SDMS DocID 000234852

FINAL SITE INSPECTION PRIORITIZATION REPORT FOR

TROY MILLS LANDFILL TROY, NEW HAMPSHIRE

CERCLIS No. NHD980520217 TDD No. 9401-60-CWX Delivery Order No. 0002

Prepared by:

Roy F. Western, Inc. 7 Eagle Square

Concord, New Hampshire 03301

September 25, 1996

ROY F. WESTON, INC. Reviewed and Approved:

f

TailcMmager £>r-' £• aott^sfc-1 Date

DeKvjiry Order Manager Date (or designee)

QA Review Date

Work Order No. 10971-002-065-0007

DISCLAIMER

This report was prepared solely for the use and benefit of the U.S. Environmental Protection Agency - New England (EPA-New England) Office of Site Remediation and Restoration for the specific purposes set forth in the contract between the U.S. Army Corps of Engineers New England Division and Roy F. Weston, Inc. (WESTON®). Professional services performed and reports generated by WESTON have been prepared for EPA-New England purposes as described in the contract. The information, statements, and conclusions contained in the report were prepared in accordance with the statement of work, and contract terms and conditions. The report may be subject to differing interpretations or misinterpretation by third parties who did not participate in the planning, research or consultation processes. Any use of this document or the information contained herein by persons or entities other than the EPA-New England shall be at the sole risk and liability of said person or entity. WESTON therefore expressly disclaims any liability to persons other than EPA-New England who may use or rely upon this report in any way or for any purpose.

CNHNPROJECTS 1097I002\065\TROY FNL U 09/25/96

TABLE OF CONTENTS

INTRODUCTION

Title Page

1

SITE DESCRIPTION 1

OPERATIONAL AND REGULATORYAND WASTE CHARACTERISTICS

HISTORY 5

WASTE/SOURCE SAMPLING

GROUNDWATER PATHWAY

9

9

SURFACE WATER PATHWAY 12

SOIL EXPOSURE PATHWAY 19

AIR PATHWAY

SUMMARY

REFERENCES

ATTACHMENT A ­

ATTACHMENT B ­

19

20

TROY MILLS LANDFILL GROUNDWATER AND SURFACE WATER SAMPLE ANALYTICAL RESULTS, GEOTECHNICAL ENGINEERS, INC. Samples collected August 30, 1995 A-l

TROY MILLS LANDFILL SEDIMENT SAMPLE ANALYTICAL RESULTS, ROY F. WESTON, INC. Samples collected 1987-1988 B-l

CNH\PROJECTS\10971002\065\TROY.FNL 111 09/25/96

LIST OF FIGURES

Figure No. Title Page

1 Location Map 2

2 Site Sketch 4

3 Surface Water Pathway 14

LIST OF TABLES

Table No. Title Page

1 Source Evaluation for Troy Mills Landfill 8

2 Hazardous Waste Quantity for Troy Mills Landfill 8

3 Estimated Drinking Water Populations Served by Groundwater Sources within Four Miles of Troy Mills Landfill 10

4 Summary of Analytical Results: Groundwater Sample Analysis Maximum Concentrations Detected in Groundwater Samples Collected by GEI from 1987 to 1990 11

5 Water Bodies Along the 15-Mile Downstream Pathway from Troy Mills Landfill 13

6 Sensitive Environments Along the 15-Mile Downstream Pathway from Troy Mills Landfill 15

7 Sediment Sample Summary: Troy Mills Landfill, Samples Collected by WESTON on August 30, 1995 16

8 Summary of Analytical Results: Sediment Sample Analysis for Troy Mills Landfill, Samples Collected by WESTON on August 30, 1995 17

9 Estimated Population within Four Miles of Troy Mills Landfill 19

10 Sensitive Environments Located within Four Miles of Troy Mills Landfill 20

CNH\PROJECTS\10971002\065\TROY FNL IV 09/75/96

Final Site Inspection Prioritization Report CERCLIS No. NHD980520217 Troy Mills Landfill TDD No. 9401-60-CWX Troy, New Hampshire Delivery Order No. 0002

Work Order No. 10971-002-065-0007

INTRODUCTION

Roy F. Weston, Inc. (WESTON®) was requested by the U.S. Environmental Protection Agency (EPA-New England) Office of Site Remediation and Restoration to perform a Site Inspection Prioritization (SIP) of the Troy Mills Landfill property off Rockwood Pond Road in Troy, New Hampshire. Tasks were conducted in accordance with the SIP scope of work and technical specifications provided by the EPA-New England. A Site Inspection (SI) Report for the Troy Mills Landfill property was prepared by the NUS Corporation Field Investigation Team (NUS/FIT) on February 26, 1985. The NUS/FIT SI documented the detection of volatile organic compounds (VOCs) and inorganics in samples cojlected from on-site leachate, groundwater, and surface water. On the basis of the information provided in the SI Report, the Troy Mills Landfill SIP was initiated.

