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TECHNICAL MEMORANDUM

TO Cheryl Sprague USEPA Region 1

FROM Woodard amp Curran

DATE August 17 2004

RE Former Lagoon Area Keefe Environmental Services Site Epping NH

The purpose of this memorandum is to provide the NHDES and the USEPA with a summary of the history and recent findings for the Former Lagoon Soil Spoils Area at the Keefe Superfund Site and to recommend the removal and off-site disposal of certain site soils to meet the Remedial Action Objectives outlined in the 1988 Record of Decision (ROD)

History

On November 15 1983 USEPA signed a Record of Decision (ROD) for OU-1 (the original lagoon area) which mandated decommissioning of the lagoon and removal of the lagoon contents In February 1984 the lagoon decommissioning was completed In 1992 as part of the implementation of the 1988 ROD which called for the extraction and on-site treatment of the contaminated groundwater the NHDES lined the former lagoon area and placed contaminated soil generated during the construction of the groundwater extraction trench into the lined lagoon area This area is now referred to as the Soil Spoils Area

The Soil Spoils Area was constructed with a 60-millimeter thick high density polyethylene (HDPE) liner topped with 6-inches of sand followed by the excavated trench soil spoils Along the southern and western ends of the lagoon were two collection trenches constructed of an 8-inch diameter perforated pipe placed along the bottom of a crushed stone-filled trench which varied in thickness (from 1-5 feet) Both trenches were sloped downward to the southwestern corner of the lagoon where leached water could gravity-drain to a collection trench manhole piped to the groundwater treatment plant

Since construction in 1992 rainfall has been allowed to percolate through the soils collect on the liner and the leached water was diverted to the on-site groundwater plant for treatment Sampling of the leachate for volatile organic compounds by Woodard amp Curran was performed monthly as part of the on-going operation and maintenance at the Site The monthly testing was discontinued in June 2001 after 10 consecutive months of non-detectable results A confirmatory sample collected in November 2002 and analyzed for VOCs also indicated that the leachate had no reportable quantities of contamination entering the treatment system To further evaluate the soils within the Soil Spoils Area as part of a risk evaluation Woodard amp Curran was directed by the NHDES to complete a test pitting and soil sampling program to characterize current conditions within the Soil Spoils Area These tests were completed to determine whether residual contamination could leach into the groundwater in exceedance of any drinking water standard upon future termination of the

35 New England Business Center Suite 180 i Andover Massachusetts 01810 978-557-8150 I 866-702-6371 I 978-557-7948 (Fax) I www woodardcurran com

WOODARDampCURRAN iirig Science5 bull u- bull I- i

leachate collection system or if the soils contaminant concentrations which could pose a risk to human health under current or reasonable foreseeable future conditions

Results of Findings

In June of 2003 a total of 16 test pit excavations were completed and subsequent laboratory analysis of soil sampling was performed The locations of the test pit excavations are shown on the attached Figure 1 The excavations were completed to the top of the drainagesand layer installed over the liner Excavations ranged in depth from 5 to 7 feet below ground surface The soils encountered primarily consisted of the brown and gray till geologic unit present at the Site Soil samples were collected from each test pit for field screening with a total volatile organic compound (VOC) analyzer by the soil jar headspace procedure The results of the field screening activities are presented in Table 1 and indicated that elevated responses were detected at only test pits TP-13 through TP-16 Observed field screening responses ranged from 10 to 135 ppmv with the highest reading detected at test pit TP-15 Each of the elevated readings was reported from soils at the bottom of the excavations (TP-13 through TP-16)

Based on the results of the field screening 16 discrete soil samples were collected and submitted to an off-site laboratory for VOC analysis by Method 8260B5035 The specific depths were based on the jar headspace results (ie all samples with observed readings on the total VOC analyzer were selected for off-site VOC analysis) andor visual conditions observed during excavation In addition to samples selected for VOC analysis composite soil samples were collected and analyzed for metals (8 samples) SVOCs (8 samples) polychlorinated biphenyls (PCBs 8 samples) pesticides (4 samples) and petroleum hydrocarbons (4 samples) Additionally one sample of the drainage sand from Test Pit TP-15 was collected for laboratory analysis The analytical results are presented on Table 2 (VOCs) and Table 3 (metals SVOCs and petroleum hydrocarbons) Additional information relative to these studies can be found in the Summary Report of Additional Investigation Activities dated September 30 2003 In summary the results indicated

bull Site-related VOCs were detected in 5 of the 16 soil samples analyzed Concentrations of total xylenes p-isopropyl toluene ethylbenzene 124-trimethylbenzene acetone 2-butanone carbon disulfide and toluene were detected The highest concentrations of VOCs were detected in samples collected from test pits TP-13 through TP-16

bull Total metals were detected in each of the 9 samples selected for analysis The metals detected consisted of antimony arsenic beryllium cadmium chromium copper lead mercury nickel thallium and zinc Concentrations of selenium and silver were not detected above the laboratorys minimum reporting limit in any of the samples

bull SVOCs were detected in the composite sample from test pits TP-15 and TP-16 Bis(2shyethylhexyl)phthalate 2-methylnaphthalene and benzo(a)pyrene were detected No SVOCs were detected the 7 remaining samples analyzed

bull Concentrations of petroleum hydrocarbons (via the MADEP Extractable Petroleum Hydrocarbon [EPH] method) were detected in 2 of the 5 samples analyzed The greatest percentages of petroleum hydrocarbons detected were reported in the sample collected from test pits TP-15 and TP-16

bull No concentrations of PCBs (9 samples) or pesticides (5 samples) were detected above the laboratorys minimum reporting limit

Keefe Environmental Services Site (Project 93424 13) 2 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN Engineering bull Science bull Operations

When compared to the NHDES Method 1 Soil criteria all detected concentrations of VOCs were below S-l soil standards (which consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater [ie leaching] at the Site) Concentrations of SVOCs exhibited in one sample collected from test pits TP-15 and TP-16 (bis(2shyethylhexyl)phthalate [69800 ugkg] and benzo(a)pyrene [741 ugkg]) were detected in excess of the S-l standards (39000 ugkg and 700 ugkg respectively) These results indicate that these compounds if left in place in site soils may potentially pose a risk of harm to human health and may leach into the groundwater resulting in exceedances of the NHDES drinking water standards

