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i;IRTIPII Q JCAIL -- Q TDRlf RECEIPT UOVl!BTIQ

February 14, 1990

Ruaaell w. Bartley, P. E. Remedial Action Coordinator TRC Environmental Conaultanta, Inc. 800 Connecticut Blvd. Eaat Hartford, CT 06108

Re: Beacon He iqhta Landfill Superfund Site: EPA Cpmments on Pre -Otaiqn Study ReOprt Reyis ion 1

Dear Kr . Bartley:

Thia letter preaenta comment• of the United statea Environmental Protection Agency (EPA) on the Pre-Oeaiqn Study Reviaion 1 received by EPA on December 22, 1989 (the Report), which was prepared by Canonie Environmental Service• Corp. on behalf of the Beacon Heiqhta Generator• coalition (BHGC) reqarclinq the Beacon Heiqhta Landfill Superfund Site in Beacon Falla, conn,cticut.

EPA rejecta the Report. In accordance with Section IV (E) of the Conaent Decree dated. September 15, 1987 in Ynit,ed St.•t.•• y B F GoOOrich Cpmpony at ol (0. conn. civ. No. N-87-286), EPA diaapprovea the Report becauae it faila to provide EPA with the information neceaaary to evaluate the remedial action alternative• presented in the Report. EPA 11uat be able to evaluate the alternatives in terms of the nine evaluation ·criteria set forth in Section 6.2 . 3 of OSWER Directive 9355 . 3-01, "Guidance for Conductinq Remedial Investiqations and Feaa ibility Studie s Under CERCLA." All n i ne criteria must be addreaaed in the resubmisaion: more specifically, the Report failed to and must address the attached comment• in t e rms of thoae cri t eria involvinq the reduct ion of toxi city, abort- t erm eff ectiveness, implementabili ty, State acceptance, and community acceptance. On this l a s t poi nt , a s waa s t at ed in a let t er t o you from Eric van Gestel dated January 10, 1990, EPA cannot evaluat e the feaaibi l i t y of off- site leachate treatment unless it receives documentation t hat Beacon Fal ls would allow discharqe of leachate from the Site t o t he POTW.

The attached numbered comments address in detail the deficiencies that remain and outline the work that IIUBt be done in order to resubmit the Report t o EPA for final review and approval. By

transmittal of the comments in this letter anci attachment, EPA does not waive, but expressly reserves, all riqhts to comment on

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Ruaaell w. Bartley, P.E. Page 2

any and all aspects of the Pre-Oeaiqn study performed to date or yet to be performed.

In accordance with Section IV (E) of the Consent Decree, BHGC must address each of the comments in this letter and the attachment, correct any deficiencies, and resubmit the Pre­Design Study. Under Section IV (E) (1) of the Consent Decree, the

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Pre-Oeaiqn study Revision .a, must be submitted to EPA within 30

thirty daya from your receipt of this letter. HIDzm

The proposed changes to the RCRA cap to minimize leachate H~

.... o))Zproduction (changing the cap to cover the aides a a well aa the "'"~top of the landfill and changing the thick:neaa, permeability, or _,I

number of layara of the synthetic membrane) are not fundamental Hffl<H

changes that would require the 1985 ROD to be "reopened" under mG>

the proviaiona of 112l(b) of SARA (Pub. L. 99-499, october 17 , , I.... 1986). such detail• of the cap design therefore need not comply m en

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with 1121 of CERCLA.; they are within the contemplated design 0suchdecisions of the pre•SARA 1985 ROD regarding the RCRA cap.

0detail• of the cap d.eaiqn need not be tully preaented in the Pre- "::f: :~=~s:e~!:~~~u!;.~utE;;1;n£tcf;::;:•:h:: :f':r:•::::tl1ity analyaia and extenaive aubaidence teatinq analyaia will need to be perforwed prior to approval of any final cap deaign~

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In contraat, the remedial ••••urea that auat co.ply with 1121 of CERCLA., that auat be fully presented in the Pre•Deaign Study Reviaion 2, and that will be addreaeed in a aupplaaental ROD are: •(1) the manner and location of l e achate treatment (onaite

veraua offaite) ;

(2) the need, if any, for air pollution controls on t he landfill gaa vents : and

(3) the extant of excavation of soil in the aatallita areas 8=·that are presently outaida the main landfill area to be capped. (areas of wasta, contaminated soils, leachate seeps and breakout areaa, and sludge, including without limitation

I · Betkowaki's Landfill) that will be consolidated and placed NI on top of the landfill prior to capping. Nota that thia

third measure may be related to the extent of the square footage and the coat of the final cap design. The

1If aa design progresses, however, the cap design begins to appear to EPA to be fundamentally different from the 1985 ROD's cap provisions, the 1985 ROD would have to be supplemented or reopened to address a cap design that would be required to meet 1121 of CERCLA.. .

