAN US SENATE
ROB SIMMONS US CONGRESS
STEPHEN L JOHNSON US EPA - HEADQUARTERS
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 04/25/2005
File Break: 14.01
Doc Date: 04/28/2005
File Break: 14.01
Doc Type: LETTER
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14: CONGRESSIONAL RELATIONS
237223 BACKGROUND ON THE DURHAM MEADOWS SITE AND RESPONSE TO PROPOSED SOLUTIONS
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: LARRY MCHUGH MIDDLESEX COUNTY (CT) CHAMBER OF COMMERC
Doc Type: LETTER
237218 RESPONSE TO 5/12/05 LETTER TO EPA ADMINISTRATOR STEPHEN JOHNSON REGARDING DURHAM
MANUFACTURING AND DURHAM MEADOWS ISSUES
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: CHRISTOPHER J DODD US SENATE
Doc Type: LETTER
237219 RESPONSE TO 5/12/05 LETTER TO EPA ADMINISTRATOR STEPHEN JOHNSON REGARDING DURHAM
MANUFACTURING AND DURHAM MEADOWS ISSUES
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: JOSEPH I LIEBERMAN US SENATE
Doc Type: LETTER
237220 RESPONSE TO 5/12/05 LETTER TO EPA ADMINISTRATOR STEPHEN JOHNSON REGARDING DURHAM
MANUFACTURING AND DURHAM MEADOWS ISSUES
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: rob SIMMONS US CONGRESS
Doc Type: LETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 05/18/2005
File Break: 14.01
Doc Date: 06/01/2005
File Break: 14.01
Doc Date: 06/01/2005
File Break: 14.01
Doc Date: 06/01/2005
File Break: 14.01
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14: CONGRESSIONAL RELATIONS
237221 RESPONSE TO 5/12/05 LETTER TO EPA ADMINISTRATOR STEPHEN JOHNSON REGARDING DURHAM
MANUFACTURING AND DURHAM MEADOWS ISSUES
Author: ROBERT W VARNEY US EPA REGION 1
Addressee: ROSA DELAURO US HOUSE OF REPRESENTATIVES
Doc Type: LETTER
237217 REQUEST FOR EPA ATTENDANCE AT A MEETING TO DISCUSS DURHAM ON-GOING CLEANUP
Author: ROSA DELAURO US HOUSE OF REPRESENTATIVES
Addressee: CHRISTOPHER J DODD US SENATE
JOSEPH I LIEBERMAN US SENATE
ROB SIMMONS US CONGRESS
STEPHEN L JOHNSON US EPA - HEADQUARTERS
Doc Type: LETTER
237233 EXPRESSION OF THANKS FOR MEETING ON 7/21/05 TO DISCUSS DURHAM MANUFACTURING COMPANY
ISSUES
Author: ROSA DELAURO US HOUSE OF REPRESENTATIVES
Addressee: CHRISTOPHER J DODD US SENATE
JOSEPH I LIEBERMAN US SENATE
ROB SIMMONS US CONGRESS
STEPHEN L JOHNSON US EPA - HEADQUARTERS
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 06/01/2005
File Break: 14.01
Doc Date: 07/15/2005
File Break: 14.01
Doc Date: 07/28/2005
File Break: 14.01
Doc Type: LETTER
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ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
10/5/2005
Page 30 of 33
14: CONGRESSIONAL RELATIONS
237229 RESPONSE TO LETTER OF 7/28/05, GIVING A HISTORY OF EPA'S DEALINGS WITH DURHAM
MANUFACTURING COMPANY, AND A LIST OF ENCLOSURES
Author: SUSAN STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION
Addressee:
CHRISTOPHER J DODD US SENATE
Doc Date: 08/02/2005
File Break: 14.01
Doc Type: LETTER
237230 RESPONSE TO LETTER OF 7/28/05, GIVING A HISTORY OF EPA'S DEALINGS WITH DURHAM
MANUFACTURING COMPANY, AND A LIST OF ENCLOSURES
Author: SUSAN STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION
Addressee:
ROSA DELAURO US HOUSE OF REPRESENTATIVES
Doc Type: LETTER
Doc Date: 08/02/2005
File Break: 14.01
237231 RESPONSE TO LETTER OF 7/28/05, GIVING A HISTORY OF EPA'S DEALINGS WITH DURHAM
MANUFACTURING COMPANY, AND A LIST OF ENCLOSURES
Author: SUSAN STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION
Addressee: JOSEPH I LIEBERMAN US SENATE
Doc Type: LETTER