Concentrations of arsenic in samples CS01 (131 mgkg) CS02 (130 mgkg) and CS04 (123 mgkg) were detected in excess of the S-l criteria of 120 mgkg Beryllium concentrations (ranging from 072 to 19 mgkg) were detected in excess of the standard (01 mgkg) in each of the composite samples analyzed (CS01 through CS08) All other concentrations of metals detected in soil were generally detected at low concentrations which are consistent with background as defined by the NHDES

For comparison purposes since NHDES does not have specific criteria for the EPH hydrocarbon ranges the EPH results were compared to Massachusetts Department of Environmental Protection (MADEP) criteria outlined in the Massachusetts Contingency Plan (310 CMR 400000) This comparison indicated that only the extractable aromatic hydrocarbon range (Cl 1-C22) detected in sample CS08 (371000 ugkg) would exceed the MCP S-lGW-1 criteria of 200000 ugkg The MCP S-lGW-1 soil category is approximately equivalent to the NHDES Method 1 soil category applicable to soil determined to be category S-l (ie residential soil scenario - which also consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater)

Recommendations

Woodard amp Curran was tasked by the NHDES to review the activities and conditions of the Site as part of the upcoming transfer of the Site from the USEPA lead for the Long-Term Remedial Action (LTRA) which has been on-going since 1993 into the State lead Operation and Maintenance (OampM) in June of 2005 The transfer activities included the review of the need for continued leachate collection from the Soil Spoils area as well as the future human health exposure potential from the Soils Spoils area with closure

Based on the results of these investigations summarized above it is recommended that soils located on the southern end of the Soil Spoils area (sampling performed in test pits TP-13 through TP-16) which may potentially pose a future risk to human health through the leaching of the contaminants into the groundwater be excavated and transported off-site for disposal

Although no target analytes for soil were detected in excess of the established ROD cleanup goals for select site contaminants in the other portions of the Soil Spoils area this area is proposed for excavation and disposal in order to minimize the potential future threat to groundwater from the leaching of certain extractable petroleum hydrocarbons (Cn - C22)shy

Due to its discrete and relatively small volume the presence of contaminants at concentrations above the NHDES S-l (and MCP S-lGW-1) standards and due to the technical impracticality of cost-effectively treating such a small volume of contaminated soils off-site disposal is recommended as the best option to minimize the future risk posed by these soils The volume of soil identified for excavation and off-site disposal

Keefe Environmental Services Site (Project 9342413) 3 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN iirig Science5 bull u- bull I- i

leachate collection system or if the soils contaminant concentrations which could pose a risk to human health under current or reasonable foreseeable future conditions

Results of Findings

In June of 2003 a total of 16 test pit excavations were completed and subsequent laboratory analysis of soil sampling was performed The locations of the test pit excavations are shown on the attached Figure 1 The excavations were completed to the top of the drainagesand layer installed over the liner Excavations ranged in depth from 5 to 7 feet below ground surface The soils encountered primarily consisted of the brown and gray till geologic unit present at the Site Soil samples were collected from each test pit for field screening with a total volatile organic compound (VOC) analyzer by the soil jar headspace procedure The results of the field screening activities are presented in Table 1 and indicated that elevated responses were detected at only test pits TP-13 through TP-16 Observed field screening responses ranged from 10 to 135 ppmv with the highest reading detected at test pit TP-15 Each of the elevated readings was reported from soils at the bottom of the excavations (TP-13 through TP-16)

Based on the results of the field screening 16 discrete soil samples were collected and submitted to an off-site laboratory for VOC analysis by Method 8260B5035 The specific depths were based on the jar headspace results (ie all samples with observed readings on the total VOC analyzer were selected for off-site VOC analysis) andor visual conditions observed during excavation In addition to samples selected for VOC analysis composite soil samples were collected and analyzed for metals (8 samples) SVOCs (8 samples) polychlorinated biphenyls (PCBs 8 samples) pesticides (4 samples) and petroleum hydrocarbons (4 samples) Additionally one sample of the drainage sand from Test Pit TP-15 was collected for laboratory analysis The analytical results are presented on Table 2 (VOCs) and Table 3 (metals SVOCs and petroleum hydrocarbons) Additional information relative to these studies can be found in the Summary Report of Additional Investigation Activities dated September 30 2003 In summary the results indicated

bull Site-related VOCs were detected in 5 of the 16 soil samples analyzed Concentrations of total xylenes p-isopropyl toluene ethylbenzene 124-trimethylbenzene acetone 2-butanone carbon disulfide and toluene were detected The highest concentrations of VOCs were detected in samples collected from test pits TP-13 through TP-16

bull Total metals were detected in each of the 9 samples selected for analysis The metals detected consisted of antimony arsenic beryllium cadmium chromium copper lead mercury nickel thallium and zinc Concentrations of selenium and silver were not detected above the laboratorys minimum reporting limit in any of the samples

bull SVOCs were detected in the composite sample from test pits TP-15 and TP-16 Bis(2shyethylhexyl)phthalate 2-methylnaphthalene and benzo(a)pyrene were detected No SVOCs were detected the 7 remaining samples analyzed

bull Concentrations of petroleum hydrocarbons (via the MADEP Extractable Petroleum Hydrocarbon [EPH] method) were detected in 2 of the 5 samples analyzed The greatest percentages of petroleum hydrocarbons detected were reported in the sample collected from test pits TP-15 and TP-16

bull No concentrations of PCBs (9 samples) or pesticides (5 samples) were detected above the laboratorys minimum reporting limit

Keefe Environmental Services Site (Project 93424 13) 2 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN Engineering bull Science bull Operations