Russell w. Bartley, P.E. Page 3

resubmission must specify the standards governing the determination of which soils must be excavated and consolidated and must specify the volumes and extent of contaminated soils to be excavated. The reaubmission must, at a minimum, address the criteria eet forth in Section III ot the Remedial Action Plan at A-5, including without limitation the protection of human health, welfare, and the environment.

Please be aware that the next submittal from BHGC will constitute the second resubmiasion for purposes of Section IV (E) ( 4) of the consent Decree, which provides that if a report is not approved by EPA after two resubmissions, the defendants s hall be deemed to be out of compliance with the consent Decree. Therefore it the resubmission due within thirty days of this letter is not approvect by EPA, BHGC s hall be deued to be out of compliance with the consent Decree and EPA may seek s tipulated penalties for failure to comply with the Consent Decree, as well as exercising any anct all rights available to it under the Consent Decree.

It you have any ques tions, please contact Eric van Gestel of •Y staff at (617) 573-5726. All colDJilunication from counsel shoulct be directed to Julie Taylor (who has replaced Gregory J:ennan as the site attorney), Assistant Regional Counsel, u . s. . Envirom~ental Protection Agency, Office of Regional Counsel, JFX Federal Building RC0-1903, Boston, MA 02203, (617) !565-3430.

Sincerely,

~s~ Merrill s. Hohman, Director waste Management Division

Enclosures

cc: /Eric van Geatel, EPA Remedial Project Manager Julie Taylor, EPA Assistant Regional Counsel Thomas Harrison, Beacon Heights Generator Coalition Susan H. Shumway, Beacon Heights Generator Coalition Robert Smith, uniroyal, Inc. Erica Peach, Connectic~t Department of Environmental Protection

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~ Attachment to Letter to Ruaaell W. Bartley

EPA COMMENTS ON BEACON HEIGHTS LANDFILL PRE-DESIGN STUDY REPORT REVISION 1

General Pre-Deaiqn Study Reyision comments

1) Aa waa aet rorth in the January 10, 1990 letter to Russell Bartley from Eric van Geatal of' EPA, which ia incorporated l>

into thaae comment• by reference, the reaubmiaaion must 0

H<lldocuaant whether or not there ia any reason at this time to "'zmbelieve that the authority having jurisdiction over the Hl>

Beacon Palla publicly owned treatment work& (POTW) would. -<0accept the leachate for treatment there.

l>:ozEPA requires the "'"

Beacon Heights Generator coalition (BHGC) to submit evidence -<IHl'lacceptable to EPA that the PO'l'W authority has indicated to <H

BHGC (by authority vote or by l atter to BHGC or by otherverifiable formal indications) that the authority ia "'"'I

inclined to accept the leachate from the Beacon Heighta ""'"'"'"'0X.ndfill! If the reaubmiaaion faila to provide auch

evidence, EPA cannot evaluate the feasibility of off-site "'0

leachate treatment and will have to consider only on-aite leachate treat..nt altemativea.

:Z) With reference to Section 7.5.1.1 of the Pre-DeaiCJn Study Reviaion 1, BHGC auat provide EPA with detailedclOCUilentation aupporting the statement in the third paragraph of page 75 that:

the quantity and quality of leachate to be discharged to the POTW (baaed on data currently available) indicate that the discharge could be· treated by the POTW without interfering with POTW operation (including aludge disposal) and without degrading the receiving water quality.

•=gEPA requires this supporting documentation in order to

evaluate the technical feasibility of treatment of the leachate by the POTW aa the recommended alternative. BHGC must therefore provide EPA with aa much information in aa detailed form as possible regarding all technical aspects of POTW upgrade necessities proposed, pass-through potentials, Ntreatment and pre-treatment pendts necessary and documentation of application to obtain them, and projectedcoats for POTW upgrade and treatment or the leachate.