Doc Date: 08/02/2005
File Break: 14.01
237232 RESPONSE TO LETTER OF 7/28/05, GIVING A HISTORY OF EPA'S DEALINGS WITH DURHAM
MANUFACTURING COMPANY, AND A LIST OF ENCLOSURES
Author: SUSAN STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION
Addressee:
ROB SIMMONS US CONGRESS
Doc Date: 08/02/2005
File Break: 14.01
Doc Type: LETTER
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Page 31 of 33
16: NATURAL RESOURCE TRUSTEE
237214 NOTIFICATION OF PROPOSED PLAN
Author: ANNI LOUGHLIN US EPA REGION 1
Addressee: KENNETH FINKELSTEIN US NATIONAL OCEANIC ATMOSPHERIC ADMINISTRATION
Doc Type: LETTER
237215 NOTIFICATION OF PROPOSED PLAN
Author: ANNI LOUGHLIN
Addressee: GINA MCCARTHY
Doc Type: LETTER
237216 NOTIFICATION OF PROPOSED PLAN
Author: ANNI LOUGHLIN US EPA REGION 1
Addressee: ANDREW RADDANT US DEPT OF THE INTERIOR
Doc Type: LETTER
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 07/12/2005
File Break: 16.04
US EPA REGION 1 Doc Date: 07/12/2005
CT DEPT OF ENVIRONMENTAL PROTECTION File Break. 16.04
Doc Date: 07/12/2005
File Break: 16.04
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17: SITE MANAGEMENT RECORDS
67298 SOIL SURVEY OF MIDDLESEX COUNTY, CONNECTICUT
Author: CONNECTICUT AGRICULTURAL EXPERIMENT STATION
Addressee: STORR AGRICULTURAL EXPERIMENT STATION
US DEPT OF AGRICULTURE SOIL CONSERVATION SERVICE
Doc Type: REPORT
238277 GUIDANCE FOR EVALUATING THE TECHNICAL IMPRACTICABILITY OF GROUND-WATER
RESTORATION
Author: US EPA - OFFICE OF SOLID WASTE & EMERGENCY RESPONSE
Addressee:
Doc Type: REPORT
67280 STUDY OF UNDERGROUND WATER RESOURCES OF CONNECTICUT
Author: US GEOLOGICAL SURVEY
Addressee:
Doc Type: REPORT
67268 CLIMATOGRAPHY OF CONNECTICUT - MONTHLY STATION NORMALS OF TEMPERATURE,
PRECIPITATION, AND HEATING AND COOLING DEGREE DAYS FROM 1971-2000
Author: NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
Addressee:
Doc Type: REPORT
AR Collection: 3710
ROD ADMIN RECORD FOR DURHAM
AR Collection QA Report
***For External Use***
Doc Date: 01/01/0001
File Break: 17.08
Doc Date: 09/01/1993
File Break: 17.07
Doc Date: 01/01/1999
File Break: 17.07
Doc Date: 02/01/2002
File Break: 17.08
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AR Collection: 3710 10/5/2005
ROD ADMIN RECORD FOR DURHAM Page 33 of 33
AR Collection QA Report
***For External Use***
17: SITE MANAGEMENT RECORDS
67295 MONTHLY STATION NORMALS OF TEMPERATURE, PRECIPITATION, AND HEATING AND COOLING
DEGREE DAYS, 1971-200
Author: NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
Addressee:
Doc Type: REPORT
Doc Date: 02/01/2002
File Break: 17.08
20: RECORDS MANAGEMENT
67327 ADMINISTRATIVE RECORD (AR) INDEX FOR PROPOSED PLAN
Author: US EPA REGION 1 Doc Date: 07/01/2005
Addressee:
File Break: 20.01
Doc Type: INDEX
Number of Documents in Collection^ 21
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The following documents were used in making the Decision and are included in the Administrative Record, but are not
releasable to the public due to Privacy Act
236700 FINAL REPORT INDOOR AIR SAMPLING STUDY, MAY 2005
Author: US EPA REGION 1 Doc Date:
Addressee: File Break:
06/30/2005 #of Pages:
03.04
236
Doc Type: Report
Appendix A of this report is available under its own entry.
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INDEX OF GUIDANCE
U.S. Army Corps of Engineers / U.S. Environmental Protection Agency (USACE/USEPA). 2000. A
Guide to Developing and Documenting Cost Estimates During the Feasibility Study. EPA 540-
R-00-002. July 2000.