When compared to the NHDES Method 1 Soil criteria all detected concentrations of VOCs were below S-l soil standards (which consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater [ie leaching] at the Site) Concentrations of SVOCs exhibited in one sample collected from test pits TP-15 and TP-16 (bis(2shyethylhexyl)phthalate [69800 ugkg] and benzo(a)pyrene [741 ugkg]) were detected in excess of the S-l standards (39000 ugkg and 700 ugkg respectively) These results indicate that these compounds if left in place in site soils may potentially pose a risk of harm to human health and may leach into the groundwater resulting in exceedances of the NHDES drinking water standards

Concentrations of arsenic in samples CS01 (131 mgkg) CS02 (130 mgkg) and CS04 (123 mgkg) were detected in excess of the S-l criteria of 120 mgkg Beryllium concentrations (ranging from 072 to 19 mgkg) were detected in excess of the standard (01 mgkg) in each of the composite samples analyzed (CS01 through CS08) All other concentrations of metals detected in soil were generally detected at low concentrations which are consistent with background as defined by the NHDES

For comparison purposes since NHDES does not have specific criteria for the EPH hydrocarbon ranges the EPH results were compared to Massachusetts Department of Environmental Protection (MADEP) criteria outlined in the Massachusetts Contingency Plan (310 CMR 400000) This comparison indicated that only the extractable aromatic hydrocarbon range (Cl 1-C22) detected in sample CS08 (371000 ugkg) would exceed the MCP S-lGW-1 criteria of 200000 ugkg The MCP S-lGW-1 soil category is approximately equivalent to the NHDES Method 1 soil category applicable to soil determined to be category S-l (ie residential soil scenario - which also consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater)

Recommendations

Woodard amp Curran was tasked by the NHDES to review the activities and conditions of the Site as part of the upcoming transfer of the Site from the USEPA lead for the Long-Term Remedial Action (LTRA) which has been on-going since 1993 into the State lead Operation and Maintenance (OampM) in June of 2005 The transfer activities included the review of the need for continued leachate collection from the Soil Spoils area as well as the future human health exposure potential from the Soils Spoils area with closure

Based on the results of these investigations summarized above it is recommended that soils located on the southern end of the Soil Spoils area (sampling performed in test pits TP-13 through TP-16) which may potentially pose a future risk to human health through the leaching of the contaminants into the groundwater be excavated and transported off-site for disposal

Although no target analytes for soil were detected in excess of the established ROD cleanup goals for select site contaminants in the other portions of the Soil Spoils area this area is proposed for excavation and disposal in order to minimize the potential future threat to groundwater from the leaching of certain extractable petroleum hydrocarbons (Cn - C22)shy

Due to its discrete and relatively small volume the presence of contaminants at concentrations above the NHDES S-l (and MCP S-lGW-1) standards and due to the technical impracticality of cost-effectively treating such a small volume of contaminated soils off-site disposal is recommended as the best option to minimize the future risk posed by these soils The volume of soil identified for excavation and off-site disposal

Keefe Environmental Services Site (Project 9342413) 3 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN Engineering bull Science bull Operations

When compared to the NHDES Method 1 Soil criteria all detected concentrations of VOCs were below S-l soil standards (which consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater [ie leaching] at the Site) Concentrations of SVOCs exhibited in one sample collected from test pits TP-15 and TP-16 (bis(2shyethylhexyl)phthalate [69800 ugkg] and benzo(a)pyrene [741 ugkg]) were detected in excess of the S-l standards (39000 ugkg and 700 ugkg respectively) These results indicate that these compounds if left in place in site soils may potentially pose a risk of harm to human health and may leach into the groundwater resulting in exceedances of the NHDES drinking water standards

Concentrations of arsenic in samples CS01 (131 mgkg) CS02 (130 mgkg) and CS04 (123 mgkg) were detected in excess of the S-l criteria of 120 mgkg Beryllium concentrations (ranging from 072 to 19 mgkg) were detected in excess of the standard (01 mgkg) in each of the composite samples analyzed (CS01 through CS08) All other concentrations of metals detected in soil were generally detected at low concentrations which are consistent with background as defined by the NHDES

For comparison purposes since NHDES does not have specific criteria for the EPH hydrocarbon ranges the EPH results were compared to Massachusetts Department of Environmental Protection (MADEP) criteria outlined in the Massachusetts Contingency Plan (310 CMR 400000) This comparison indicated that only the extractable aromatic hydrocarbon range (Cl 1-C22) detected in sample CS08 (371000 ugkg) would exceed the MCP S-lGW-1 criteria of 200000 ugkg The MCP S-lGW-1 soil category is approximately equivalent to the NHDES Method 1 soil category applicable to soil determined to be category S-l (ie residential soil scenario - which also consider both the potential risk of harm resulting from direct exposure to the contaminants in the soil and the potential impacts on the groundwater)

Recommendations

Woodard amp Curran was tasked by the NHDES to review the activities and conditions of the Site as part of the upcoming transfer of the Site from the USEPA lead for the Long-Term Remedial Action (LTRA) which has been on-going since 1993 into the State lead Operation and Maintenance (OampM) in June of 2005 The transfer activities included the review of the need for continued leachate collection from the Soil Spoils area as well as the future human health exposure potential from the Soils Spoils area with closure

Based on the results of these investigations summarized above it is recommended that soils located on the southern end of the Soil Spoils area (sampling performed in test pits TP-13 through TP-16) which may potentially pose a future risk to human health through the leaching of the contaminants into the groundwater be excavated and transported off-site for disposal

Although no target analytes for soil were detected in excess of the established ROD cleanup goals for select site contaminants in the other portions of the Soil Spoils area this area is proposed for excavation and disposal in order to minimize the potential future threat to groundwater from the leaching of certain extractable petroleum hydrocarbons (Cn - C22)shy

Due to its discrete and relatively small volume the presence of contaminants at concentrations above the NHDES S-l (and MCP S-lGW-1) standards and due to the technical impracticality of cost-effectively treating such a small volume of contaminated soils off-site disposal is recommended as the best option to minimize the future risk posed by these soils The volume of soil identified for excavation and off-site disposal

Keefe Environmental Services Site (Project 9342413) 3 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN FEngmosring bull Scence bull Upei^i-jns

is approximately 350 cubic yards Woodard amp Curran estimates that this activity can be completed in approximately 2 weeks of field effort and would include the disposal of the contaminated soils in a State RCRA D landfill