J) BHGC must provide EPA with documentation that all permit applications are in the process or being completed within the necessary timerrames.

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EPA comment• -- Beacon Heights Pre-Design study R8viaion 1 Page 2

4) In reference to the bottom of page 3 of the Pre-Design study Raviaion where BHCC recommends that "the supplemental ROD address capping of the landfill in addition to the leachate treatment and landfill gas venting issues," EPA is not at this point opposed to changing the cap desiqn presented in the Remedial Action Plan to one with both an impermeable top and impermeable aides provided EPA has sufficientinformation to evaluate such a new cap design. However, detailed deaiqn of a new cap design will taka place during

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the preliminary phases of Remedial Deaiqn of the project; :tHIDsuch details of the cap daaiqn need not be fully presented zm

in the pre-Design Study and therefore need not be tully Hl>

addreaaed in the Supplemental ROD. EPA will make a final ""':ozdeciaion at a later point aa to whether and how any -<0

deciaiona modifying the cap should be documented in a formal ~IHmEPA deciaion document. <H

"'":r atatea that "There are no regulation• apecif'ically related '""'nto the discharge concentration• of leachate." Thia 0

:0atat..ent ia incomplete and therefore irrelevant becauae 0

there are regulation• related to diapoaing, diacharginq, or tranaportinq the leachate, auch •• requlationa under RCRA

5) Page 15, Section 2. 2. 1 of the Pre-Deaign Study Reviaion 1 :0-<

and the NPDES proqr••· Theae regulation• muat be. addreaaed in the reaubmiaaion.

6) In reference to page 19, Section 2.3.1, truckinq of the waate to an off-aite facility will require a RCRA aanif'eat if the waate ia a hazardoua waate under 40 CFR 261.

7) In reference to page 50, third paragraph, "(EPA 1980)" ia an incomplete reference to any EPA guidance document you may have intended to reference. The resubmiaaion muat refer to apecif'ic and relevant EPA atandarda and auat alaoincorporate aite apecif'ic values.

8) Page 73 of the Pre-Deaign Study makes an aasumption that reaidual treatment by-product waatea would be diapoaed of on-aite. BHGC must provide EPA with documentation aa to the probable type and quantity of reaiduala left in place and what ARAR and permit restrictions might apply to on-site diapoaal of these residuals. (RCRA Land Ban Restrictions and Notification• may apply).

9) In accordance with Attachment III of the Remedial Action Plan, BHGC must supply EPA with the originals or legible reproducible copies of the surveys and field book.a tor the topographic land survey and site plan.

EPA Couanta -- Beacon Haighta Pre-Design Study Revision 1 Page 3

Pra-Ptsign Study Reyiaion Comments Pertaining to Air

10) Table 26, titled Air Quality control criteria, ot the Pre­Oesiqn study Revision 1, inclicatea that aeveral ot the odor threshold limits have been exceeded at the property line. BHGC must document what measures will be required to bring these levels down to the acceptable odor threshold limits.

11) With regard to response no. 21 in the letter to EPA dated ~December 1, 1989 from Canonie Environmental services Corp. 3

HCOon behalf ot BHGC regarding the Beacon Heights Landfill zm

H]>Superfund Site, which contained responses to EPA couants on U>nthe tirat submission ot the Pre-Design Study, the --<0

:uzConnecticut Hazardous Air Pollutant Regulations discussed l>

are ~, in tact, health-risk-basad. They are adopted from -<J: < H

not r e levant to EPA 1s evaluations regarding Federal "'"J:worker exposur e l evel s which are not risk-baaed and thus are H"'

,__,Superfund sites. Therefore, a risk assessment ot landfill gas eaiasions aust be partorllad by the and ot Daa iqn phase. "'"'n

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12) Again, with r egard to reaponsa no. 21 in the Dacaabar 1, 0

1989 latter, "con4itions siailar to an uncapped 1an4till" will not necessarily axiat attar capping. The cap aay raise the taaperature and increase the generation ot gas.P'U.rtheraore, it vents are to be installed in the Cap (point source) it aay be expected to have a different impact than an uncapped landfill (area source). The maximum ground laval concentrations at the property boun4ary aight DQt be aiailar to those actual measurements (provided in Tables 21 and 22 ot the Pre-Design Studies report). Modelingtherefore ia required during the early stages ot the RamacUal Design phase.