Background information used in the generation of this report was obtained through file searches conducted at EPA-New England and the New Hampshire Department of Environmental Services (NHDES), telephone interviews with town officials, conversations with persons knowledgeable of the Troy Mills Landfill property, and conversations with other Federal, State, and local agencies. Additional information was gathered during the WESTON on-site reconnaissance on July 20, 1995 and environmental sampling on August 30, 1995.

This package follows the guidelines developed under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, commonly referred to as Superfund. However, these documents do not necessarily fulfill the requirements of other EPA regulations such as those under the Resource Conservation and Recovery Act (RCRA) or other Federal, State, or local regulations. SIPs are intended to provide a preliminary screening of sites to facilitate EPA-New England's assignment of site priorities. They are limited efforts and are not intended to supersede more detailed investigations.

SITE DESCRIPTION

The Troy Mills Landfill property is located on an unpaved access road off Rockwood Pond Road in Troy, Cheshire County, New Hampshire at geographic coordinates 42° 48' 06" north latitude and 72° 11' 12" west longitude (Figure 1) [9]. The 200-acre property is depicted on the Town of Troy Tax Assessor's Plan as Map 17, Lot 25. With the exception of the 10-acre landfill area, the 200-acre property is undeveloped [20]. The area surrounding the property is heavily wooded and remote, with the nearest residence located approximately 0.4 miles south of the landfill area. Approximately 123 people live within one mile of the property [3].

Note: Text •which appears in italics was either copied or paraphrased from the referenced document.

CNH\PROJECTS\10971002\065\TROY.FNL 09/25/96

SURFACE WATER PATHWAY

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1000 1000 2000 3000 4000 3000 6000 7000 FEET QUADRANGLE LOCATION

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TROY MILLS LANDFILL TROY, NEW HAMPSHIRE FIGURE 1

The ten-acre solid waste disposal area on the property is currently operated by Troy Mills, Inc. Wastes are generated off-site, at the Troy Mills, Inc. woolen mill in Troy, New Hampshire. Wastes typically deposited at the landfill include acrylic fabric, wood scraps, broken tools and empty, damaged 55-gallon fiberboard drums [I]. The landfill area is roughly square-shaped, with six to eight-foot terraces constructed during landfilling operations. More than 90 percent of the landfill surface is comprised of unvegetated, sandy soil. No areas of stained soil or unusual odors were observed during the WESTON on-site reconnaissance. Approximately 30 cubic yards of fabric wastes, staged for burial, were piled near the southeast edge of the landfill (Figure 2) [20]. The landfill is located on the east flank of the Rockwood Brook Valley.

The area surrounding the property is criss-crossed by unpaved logging roads. An unpaved road that provides access to the property extends north approximately 100 feet from Rockwood Pond Road. The unpaved access road crosses over an unnamed brook immediately south of the property, and continues parallel to the brook (Figure 2). The unpaved access road crosses over to the west side of the brook just before the brook enters Sand Dam Pond. The unpaved road then merges with Morse Road, which leads to the center of the Town of Troy. Access to the property for vehicular traffic is restricted by locked gates across the unpaved access roads. No fences or other barriers are located around the perimeter of the landfill to prevent site access. Pedestrians and off-road vehicles can access the property by travelling around the gates located on the unpaved access roads.

The location of four on-site monitoring wells (two of which are part of a couplet) at the landfill disposal area was verified during the WESTON on-site reconnaissance (Figure 2). The wells are located west of the landfill, between the disposal area and Rockwood Brook. The wells are protected by four-inch steel cased raisers which extend approximately three feet above ground surface. One well, MW-102, was unlocked and had a rusted outer casing. The other wells appeared to be in good condition. In addition to these four wells, twelve additional wells were reportedly installed on the property which are further discussed in the Operational History Section of this report.

The landfill topography slopes down to the west to Rockwood Brook. Landfilling operations have altered the surface topography of the property. The area surrounding the landfill is wooded (Figure 2) [20]. Overland flow from the landfill area likely travels to the west toward Rockwood Brook. A small leachate seep is also present between Rockwood Brook and the landfill area (Figure 2). The leachate seep is approximately 100 square feet and less than one foot deep. During the WESTON on-site reconnaissance, orange staining was observed in the seep [20].

An estimated 3,102 people are served by public and private groundwater sources within a four-mile radius of the Troy Mills Landfill property. The nearest public wells are gravel pack wells operated by the Town of Troy and are located approximately 3.5 miles northwest of the property [13, 14, 15, 19]. The majority of residents within a one-mile radius are served by private wells; the nearest of which is approximately 0.4 miles south of the landfill [3].