It is proposed that once the residual contaminated material is excavated and removed the remaining soil from the former lagoon will be temporarily stockpiled on one side of the lagoon and the liner removed Once the soil and liner are removed from one side of the lagoon the other side will be completed During completion of this task the synthetic liner (along with the piping from the collection trenches and sampling manhole) will be removed and disposed of as non-hazardous waste at an off-site facility Following removal the remaining soil will be regraded covered with loam and seeded A minimum of one foot of clean fill will be required to cover the former soils spoil area

Additionally Section 121(b)(l) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) presents several factors that at a minimum EPA is required to consider in its assessment of alternatives at a site Building upon these specific statutory mandates the National Contingency Plan (NCP) articulates nine evaluation criteria to be used in assessing the individual remedial alternatives The following is a summary assessment of the recommended alternative with respect to the following nine evaluation criteria

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

The excavation and off-site disposal of the contaminated soils will protect human health through the elimination of future risks related to the leaching of contaminants from the soil into groundwater above drinking water standards

2 Compliance with applicable or relevant and appropriate requirements (ARARs) addresses whether or not a remedy will meet all of the ARARs or other Federal and State environmental laws andor provide grounds for invoking a waiver The implementation of this alternative will meet and comply with the following ARARs

The ARARs set forth in the ROD will be complied with along with additional ARARs identified as potentially relevant or applicable andor appropriate as part of this action including

o Occupational Safety and Health Standards (OSHA 29 CFR Part 1910)

o Department of Transportation Rules for Transportation of Hazardous Materials (49 CFR Part 107 and 171)

o NHDES Contaminated Sites Risk Characterization amp Management Policy (RCMP) and

o RCRA Subtitle D - Criteria for Municipal Solid Waste Landfills (40 CFR Part 258)

Keefe Environmental Services Site (Project 9342413) 4 08172004 revised tech memo_soil spoils area_2doc

WOODARDampCURRAN

Primary Balancing Criteria

3 Long-term effectiveness and permanence addresses the long-term effectiveness and permanence they afford along with the degree of certainty that the alternative will prove successful

Excavation and off-site disposal will provide long-term effectiveness and permanence through the permanent removal of all soils which could pose a risk to human health in the future

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

As previously discussed treatment of the soil spoils within the lagoon has been ongoing since construction in 1993 As a result of this treatment (ie treatment of leached water diverted to the on-site groundwater plant) only residual contaminants remain within a portion of the soils in the lagoon area Therefore the excavation and off-site disposal option does not employ any further treatment alternatives

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

The most significant short-term risks that might be posed to the community or site workers revolve around the physical aspects of the removal activity itself Specifically the biggest risks are posed by the excavation and removal equipment and those most at risk are the site construction workers In terms of chemical hazards most of the contaminants have been flushed and treated through the groundwater plant therefore contaminant exposures through direct contact or air dispersion are minimal However all excavation work will be conducted in accordance with the requirements of the OSHA standard 29 CFR 1926650-652 as well as the Site Specific Health and Safety Plan (updated August 2004) Additionally the Site is secured by fence and locking gate

With regard to the implementation period protection is achieved immediately following the removal and restoration activities

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

There are no known technical difficulties associated with conducting the removal activity Administratively once the removal is approved by the USEPA and the NHDES the only other organization that requires coordination and approval efforts is the Turnkey Landfill located in Rochester NH Currently Waste Management which operates the landfill is in the process of reviewing the waste profile for acceptance into the landfill All other required services and resources are currently available through Woodard amp Curran

Keefe Environmental Services Site (Project 9342413) 5 08172004 revised tech memo_soil spoils area_2 doc

WOODARDampCURRAN

7 Cost

The estimated cost for employing this alternative is approximately $40000 which includes both direct and indirect expenditures There are no annual operations or maintenance cost associated with the excavation and off-site disposal recommendation

Modifying Criteria

8 State acceptance addresses the states position and concerns related to the preferred alternative

The State of NH supports this recommendation for excavation and off-site disposal

9 Community acceptance includes determining which components of the alternatives interested parties in the community support have reservations about or oppose

It is anticipated based on past activities at the Site that the community will accept this activity in that it will remove any future risk posed by the Soil Spoils area at the Site

Woodard amp Outran also recommends that as part of these activities the former decontamination pad and drum storage pad be broken up and disposed of off-site as part of the soil excavation and off-site disposal action While the former decontamination area does not pose a risk to human health removal of the structure will need to be conducted as part of the future closure activities Removal of this structure now will be cost-effective in that the equipment used to perform the excavation for the soils can be used to break up the concrete decon pad This material is not of significant volume and the costs for including the removal and disposal of this decon pad was included in the costs presented above

MLBmlb

9342413

Attachment(s)

cc Tom Andrews (NHDES) Karl Kasper (WampC) Dave Dedian (WampC)

Keefe Environmental Services Site (Project 9342413) 6 08172004 revised tech memo_soil spoils area_2 doc

WOODARDampCURRAN

7 Cost

The estimated cost for employing this alternative is approximately $40000 which includes both direct and indirect expenditures There are no annual operations or maintenance cost associated with the excavation and off-site disposal recommendation

Modifying Criteria

8 State acceptance addresses the states position and concerns related to the preferred alternative

The State of NH supports this recommendation for excavation and off-site disposal

9 Community acceptance includes determining which components of the alternatives interested parties in the community support have reservations about or oppose

It is anticipated based on past activities at the Site that the community will accept this activity in that it will remove any future risk posed by the Soil Spoils area at the Site

Woodard amp Outran also recommends that as part of these activities the former decontamination pad and drum storage pad be broken up and disposed of off-site as part of the soil excavation and off-site disposal action While the former decontamination area does not pose a risk to human health removal of the structure will need to be conducted as part of the future closure activities Removal of this structure now will be cost-effective in that the equipment used to perform the excavation for the soils can be used to break up the concrete decon pad This material is not of significant volume and the costs for including the removal and disposal of this decon pad was included in the costs presented above