••,.13) With r egard to responses nos. 22, 26, and 27 in Canonie'a

December 1, 1989 l atter, analyzing the secondary (back-up) traps would have provided the additional data to support the estimated value reported tor the priaary traps. BHGC must analyze all secondary traps and provide EPA with the resulting data. 8

14) With regard to response no. 23 in the December 1, ·1989 Nlatter, BHGC must provide information supporting how the surrogate control limits were established.

15) With regard to response no. 27 in the December 1, 1989 latter, BHGC must define "Default Limits" and provide the method validation pro~edure used.

EPA Co11111enta -- Beacon Heights Pre-Design Study Revision 1 Page 4

Given the problema encountered with gas vent monitoring and16) the fact that the maximum allowable stack concentrationswere baaed only on the Tedlar Bag data from one vent, BHGC muat make provisions to monitor the effect of capping on the landfill emissions. This would provide a more realisticassessment of gas emhaions from the landfill and thenecessary information to determine if a gas treatment system would be needed. BHGC mus t design this gas emissionmonitoring program by the end of the Remedial Action Work Plan approval phase.

17) Venting of the landfill does not require a permitapplication. However, the venting system must comply with section 22a-174-29, The Hazardous Air Pollutant Regulations (i.e. Maximum Allowable Concentrations) as well as The Odor Threshol d Li mits as presented in Table 8-1 of section 22a- · 174- 23 of the regulations.

Pra• Ptlign St udy Rey ilion c ogent s Pertaini ng to t h e

Sewer syatg

18) With regard to r esponse no. 15 in canonie ' s lette r to EPA elated Decellber 1, 1989, the risk to sewe r 11aintenance worker s from exposure to the l eachate mus t be calculated and i ncluded in the r e submiaaion to ens ure that it doesn't put the workers at an unacceptable r isk l eve l. This i ssue i s r e lated to protection of huaan health, one of the crite ria EPA a us t uae to evaluate any proposed alternative , including one r e latinq to offsite l e achate treatment. (The ris k calculation should assume no loaa e n route to the POTW and s hould aaauae exposure at a aximum concentrations. ) Compli ance with OSHA Permissible Exposure Limits (PELs) is Illnot s uff i cient. Because Supe r f und is a r isk-baaed program, ,.•this a nd other risks must be evaluated quantit atively.

19) Response no. 7 in Canonie'a letter dated December 1, 1989 states that "Prior to the cUsposa1 of leachate to the P0'1'W, the sewer line along Route 42 will be evaluated through a television inspection of the pipeline and/or pressuretesting if necessary. Sections of the line shoving defects 8will be addressed prior to discharge of leachate to the system." BHGC must incorporate this statement in the Nresubmission of the Pre-Design Study, and must address the issue of whether additional testa, s uch as those estimatingcorrosion potential, should also be included in any evaluation of the sewer line.

20) Response no. 8 in the December 1, 1989 Canonie letter states regarding the sewer system that "Further hydraulic analyses will be performed as part of RD and modificationsmade to the sewer line piping or leachate handlinq system

EPA Comments -- Beacon Heights Pre-Design Study Revision 1 Page .5

(e.g., holding baain to discharge leachate during off-peak houra if neceasary) to enaura aufficiant ayatam capacity as necessary." Thia atatemant muat be incorporated in the reaubmiaaion of the Pre-Design study.

Pre-oeeign Study Royiaion Cotpmente Pertaining to Leachate and Sludge Prgtection

21) With regard t o raaponae no. 17 in Canonie 1a latter to EPA dated December 1, 1989, the muJ.mlm muat be used i nstead of the JU4iAn in observed leachate concent r a tion , and aa i ndicated above, a risk level muat be c omputed f or worker exposure.

22 ) Response no. 14 in the December 1, 1989 l etter atatea t hat "Furthe r bench- and pilot-acale testing wi ll be per f ormed. for the purpose of apecific equi paent sel ection and aizing during the RD phaae . The potential for metals r - obilization will be dete rmined at that time and proceaa concUtions modified appropriately to preclude the production of a hazardous sludge a s a res ult of traataent .• Thia stat-ant •ust be incorporated into the reaubaiaaion of the Pre-Design study.