CNH\PROJECTS\1097I002\065\TROY FNL 3 09/25/96

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OPERATIONAL AND REGULATORY HISTORY AND WASTE CHARACTERISTICS

The Troy Mills Landfill property is currently owned by Troy Mills, Inc. of Troy, New Hampshire. Troy Mills. Inc. has operated a woolen mill, manufacturing wool and acrylic products, from the late 1800s to the present. Available file information did not describe prior manufacturing processes at the Troy Mills facility; however, woolen and acrylic textile processes typically consist of combing, which is a dry process; cleaning; preparing the raw fibers; and finishing the fabrics. Raw wool must first be scoured with hot alkaline detergents, caustic soda, soap, and soda ash to remove oil, grease, dirt, and foreign organic matter. After scouring, wool fibers may be bleached before or after conversion to fabric (i.e., stock dyeing or piece dyeing). The dyeing process involves a pre-scour bath and rinse. The wool is then soaked in a heated dye solution until the dye is exhausted. Commonly used dyes include acid, sulfur, metallized, and mordant or chromium dyes. Wool processing may involve the use of other chemicals such as sodium hypochlorite, hydrogen peroxide, sodium hydroxide, sulfuric acid, and sodium carbonate. The processing of non-cellulosic synthetic fiber, such as acrylic, is performed in approximately the same manner as described above. However, the application of anti-static agents before spinning and weaving operations is necessary. These agents include polyvinyl alcohol, styrene-based resins, polyalkene glycols, and gelatin. Acrylic requires only a light scouring and bleaching before dyeing as the compounds used in making synthetic fibers are typically free from dirt and grease.

Prior to 1967, the Troy Mills Landfill property was undeveloped. In 1967, Troy Mills, Inc. began using the property as a landfill for the disposal of solid and liquid wastes. The landfill includes a one-acre drum disposal area and a nine-acre solid waste landfill, with waste disposal primarily contained to surface sources [1].

Drummed wastes and empty steel drums were transported to the landfill by a local hauler. The number of drums disposed of from 1967 to 1978 reportedly averaged between 15 and 20 per week. A total of approximately 5,000 drums have reportedly been disposed at the landfill; however, estimates on the number of drums disposed at the landfill have been as high as 11,249 [1]. Previous reports indicate that drum disposal was limited to the one-acre area, in the southern section of the landfill [1, 3, 5]. Drummed wastes included surplus mixes and tank residues of vinyl resins, top-coating products, plasticizers and solvents. Three primary solvents were used at the Troy Mills, Inc. manufacturing facility; Varsol, methyl ethyl ketone (MEK) and 1,1,1-trichloroethane. Varsol, which was used in significantly larger quantities than the other substances, is composed of aromatic hydrocarbons, naphthalenes and paraffins. In 1978, Troy Mills, Inc. discontinued landfilling full drums at property. The drum disposal area was subsequently closed, graded and capped with a soil cover with grass. Based on available information, the exact thickness of the soil cap could not be determined. Troy Mills, Inc. has continued to dispose of fabric solid wastes in the nine-acre solid waste portion of the landfill.

According to a local resident, Troy Mills, Inc. also disposed drums along the unpaved road, approximately 100 yards north of Rockwood Pond Road (Figure 2) [20]. The resident indicated that the drums were disposed during the 1950s, and that the area is now overgrown. The resident also indicated that smaller piles of drums were likely scattered along the unpaved access road, south of the current landfill. Inspection of this area during the WESTON on-site reconnaissance confirmed the overgrown nature of the area, but no evidence of drum disposal was observed [20].

CNH\PROJECTS\10971002\065\TROYFNL 5 09Q5/96

In October 1978, Troy Mills, Inc. applied for and received a permit from NHDES to operate a solid waste disposal facility at the property. In October 1980, Troy Mills, Inc. was issued an order by NHDES to cease dumping at the southern drum disposal area and study groundwater quality at the landfill [1]. In 1981, Troy Mills, Inc. contracted Normandeau Associates, Inc. (NAI) to begin investigative work at the property. NAI excavated several on-site test pits for waste delineation, installed and sampled monitoring wells, and conducted surface water sampling. Between 1981 and 1985, NAI completed Phase I, Phase II, and Phase III investigations of the Troy Mills Landfill property [1].

During the NAI property evaluation, samples were collected from excavated steel drums and submitted for laboratory analysis. Of 45 drums that were encountered during the test pit excavations, 16 percent contained liquid and/or sludge, 33 percent were crushed flat, and 51 percent were not sampled because there were no accessible openings [4].