U.S. Environmental Protection Agency (USEPA). 1988. Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA. USEPA Office of Solid Waste and
Emergency Response, Washington, D.C. Interim Final, October 1988.
U.S. Environmental Protection Agency (USEPA). 1989. Risk Assessment Guidance for Superfund.
Volume I: Human Health Evaluation Manual. Part A. Interim Final. EPA/540/1-89/002.
December 1989.
U. S. Environmental Protection Agency (USEPA). 1989. Region I Laboratory Data Validation
Functional Guidelines for Evaluating Inorganics Analyses. 1989.
U.S. Environmental Protection Agency (USEPA). 1990. National Oil and Hazardous Substances
Pollution Contingency Plan (National Contingency Plan). Code of Federal Regulations, Title 40,
Part 300, Federal Register, Volume 55, Number 46, pp. 8666 et seq. March 9, 1990.
U.S. Environmental Protection Agency (USEPA). 1991. Risk Assessment Guidance for Superfund.
Volume I: Human Health Evaluation Manual. Supplemental Guidance." Standard Default
Exposure Factors". Interim Final. 9285.6-3. March 25, 1991.
U.S. Environmental Protection Agency (USEPA). 1991. Role of Baseline Risk Assessment in Superfund
Remedy Selection Decisions. Office of Solid Waste and Emergency Response. Washington,
D.C. OSWER Directive 9355.0-30. Memo from Don R. Clay. April 22, 1991.
U.S. Environmental Protection Agency (USEPA). 1991. Design and Construction of RCRA/CERCLA
Final Covers. U.S. Environmental Protection Agency, Office of Emergency Research and
Development, Washington, D.C. EPA/625/4-91/025. May 1991.
U.S. Environmental Protection Agency (USEPA). 1991. Risk Assessment Guidance for Superfund.
Volume I: Human Health Evaluation Manual. Part B, Development of Risk-Based Preliminary
Remediation Goals. Interim Final. 9285.7-01 B. December 1991.
U.S. Environmental Protection Agency (USEPA). 1992. Supplemental Guidance to RAGS: Calculating
the Concentration Term. Office of Solid Waste and Emergency Response. Washington, D.C.
Publication 9285.7-081. May 1992.
U. S. Environmental Protection Agency (USEPA). 1992. EPA Handbook of RCRA Groundwater
Monitoring Constituents: Chemical and Physical Properties, 40 CFR Part 264,
Appendix IX, September 1992.
U.S. Environmental Protection Agency (USEPA). 1993. Provisional Guidance for Quantitative Risk
Assessment of Polycyclic Aromatic Hydrocarbons. Office of Research and Development.
Washington, DC. EPA/600/R-93/089. July 1993.
U.S. Environmental Protection Agency (USEPA). 1993. Guidance for Evaluating the Technical
Impracticability of Ground-Water Restoration - Interim Final. Office of Solid Waste and
Emergency Response, Washington D.C. Directive 9234.2-25. September 1993.
U.S. Environmental Protection Agency (USEPA). 1993. Presumptive Remedies: Policy and
Procedures. Office of Solid Waste and Emergency Response, Washington D.C. Directive 9355.0-
47FS. September 1993.
-------
U.S. Environmental Protection Agency (USEPA). 1993. Presumptive Remedies: Site Characterization
and Technology Selection for CERCLA Sites with Volatile Organic Compounds in Soils. Office of
Solid Waste and Emergency Response, Washington D.C. Directive 9355.0-48FS. September
1993.
U.S. Environmental Protection Agency (USEPA). 1994. Guidance Manual for the Integrated Exposure
Uptake Biokinetic Model for Lead in Children. Office of Solid Waste and Emergency Response.
Washington, D.C. EPA/540/R-93/081. February 1994.
U.S. Environmental Protection Agency (USEPA). 1994. Revised Interim Soil Lead Guidance for
CERCLA Sites and RCRA Corrective Action Facilities. Office of Solid Waste and Emergency
Response, Washington D.C. OSWER Directive 9355.4-12. July 1994.
U.S. Environmental Protection Agency (USEPA). 1994. Risk Updates, No. 2. USEPA Region I.
August 1994.
U.S. Environmental Protection Agency (USEPA). 1995. Risk Updates, No. 3. USEPA Region I. August
1995.
U.S. Environmental Protection Agency (USEPA). 1996. Final Guidance, Presumptive Response
Strategy and Ex Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites.
Office of Solid Waste and Emergency Response, Washington D.C. EPA 540/R-96/023. October
1996.