Pra-Diwiqn Study Reyilign Comme nt• Pertaining to Spil Cpntom1nant Concentrotion ond Expayotipn Crite rio

2 3) With r egard to r esponse no. 41 in Canonia • a l etter to EPA dated. Dec&JDber 1, 1989, the r eport s till faila to addreaa the potential threat to human health and the environaent associated wi th the excavati on of contami nated aoil and waat e f ro11 sat ellite areas and i ta transport and deposit i n the aain l andfi ll a r ea . The r esubmiasion mus t addr ess t his potential threat in sufficient detail t or EPA t o evaluate the recommended alternatives .

24) Cleanup level• in soil must be determined f or each contaminant of concern identified in the FS by back calculating from the appropriate MCL/KCI.G or the 10·6 risk level or reference dose when the KCL/KCLG is unavailable. Note: the proposed MCL for lead should be used (.5 ug/1). Additionally, the Interim Guidance that is the reference for soil lead levels of 500-1,000 ppm applies only to direct contact exposure scenarios. Although the direct contact exposure risk must be calculated, this guidance should not be applied to the other risk that must be calculated regarding the Beacon Heights Landfill, which is the risk of exposure via leaching into groundwater .

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EPA ColiJDenta -- Beacon Height• Pre-Design Study Revision 1 Page 6

25) Aa mandated in the Remedial Action Plan, which ia incorporated in the Consent Decree aa Appendix A, BHQC mu.st meet the objectives set forth in Attachment III (2) regarding the excavation of contaminated aoila. The reaubmiaaion muat, at a minimum, identify those satellite areas of contamination which cannot be effectively capped in place and need to be placed under the Main Landfill Cap and specify the volumes and extent of contaminated soils to be excavated.

26) X.vels up to, but not exceeding, Connecticut Action X.vela tor drinkin; water must be met f or soil excavation criteria asaUIIin<J scenarios of leaching into groundwater. Response no. 35 in the Canonie December 1, 1989 letter atates that •[s]ince contaminant reduction must occur during migration, allowable l evela greater than drinking water standards are cons idered appropriate. • This i a incorrect , leaving conta•inated soils above Connecticut Action Level• for drinking water i a unacceptable aa the excavation criteria .

27) Page 47 of the Pre-Design study Revision 1 atatea that "the extent of capping waa [also) baaed on a coat evaluation of the benefit of capping in place versus excavating and ..-, consolidating soila and waste in the main body of, the

,-....) landfill. The break even point for excavation ia at depth of about 12 to 15 feet at which point it ia more coat effective to cap in place, assWiing the previoua criteria are satisfied. • The resubmission aust provide detailed documentation and calculations to support this concluaion on the coat-effective aapects of the deciaion regarding the extent of capping.

28) In reference to the aecond paragraph of page 50 of the Revision 1, the reaubmiaaion mus t calculate the s oil-water partition coefficients f or each constituent:

II, • (F,.) (II,.) I

where: ~ • soil-water partition coefficient Foc • fraction of organic carbon Xoc • octanal water partition coefficient

29) The resubmiasion must document, including the indication of any references relied upon, how the leachability and attenuation values were derived.

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EPA couenta -- Beacon Heights Pre-Design Study Revision 1 .page 1

30) The resubmission :must specify which quidance is referred to in the last paragraph of page 50, which statea that •[a]ccorclingly, the aelection of these parameters ia consistent with, or more conservative than, requlatorysmJ.4Ana for back calculating allowable soil concentrations. • (emphasis added). The reaubmiaaion auat also indicate which values are being compared to the para..ters. ~

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31) In reference to page 51, the tirat paragraph, the zm HJ>resubaiasion must calculate the groundwater flux for the CI>O

site in the fractured bedrock. The top of page 51 atatea -<0

that • [i]nfiltration, thus, baa no bearing on the allowable ,.:oz -<:J:soil contaminant concentration.• This i a incorrect' Hl'l

infiltration (Q1) is important as it is the only way <H

contuinants can reach the ground water. ,"'" :J: .... 032) The rea~aiaaion auat present the teat calculations used in "'"' 0

preparing Table 14 of the Pre-Deaiqn study Revision 1. i!l

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