MLBmlb

9342413

Attachment(s)

cc Tom Andrews (NHDES) Karl Kasper (WampC) Dave Dedian (WampC)

Keefe Environmental Services Site (Project 9342413) 6 08172004 revised tech memo_soil spoils area_2 doc

2

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KEEFE ENVIRONMENTAL SERVICE SITE SOIL SPOILS AREA EPPING NEW HAMPSHIRE SAMPLE LOCATIONS WOODARD amp CURRAN

QUALITY ASSURANCE PROJECT PLAN (QAPP) DESIGNED BY MLB

Table 1

Summary of Field Screening Results Soil Spoils Area - Keefe Environmental Services Site

Epping New Hampshire

Test Pit Location TP-01

Sample Date 070803

Soil Description Brown Till

Sample Depth (ft bgs)

1 -2

Total VOC Analyzer Results

(ppmv)

rp-os

TP-04

TP-05

TP-06

070803

070803

070803

Drainage Sand Brown Till Gray Till

Drainage Sand Brown Till Gray Till

Drainage Sand Brown Till

1 -2 5 - 6 70 1-2 5 - 6 70 1 - 2

00 00 00 00 00 00 00

TP-07

TP-08

TP-09

TP-10

TP-11

070803

070803

070803

070803

070803

Drainage Sand Brown Till Gray Till

Drainage Sand

Gray Till Drainage Sand

Brown Till

Drainage Sand

Gray Till Drainage Sand

Brown Till

70 1 - 2 5 6 70

5 - 6 70 1 -2

70

5 6 70 1-2

00 00 00 00

00 00 00 00 00

00 00 00

TP-12

TP 13

070803

070803

Drainage Sand

Gray Till Drainage Sand

70

5 - 6

00 00 00 00

TP-14 070803 Drainage Sand

Brown Till Gray Till

1 -2 3 - 4

00 00

Drainage Sand 7 0 00

Andoverprojects93424 nh des - epping nhwipTech MemoVTable 1_fieldresults xls Page 1 of 2

Table 1

Summary of Field Screening Results Soil Spoils Area - Keefe Environmental Services Site

Epping New Hampshire

Total VOC Sample Depth Analyzer Results

Test Pit Location Sample Date Soil Description (ftbgs) (ppmv) TP-15 070803 Brown Till 1 -2

Notes

ft bgs = feet below ground surface

VOC = Volatile organic compound

Total VOC (Volatile Organic Compound) Analyzer data obtained using Photovac Microtip

Model IS 3000 with 117 eV lamp hand-held photoionization detectors Readings are in

parts per million per volume (ppmv)

Shading indicates sample submitted to laboratory for analysis

Andoverprojects93424 nh des - epping nhwipTech MemoVTable 1_fieldresultsxls Page 2 of 2

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PQ O V V V V V V V V V rf | a -s 2 1V)(N f e -a 1 $P

o c o

1 sect

g 11 1 9 gt 1 1 1I c g p P pound D D P D D P D D P

f~ P i g S sect laquo sect S UJ O in t~- laquos TJ- o in vO 00 r-~ o mdashHc tj 00 o ro igt m OJ o 0 VO in VO v~gt g in m bull91 | 1 pound 1 |

^ S 0 ^ r^ laquoagt ON o lt V V V V V V V V V V V V

V V

Vo o ^ s 1 i 1 e 1 T3 ^ J2 g g ^ 2o s S -8 S sect -| 3O in

vo m in VO (N VO m m ( CN| in =i 1 e s1 M shyUS ^O CN vo VO o a mdash o S a W 2 1 1 I i

in (N in t in in r4 (N m VO m mco degs vd sl i-^lS rt 11 i i sect 1 1 S g g i S S euro amp

m m m ergt m m ro m m PI m m ro m rn mo O O o o O O O O O O O O O O O o () imdashlt

illl Li fll| CX J2 bull S c L ^ S S C C l ^ gt ^ oo oo 00 oo oo CO oo oo 00 00 oo oo OO oo 00O O O 0 0 O O O O O 0 O o sect O O CO bull S a f i i s 5 | a | | |1 Q Mr^ r-~ r~- r~- f- t^ r- r- t~- g S S amp sect 2 S 3 ^ pound |co o o S o o S B O 5 O o B pound B o o Q

ffi |MiS s sect isll bullsect S i ^ g - s s a - g s s i

u c h p S sect g 2 ^ S S g | ^ sectJB o a S g S c a B deg - f l r S J K o o o o o o o O o o O o 0 0

E amp bullSll^ll1^l1a -aa Ha CO CO CO CO CO CO S CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO a laquo g

OT j ro oo o o CN m m bull4 in m in VO 2 3 1 g | S laquo 5n2S g lt Kn S M W lt-gt ^ Q ~ n amp0 a pound eu fcCn dn PL OH OH PH OH sect f t 8 I | M - z

g d a v D - ^ t J c o Z H H pound H pound H H H amp amp H H amp

C

CO 13 CO

so 00 8

SO

CO 0)

W C3 O 0) 0)Q (0c oA (5u o I

01 (0

IDgt C

I 3 v i laquo lt 0) O u) bullbullbull pound = w0) O wQ Q- Q) o3 laquo o

S8 a i 2 Q)

-5 U)

ltN 00

00

Ox

v

so

r

00

SO

so

00

SO

00

V

llil I

1 I

S U

00

o o o

O

I I o

2 c 0)u

so V)

so SO so ltN

E g Sz e

Qo O N

U

B C

2-E

thyl

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thal

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- ts 1

Table 1

Summary of Field Screening Results Soil Spoils Area - Keefe Environmental Services Site

Epping New Hampshire

Test Pit Location TP-01

Sample Date 070803

Soil Description Brown Till

Sample Depth (ft bgs)