U.S. Environmental Protection Agency (USEPA). 1996. Risk Updates, No. 4. USEPA Region I.
November 1996.
U. S. Environmental Protection Agency (USEPA). 1996. Region I, EPA-New England Data
Validation Functional Guidelines for Evaluating Environmental Analysis. 1996.
U.S. Environmental Protection Agency (USEPA). 1997. Presumptive Remedy: Supplemental Bulletin
Multi-Phase Extraction (MPE) Technology for VOCs in Soil and Groundwater. Office of Solid
Waste and Emergency Response, Washington D.C. EPA 540-F-97-004. April 1997.
U.S. Environmental Protection Agency (USEPA). 1997. Health Effects Assessment Summary Tables,
FY-1997 Annual (HEAST). Office of Health and Environmental Assessment. Environmental
Assessment and Criteria Office and Office of Solid Waste and Emergency Response.
Washington, D.C. July 1997.
U.S. Environmental Protection Agency (USEPA). 1997. Exposure Factors Handbook. Office of
Research and Development. Washington, D.C. August 1997.
U.S. Environmental Protection Agency (USEPA). 1998. Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Groundwater. Office of Research and Development,
Washington D.C. EPA/600/R-98/128. September 1998.
U.S. Environmental Protection Agency (USEPA). 1998. Management of Remediation Waste Under
RCRA. Office of Soil Waste and Emergency Response. EPA530-F-98-026. October 1998.
U.S. Environmental Protection Agency (USEPA). 1999. Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and Underground Storage Tank Sites. Office of Solid Waste
and Emergency Response, Washington D.C. Directive 9200.4-17P. April 1999.
U.S. Environmental Protection Agency (USEPA). 1999. A Guide to Preparing Superfund Proposed Plans,
Records of Decision, and Other Remedy Selection Documents. Office of Solid Waste
and Emergency Response, Washington D.C. Directive 9200.1-23.P. July 1999.
-------
U. S. Environmental Protection Agency (USEPA). 2000. EPI (Estimation Programs Interface)
Suite. Developed by EPA's Office of Pollution Prevention Toxics and Syracuse Research
Corporation (SRC). 2000.
U.S. Environmental Protection Agency (USEPA). 2001. Revised Alternative Cap Design Guidance
Proposed for Unlined, Hazardous Waste Landfills in the EPA Region I. February 5, 2001.
U.S. Environmental Protection Agency (USEPA). 2001. Supplemental Guidance for Developing Soil
Screening Levels for Superfund Sites. Peer Review Draft. Office of Emergency and Remedial
Response. Washington, D.C. OSWER Directive 9355.4-24. March 2001.
U.S. Environmental Protection Agency (USEPA). 2001. Risk Assessment Guidance for Superfund.
Volume I: Human Health Evaluation Manual. Part D, Standardized Planning, Reporting, and
Review of Superfund Risk Assessments. Final. Office of Emergency and Remedial Response.
Washington, D.C. OSWER Directive 9285.7-47. December 2001.
U.S. Environmental Protection Agency (USEPA). 2002. User's Guide for the Integrated Exposure
Uptake Biokinetic Model for Lead in Children. Office of Emergency and Remedial Response.
Washington, D.C. EPA 9285.7-42. May 2002.
U.S. Environmental Protection Agency (USEPA). 2002. Draft Guidance for Evaluating the Vapor
Intrusion to Indoor Air Pathway from Groundwater and Soils. RCRA/2002/033. November 2002.
http://www.epa.gov/correctiveaction/eis/vapor.htm.
U.S. Environmental Protection Agency (USEPA). 2002. National Recommended Water Quality Criteria.
Federal Register. December 27, 2002.
U.S. Environmental Protection Agency (USEPA). 2002. Calculating Upper Confidence Limits for
Exposure Point Concentrations at Hazardous Waste Sites. Office of Emergency and Remedial
Response. Washington, D.C.. OSWER 9285.6-10. December 2002.
U.S. Environmental Protection Agency (USEPA). 2003. Recommendations of the Technical Review
Workgroup for Lead for an Approach to Assessing Risk Associated with Adult Exposures to Lead
in Soil. Technical Review Workgroup for Lead. January 2003.
U.S. Environmental Protection Agency (USEPA). 2003. Draft Final Guidelines for Carcinogen Risk
Assessment. External Review Draft. Risk Assessment Forum. February 2003.
U.S. Environmental Protection Agency (USEPA). 2003. Drinking Water Standards. Office of Water.
June 2003.