1 -2

Total VOC Analyzer Results

(ppmv)

rp-os

TP-04

TP-05

TP-06

070803

070803

070803

Drainage Sand Brown Till Gray Till

Drainage Sand Brown Till Gray Till

Drainage Sand Brown Till

1 -2 5 - 6 70 1-2 5 - 6 70 1 - 2

00 00 00 00 00 00 00

TP-07

TP-08

TP-09

TP-10

TP-11

070803

070803

070803

070803

070803

Drainage Sand Brown Till Gray Till

Drainage Sand

Gray Till Drainage Sand

Brown Till

Drainage Sand

Gray Till Drainage Sand

Brown Till

70 1 - 2 5 6 70

5 - 6 70 1 -2

70

5 6 70 1-2

00 00 00 00

00 00 00 00 00

00 00 00

TP-12

TP 13

070803

070803

Drainage Sand

Gray Till Drainage Sand

70

5 - 6

00 00 00 00

TP-14 070803 Drainage Sand

Brown Till Gray Till

1 -2 3 - 4

00 00

Drainage Sand 7 0 00

Andoverprojects93424 nh des - epping nhwipTech MemoVTable 1_fieldresults xls Page 1 of 2

Table 1

Summary of Field Screening Results Soil Spoils Area - Keefe Environmental Services Site

Epping New Hampshire

Total VOC Sample Depth Analyzer Results

Test Pit Location Sample Date Soil Description (ftbgs) (ppmv) TP-15 070803 Brown Till 1 -2

Notes

ft bgs = feet below ground surface

VOC = Volatile organic compound

Total VOC (Volatile Organic Compound) Analyzer data obtained using Photovac Microtip

Model IS 3000 with 117 eV lamp hand-held photoionization detectors Readings are in

parts per million per volume (ppmv)

Shading indicates sample submitted to laboratory for analysis

Andoverprojects93424 nh des - epping nhwipTech MemoVTable 1_fieldresultsxls Page 2 of 2

(NIsect vo t VO O VO fgt in VO 0 ltbull ro VO Tj- 5 in VO rrgt ^t Tt bulln CN rH CN m

0 ^ r^ V V V V V V V V V 00 V O s V V sectVX ^ laquolaquo

gtgt u o O O in o O OO 0 o o (- o I- O^H rmdashf ltN ^ S sect CN (N bullt bulln (N 1 bullt DO O s i V bullf V Vs - V V V V V V V V V V J^ Vsect~ S-8

1

1

3 i shy o 1

oS pound amp g o o o in 0 O 0 0 o O

IT)

soo ltltJ t-^ (N (N bull gtn (N bull-H 00 on tfgtltC o a

bull0 iH uo -S V V V V Von O V V V V V V V V bull gtmdashi -t-j cx z

O 6(0 fi M o mvo o CN

O O tmdash4 m bulln vo cs q r- VO VO ^o ^t in

Met

hyle

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hlor

ide

Tol

uene

(0a bull bullltt ro bullltt m r-laquoTl- CN fN mCN 1 IO V V V V V ltN V V V VV V V V V 1V 1bulla tlaquo o u

Sa re

Vola

tile

Orj a

nic C

om

poiSx

agt

D)

bulla a5 r- 3 vo CN a Tt VO o VO m m vO rN CN s bull m ^o TT m bull m CN cc m 1m q mdashi rn ^o ZV V V V V V CN V CN VV V V V V 1V -

V V CO deg

S S O 11 aQ a - CN

^S o vo Ov Tjshy raquo-H CN O en sect1 gtraquo CO v-i vO Tt vO ^f 00 bulls ao

VO VO VO gtn bull bullltt bulllaquot CN bull (N

i CO (N mc4 bullltfr C N V) o rtC3 _

V VV fD VV V V V bull0 u J2 -^w | V V VO lt O 1V VVCM ^H o =S w OjQ) -st- 1a

Z2

3 3n O = gt 51

o o o o oo O O vp r~7 o IIltN (N sect ltn in rsl ^H

mdashH i ryi o s oo

bulla laquo ST bull- imdashi V V V V V V V VV V

-raV V V V V gt- 2a0) deg Q) = w (0 1 u 1^ ca mdash rt p cx r

8 a a -Mo 2 secto 0 o O 00 0 o vp [- o S s pound

(U 8 pound CN ltN 3 t-~ in (N rmdash1 sect O oefl PL] 00 $ ON sect 1 IS sectgta o V V V V V V ^ sectbull S sect P

PQ O V V V V V V V V V rf | a -s 2 1V)(N f e -a 1 $P

o c o

1 sect

g 11 1 9 gt 1 1 1I c g p P pound D D P D D P D D P

f~ P i g S sect laquo sect S UJ O in t~- laquos TJ- o in vO 00 r-~ o mdashHc tj 00 o ro igt m OJ o 0 VO in VO v~gt g in m bull91 | 1 pound 1 |

^ S 0 ^ r^ laquoagt ON o lt V V V V V V V V V V V V

V V

Vo o ^ s 1 i 1 e 1 T3 ^ J2 g g ^ 2o s S -8 S sect -| 3O in

vo m in VO (N VO m m ( CN| in =i 1 e s1 M shyUS ^O CN vo VO o a mdash o S a W 2 1 1 I i

in (N in t in in r4 (N m VO m mco degs vd sl i-^lS rt 11 i i sect 1 1 S g g i S S euro amp

m m m ergt m m ro m m PI m m ro m rn mo O O o o O O O O O O O O O O O o () imdashlt

illl Li fll| CX J2 bull S c L ^ S S C C l ^ gt ^ oo oo 00 oo oo CO oo oo 00 00 oo oo OO oo 00O O O 0 0 O O O O O 0 O o sect O O CO bull S a f i i s 5 | a | | |1 Q Mr^ r-~ r~- r~- f- t^ r- r- t~- g S S amp sect 2 S 3 ^ pound |co o o S o o S B O 5 O o B pound B o o Q

ffi |MiS s sect isll bullsect S i ^ g - s s a - g s s i

u c h p S sect g 2 ^ S S g | ^ sectJB o a S g S c a B deg - f l r S J K o o o o o o o O o o O o 0 0

E amp bullSll^ll1^l1a -aa Ha CO CO CO CO CO CO S CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO a laquo g

OT j ro oo o o CN m m bull4 in m in VO 2 3 1 g | S laquo 5n2S g lt Kn S M W lt-gt ^ Q ~ n amp0 a pound eu fcCn dn PL OH OH PH OH sect f t 8 I | M - z

g d a v D - ^ t J c o Z H H pound H pound H H H amp amp H H amp

C

CO 13 CO

so 00 8

SO

CO 0)

W C3 O 0) 0)Q (0c oA (5u o I

01 (0

IDgt C

I 3 v i laquo lt 0) O u) bullbullbull pound = w0) O wQ Q- Q) o3 laquo o

S8 a i 2 Q)

-5 U)

ltN 00

00

Ox

v

so

r

00

SO

so

00

SO

00

V

llil I

1 I

S U

00

o o o

O

I I o

2 c 0)u

so V)

so SO so ltN

E g Sz e

Qo O N

U

B C

2-E

thyl

hexy

l)ph

thal

ate

- ts 1

Table 1

Summary of Field Screening Results Soil Spoils Area - Keefe Environmental Services Site

Epping New Hampshire

Total VOC Sample Depth Analyzer Results

Test Pit Location Sample Date Soil Description (ftbgs) (ppmv) TP-15 070803 Brown Till 1 -2

Notes

ft bgs = feet below ground surface

VOC = Volatile organic compound

Total VOC (Volatile Organic Compound) Analyzer data obtained using Photovac Microtip

Model IS 3000 with 117 eV lamp hand-held photoionization detectors Readings are in

parts per million per volume (ppmv)

Shading indicates sample submitted to laboratory for analysis

Andoverprojects93424 nh des - epping nhwipTech MemoVTable 1_fieldresultsxls Page 2 of 2

(NIsect vo t VO O VO fgt in VO 0 ltbull ro VO Tj- 5 in VO rrgt ^t Tt bulln CN rH CN m

0 ^ r^ V V V V V V V V V 00 V O s V V sectVX ^ laquolaquo

gtgt u o O O in o O OO 0 o o (- o I- O^H rmdashf ltN ^ S sect CN (N bullt bulln (N 1 bullt DO O s i V bullf V Vs - V V V V V V V V V V J^ Vsect~ S-8

1

1

3 i shy o 1

oS pound amp g o o o in 0 O 0 0 o O

IT)

soo ltltJ t-^ (N (N bull gtn (N bull-H 00 on tfgtltC o a

bull0 iH uo -S V V V V Von O V V V V V V V V bull gtmdashi -t-j cx z

O 6(0 fi M o mvo o CN

O O tmdash4 m bulln vo cs q r- VO VO ^o ^t in

Met

hyle

neC

hlor

ide

Tol

uene

(0a bull bullltt ro bullltt m r-laquoTl- CN fN mCN 1 IO V V V V V ltN V V V VV V V V V 1V 1bulla tlaquo o u

Sa re

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tile

Orj a

nic C

om

poiSx

agt

D)

bulla a5 r- 3 vo CN a Tt VO o VO m m vO rN CN s bull m ^o TT m bull m CN cc m 1m q mdashi rn ^o ZV V V V V V CN V CN VV V V V V 1V -

V V CO deg

S S O 11 aQ a - CN

^S o vo Ov Tjshy raquo-H CN O en sect1 gtraquo CO v-i vO Tt vO ^f 00 bulls ao

VO VO VO gtn bull bullltt bulllaquot CN bull (N

i CO (N mc4 bullltfr C N V) o rtC3 _

V VV fD VV V V V bull0 u J2 -^w | V V VO lt O 1V VVCM ^H o =S w OjQ) -st- 1a

Z2

3 3n O = gt 51

o o o o oo O O vp r~7 o IIltN (N sect ltn in rsl ^H

mdashH i ryi o s oo

bulla laquo ST bull- imdashi V V V V V V V VV V

-raV V V V V gt- 2a0) deg Q) = w (0 1 u 1^ ca mdash rt p cx r

8 a a -Mo 2 secto 0 o O 00 0 o vp [- o S s pound

(U 8 pound CN ltN 3 t-~ in (N rmdash1 sect O oefl PL] 00 $ ON sect 1 IS sectgta o V V V V V V ^ sectbull S sect P

PQ O V V V V V V V V V rf | a -s 2 1V)(N f e -a 1 $P

o c o

1 sect

g 11 1 9 gt 1 1 1I c g p P pound D D P D D P D D P

f~ P i g S sect laquo sect S UJ O in t~- laquos TJ- o in vO 00 r-~ o mdashHc tj 00 o ro igt m OJ o 0 VO in VO v~gt g in m bull91 | 1 pound 1 |

^ S 0 ^ r^ laquoagt ON o lt V V V V V V V V V V V V

V V

Vo o ^ s 1 i 1 e 1 T3 ^ J2 g g ^ 2o s S -8 S sect -| 3O in

vo m in VO (N VO m m ( CN| in =i 1 e s1 M shyUS ^O CN vo VO o a mdash o S a W 2 1 1 I i

in (N in t in in r4 (N m VO m mco degs vd sl i-^lS rt 11 i i sect 1 1 S g g i S S euro amp

m m m ergt m m ro m m PI m m ro m rn mo O O o o O O O O O O O O O O O o () imdashlt

illl Li fll| CX J2 bull S c L ^ S S C C l ^ gt ^ oo oo 00 oo oo CO oo oo 00 00 oo oo OO oo 00O O O 0 0 O O O O O 0 O o sect O O CO bull S a f i i s 5 | a | | |1 Q Mr^ r-~ r~- r~- f- t^ r- r- t~- g S S amp sect 2 S 3 ^ pound |co o o S o o S B O 5 O o B pound B o o Q

ffi |MiS s sect isll bullsect S i ^ g - s s a - g s s i

u c h p S sect g 2 ^ S S g | ^ sectJB o a S g S c a B deg - f l r S J K o o o o o o o O o o O o 0 0

E amp bullSll^ll1^l1a -aa Ha CO CO CO CO CO CO S CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO a laquo g

OT j ro oo o o CN m m bull4 in m in VO 2 3 1 g | S laquo 5n2S g lt Kn S M W lt-gt ^ Q ~ n amp0 a pound eu fcCn dn PL OH OH PH OH sect f t 8 I | M - z

g d a v D - ^ t J c o Z H H pound H pound H H H amp amp H H amp

C

CO 13 CO

so 00 8

SO

CO 0)