U.S. Environmental Protection Agency (USEPA). 2003. The DNAPL Remediation Challenge: Is There
a Case for Source Depletion? Expert Panel on DNAPL Remediation, Ground Water and
Ecosystems Restoration Division. EPA Contract No. 68-C-02-092. December 2003.
U.S. Environmental Protection Agency (USEPA). 2004. User's Guide for ProUCL Version 3.0.
Technical Support Center, http://www.epa.gov/nerlesd1/tsc/software.htm. April 2004.
U.S. Environmental Protection Agency (USEPA). 2004. Risk Assessment Guidance for Superfund
Volume I: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk
Assessment). Final. Office of Superfund Remediation and Technology Innovation. Washington,
D.C. EPA/540/R/99/005. July 2004.
U.S. Environmental Protection Agency (USEPA). 2004. Preliminary Remediation Goals Table. Region
9 Technical Support Team. Office of Superfund Programs. Region IX. October 2004.
-------
U. S. Environmental Protection Agency (USEPA). 2005. Waste Site Cleanup & Reuse in New England.
http://yosemite.epa.gov/r1/npl_pad.nsf/Accessed February 25, 2005.
U.S. Environmental Protection Agency (USEPA). 2005. Integrated Risk Information System (IRIS).
Environmental Criterion and Assessment Office. March 2005.
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Record of Decision
Appendices
Appendix H
References
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30, 2005
Appendices
-------
Record of Decision
Appendices
References;
Advanced Environmental Interface (AEI). 2005 . 2004 Annual Monitoring Report for the
F.W. Strong School. March 2005.
Connecticut Department of Environmental Protection (CTDEP). 2001. State of
Connecticut DEP. Air Management Bureau, Hartford, Premise Evaluation Report. May
15, 2001.
Connecticut Department of Environmental Protection (CTDEP). 2005a. Summary of the
Water Quality Standards and Classifications, http://dep.state.ct.us/wtr/wq/wqsinfo.htm
Accessed April 1,2005.
Connecticut Department of Environmental Protection (CTDEP). 2005b, Durham
Meadows National Priorities List Superfund Site, Durham, Connecticut, Ground Water
Use and Value Determination, June 2005. July 5, 2005.
Efroymson, R.A., G.W. Sutcr, B.E Sample, and D.S. Jones. 1997. Preliminary
remediation goals for ecological endpoints. Oak Ridge National laboratory. ES/ER/TM-
162/R2.
Ingersoll, C.G., D.M. MacDonald, N. Wang, J.L. Crane, L.J. Field, P.S. Havcrland, N.E.
Kemble, R.A. Lindskoog, C. Severn, and D.E. Smorong. 2000. Prediction of sediment
toxicity using consensus-based freshwater sediment quality guidelines. EPA 905/R-
00/007.
Jaagumagi, R., D. Persaud, and D. Bedard, 1995. Ontario's approach to sediment
assessment and remediation. Second SETAC World Congress (16th Annual Meeting).
Vancouver, BC, Canada, November 5-9, 1995.
Jones, D.S,, G.W. Suter, and R.N. Hull. 1997. Toxicological benchmarks for screening
contaminants of potential concern for effects on sediment-associated biota: 1997 revision.
Oak Ridge National Laboratory. ES/ER/TM-95/R4.
Kueper, B.H.; Wealthall, G.P; Smith, J.W.N; Lehame, S.A; and Lerner, D.N. (Kueper et.
al,), 2003, An Illustrated Handbook of DNAPL Transport and Fate in the Subsurface.
Bristol, England: Environment Agency, R&D Publication 133. June 2003,
Leggette, Brashears, & Graham, Inc. (LB&G). 1982. Ground-water Quality
Investigation, Durham Manufacturing Company, Durham, Connecticut. October, 1982.
Leggette, Brashears, & Graham, Inc. (LB&G). 1994. Summary of Subsurface
Investigations, Durham Manufacturing Company, Durham, Connecticut. Received by
CT Waste Management Branch, Connecticut Superfund Section on January 10, 1994.
Record of Decision
Durham Meadows Superfund Site
Durtiam, Connecticut
Version; FINAL
Date: September 30, 2005
Appendices
-------
Record of Decision
Appendices
Leggette, Brashears, & Graham, Inc. (LB&G), 1999, Draft Data Report, Durham
Meadows Superfund Site, Durham, Connecticut. August 1999,
Leggette, Brashears, & Graham, Inc. (LB&G), 2005, Draft Remedial Investigation
Report, Durham Meadows Superfund Site, Durham, Connecticut. 2005.
Long, E.R., D.D. MacDonald, S.L, Smith and F.D. Calder. 1995, Incidence of adverse
biological effects with ranges of chemical concentrations in marine and estuarine
sediments. Environ, Manag. 19:81-97.
MacDonald, D.D., C.G. Ingersoll and T.A. Berger. 2000, Development and evaluation of
consensus-based sediment quality guidelines for freshwater ecosystems. Arch. Environ.
Contam. Toxicol. 39:20-31.
Metcalf & Eddy (M&E). 1994. Data Summary Report for START Initiative, Durham
Meadows, Durham, Connecticut. April 1994.
Metcalf & Eddy (M&E). 2005a. Draft Final Remedial Investigation Report, Durham
Meadows Superfund Site, Durham, Connecticut. June 2005.
Metcalf & Eddy (M&E). 2005b. Draft Final Feasibility Study Report, Durham Meadows
Superfund Site, Durham, Connecticut. June 2005.
Metcalf & Eddy (M&E), 2005c. Draft Final Technical Impracticability Evaluation
Report, Durham Meadows Superfund Site, Durham, Connecticut. June 2005.
Metcalf & Eddy (M&E). 2005d. Draft Final Baseline Human Health Risk Assessment
Report, Durham Meadows Superfund Site, Durham, Connecticut. June 2005,
National Oceanic and Atmospheric Administration (NOAA). 2002. Climatography of
the United States No. 81. Monthly Station Normals of Temperature, Precipitation, and
Heating and Cooling Degree Days, 1971-2000, Connecticut 06. National Oceanic and
Atmospheric Administration, National Environmental Satellite, Data, and Information
Service, National Climatic Data Center, Asheville, NC. February 2002.
Pankow, J.F. and J,A. Cherry. 1996. Dense Chlorinated Solvents and Other DNAPLs in
Groundwater. Portland, OR; McGraw-Hill. 1996.
Persaud, D., R. Jaagumagi and A. Hayton. 1993. Guidelines for the protection and
management of aquatic sediment quality in Ontario. Ontario Ministry of Environment
and Energy.
Roux Associates (Roux). 1990. Soil Gas Survey Report. October and December 1990.
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30, 2005
Appendices
-------
Record of Decision
Appendices
Sample, B.E., D.M. Opresko and G.W. Suter, 1996, Toxicological benchmarks for
wildlife: 1996 revision. Oak Ridge National Laboratory. ES/ER/TM-86/R3.
Suter, G.W. and C.L. Tsao. 1996. Toxicological benchmarks for screening potential
contaminants of concern for effects on aquatic biota: 1996 revision. Oak Ridge National
Laboratory. ES/ER/TM-96/R2.
Town of Durham . 2003a. Durham, Connecticut Zoning Regulations. Amended June 1,
2003.
Town of Durham. 2003b. Plan of Conservation and Development, Town of Durham,
Connecticut. Effective date March 1,2003.
U. S. Environmental Protection Agency (USEPA). 1993. Guidance for Evaluating the
Technical Impracticability of Ground- Water Restoration, Interim Final. OSWER
Directive 9234.2-25. September 1993.
U. S. Environmental Protection Agency (USEPA). 1996. Ecotox threshold. EPA 540/F-
95/038.
U, S. Environmental Protection Agency (USEPA). 2002a. Environmental News: EPA
Settles with Connecticut Manufacturing Company of Federal "Right to Know"
Regulations. January 23,2002.
U. S. Environmental Protection Agency (USEPA). 2002. National recommended water
quality criteria: 2002b. EPA 822-R-02-047,
U. S. Environmental Protection Agency (USEPA). 2003. Ecological soil screening level
for aluminum. Interim final. OSWER Directive 9285,7-60.
U. S. Environmental Protection Agency (USEPA). 2005. Final Screening-Level
Ecological Risk Assessment, Durham Meadows Site, Durham, Connecticut. June 2005.
U. S. Geological Survey (USGS). 1995. Geohydrology and Water Quality of the Durham
Center Area, Durham, Connecticut, Water-Resources Investigations Report 94-4237.
1995.
Zenker, M.J.; Borden, R.C.; and Barlaz, M.A (Zenker et. al.). 2003. Occurrence and
Treatment of 1,4-Dioxatic in Aqueous Environments, Environmental Engineering Science
vol. 20. pp. 423-431. November 2003.
Record of Decision
Durham Meadows Superfund Site
Durham, Connecticut
Version: FINAL
Date: September 30, 2005
Appendices
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