W C3 O 0) 0)Q (0c oA (5u o I

01 (0

IDgt C

I 3 v i laquo lt 0) O u) bullbullbull pound = w0) O wQ Q- Q) o3 laquo o

S8 a i 2 Q)

-5 U)

ltN 00

00

Ox

v

so

r

00

SO

so

00

SO

00

V

llil I

1 I

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00

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so V)

so SO so ltN

E g Sz e

Qo O N

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(NIsect vo t VO O VO fgt in VO 0 ltbull ro VO Tj- 5 in VO rrgt ^t Tt bulln CN rH CN m

0 ^ r^ V V V V V V V V V 00 V O s V V sectVX ^ laquolaquo

gtgt u o O O in o O OO 0 o o (- o I- O^H rmdashf ltN ^ S sect CN (N bullt bulln (N 1 bullt DO O s i V bullf V Vs - V V V V V V V V V V J^ Vsect~ S-8

1

1

3 i shy o 1

oS pound amp g o o o in 0 O 0 0 o O

IT)

soo ltltJ t-^ (N (N bull gtn (N bull-H 00 on tfgtltC o a

bull0 iH uo -S V V V V Von O V V V V V V V V bull gtmdashi -t-j cx z

O 6(0 fi M o mvo o CN

O O tmdash4 m bulln vo cs q r- VO VO ^o ^t in

Met

hyle

neC

hlor

ide

Tol

uene

(0a bull bullltt ro bullltt m r-laquoTl- CN fN mCN 1 IO V V V V V ltN V V V VV V V V V 1V 1bulla tlaquo o u

Sa re

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tile

Orj a

nic C

om

poiSx

agt

D)

bulla a5 r- 3 vo CN a Tt VO o VO m m vO rN CN s bull m ^o TT m bull m CN cc m 1m q mdashi rn ^o ZV V V V V V CN V CN VV V V V V 1V -

V V CO deg

S S O 11 aQ a - CN

^S o vo Ov Tjshy raquo-H CN O en sect1 gtraquo CO v-i vO Tt vO ^f 00 bulls ao

VO VO VO gtn bull bullltt bulllaquot CN bull (N

i CO (N mc4 bullltfr C N V) o rtC3 _

V VV fD VV V V V bull0 u J2 -^w | V V VO lt O 1V VVCM ^H o =S w OjQ) -st- 1a

Z2

3 3n O = gt 51

o o o o oo O O vp r~7 o IIltN (N sect ltn in rsl ^H

mdashH i ryi o s oo

bulla laquo ST bull- imdashi V V V V V V V VV V

-raV V V V V gt- 2a0) deg Q) = w (0 1 u 1^ ca mdash rt p cx r

8 a a -Mo 2 secto 0 o O 00 0 o vp [- o S s pound

(U 8 pound CN ltN 3 t-~ in (N rmdash1 sect O oefl PL] 00 $ ON sect 1 IS sectgta o V V V V V V ^ sectbull S sect P

PQ O V V V V V V V V V rf | a -s 2 1V)(N f e -a 1 $P

o c o

1 sect

g 11 1 9 gt 1 1 1I c g p P pound D D P D D P D D P

f~ P i g S sect laquo sect S UJ O in t~- laquos TJ- o in vO 00 r-~ o mdashHc tj 00 o ro igt m OJ o 0 VO in VO v~gt g in m bull91 | 1 pound 1 |

^ S 0 ^ r^ laquoagt ON o lt V V V V V V V V V V V V

V V

Vo o ^ s 1 i 1 e 1 T3 ^ J2 g g ^ 2o s S -8 S sect -| 3O in

vo m in VO (N VO m m ( CN| in =i 1 e s1 M shyUS ^O CN vo VO o a mdash o S a W 2 1 1 I i

in (N in t in in r4 (N m VO m mco degs vd sl i-^lS rt 11 i i sect 1 1 S g g i S S euro amp

m m m ergt m m ro m m PI m m ro m rn mo O O o o O O O O O O O O O O O o () imdashlt

illl Li fll| CX J2 bull S c L ^ S S C C l ^ gt ^ oo oo 00 oo oo CO oo oo 00 00 oo oo OO oo 00O O O 0 0 O O O O O 0 O o sect O O CO bull S a f i i s 5 | a | | |1 Q Mr^ r-~ r~- r~- f- t^ r- r- t~- g S S amp sect 2 S 3 ^ pound |co o o S o o S B O 5 O o B pound B o o Q

ffi |MiS s sect isll bullsect S i ^ g - s s a - g s s i

u c h p S sect g 2 ^ S S g | ^ sectJB o a S g S c a B deg - f l r S J K o o o o o o o O o o O o 0 0

E amp bullSll^ll1^l1a -aa Ha CO CO CO CO CO CO S CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO a laquo g

OT j ro oo o o CN m m bull4 in m in VO 2 3 1 g | S laquo 5n2S g lt Kn S M W lt-gt ^ Q ~ n amp0 a pound eu fcCn dn PL OH OH PH OH sect f t 8 I | M - z

g d a v D - ^ t J c o Z H H pound H pound H H H amp amp H H amp

C

CO 13 CO

so 00 8

SO

CO 0)

W C3 O 0) 0)Q (0c oA (5u o I

01 (0

IDgt C

I 3 v i laquo lt 0) O u) bullbullbull pound = w0) O wQ Q- Q) o3 laquo o

S8 a i 2 Q)

-5 U)

ltN 00

00

Ox

v

so

r

00

SO

so

00

SO

00

V

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1 I

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o o o

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C

CO 13 CO

so 00 8

SO

CO 0)

W C3 O 0) 0)Q (0c oA (5u o I

01 (0

IDgt C

I 3 v i laquo lt 0) O u) bullbullbull pound = w0) O wQ Q- Q) o3 laquo o

S8 a i 2 Q)

-5 U)

ltN 00

00

Ox

v

so

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00

SO

so

00

SO

00

V

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1 I

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