On October 21, 1981, EPA conducted a RCRA inspection of the property. The inspection revealed approximately 50 drums of hazardous waste in long-term storage. As a result of this inspection, Troy Mills, Inc. was cited for the following violations:

• Operating a hazardous waste storage facility without a permit; • Failing to maintain and submit a contingency plan; • Failing to post danger signs; • Maintaining hazardous waste containers that were not closed; • Failing to conduct weekly inspections of hazardous waste storage areas; • Failing to provide sufficient aisle space for emergency movement.

In addition to these citations, Troy Mills, Inc. was warned on five separate issues, including poor maintenance of inspection logs, written operation records, closure plans, and facility personnel training [5].

In 1983, the NHDES issued an Order of Abatement to complete "a detailed history of waste disposal practices, continue monitoring surface and groundwater quality, perform excavations within the landfill, and perform a leachability test on landfilled fabric waste."

In January 1985, the NHDES and Troy Mills, Inc. entered into a Consent Agreement which required Troy Mills, Inc. to submit a Waste Analysis Plan, complete a Preliminary Risk Assessment, as well as a Remedial Investigation (RI) and Feasibility Study (FS), and submit an engineering design of a selected remedial alternative [1].

In 1985, NUS/FIT completed an SI of the Troy Mills Landfill property. NUS/FIT collected four surface soil samples from within and downgradient of the drum disposal area, three groundwater samples from downgradient wells, and three surface water samples (one upgradient and two downgradient of landfill). The samples were screened in-house for VOCs. polychlorinated biphenyls (PCBs), and inorganics [5]. VOCs were detected in the leachate and groundwater samples. Concentrations ranged from trace to 500 micrograms per liter (ug/L). The highest concentration of VOCs was detected in well MW-2. Specific compounds detected included 1,1-dichloroethane, trichloroethylene, benzene, tetrachloroethylene, chlorobenzene, ethylbenzene, m-xylene and o-xylene. Inorganic analyses of groundwater samples reported concentrations of

CNH\PROJECTS\10971002\065\TROY.FNL 6 09/25/96

iron and manganese above the (unspecified) detection limit. No VOCs or PCBs were reported in NUS/FIT soil samples. Inorganic analyses ofon-site soil samples indicated that concentrations of chromium, barium, copper, zinc, lead, and manganese exceeded the detection limit, but were considered by NUS/FIT to be background levels [1]. No reference soil or groundwater samples were collected during the NUS/FIT SI.

An RI conducted by Geotechnical Engineers, Inc. (GEI) in 1987 included the following work: geophysical investigations, including seismic refraction and magnetometer work; excavation of 35 test pits in the active solid waste disposal area and former drum disposal area; installation and sampling of twelve monitoring wells, and collection of surface water samples at three points along Rockwood Brook.

Based on the findings of the RI, a single overburden aquifer underlies the property; no landfilled wastes are in contact with groundwater; Rockwood Brook is the only surface water body that receives groundwater discharge frorri beneath the landfill; and no significant concentrations of landfill-related residuals are present in the groundwater or Rockwood Brook. The RI report characterized the landfill as having two distinct areas, the solid waste area and the drum disposal area. The waste disposed at the solid waste area consists mainly of scrap fabrics, cleaning wastes, and miscellaneous equipment, parts and tools. The drum disposal area contains barrels of vinyl resins, top-coating products, plasticizers, and solvents.

The RI documented that a release to groundwater from on-site sources has occurred. Based on analytical results from in the RI, elevated concentrations of VOCs, semivolatile organic compounds (SVOCs) and inorganics have been detected in soil and groundwater samples collected at the property [1, 2]. Groundwater sampling conducted at the property by GEI is further discussed in the Groundwater Pathway Section of this report.

A Risk Assessment (RA) for the Troy Mills Landfill property was conducted by Menzie-Cura & Associates, Inc., in 1991 [4]. The RA focused on the human health risks related to the VOCs detected in Rockwood Brook, as documented by the RI. Five scenarios were evaluated in the RA: (1) people swimming in Sand Dam Pond; (2) people eating fish from Sand Dam Pond; (3) residents living near Rockwood Brook (and potentially exposed to VOCs); (4) people trespassing at the landfill; and (5) potential risks to on-site workers. The Risk Assessment concluded that under current conditions, the risks to human health and to the environment are negligible [4].

An FS for the Troy Mills Landfill was prepared by GEI in December 1992. The FS evaluated six source control and three migration management alternatives. The proposed remedy involved capping the inactive disposal area, installing additional monitoring wells to complete the groundwater monitoring network, and if necessary, implementing a groundwater recovery and treatment system [3].

Sediment sampling of the surface water pathway was conducted by WESTON on August 30, 1995. Sediment samples were collected from eight locations. WESTON sediment samples were analyzed for full organic and inorganic analyses through the EPA Contract Laboratory Program (CLP). Analytical results are further discussed in the Surface Water Pathway Section of this report.

CNH\PROJECTS\10971002\065\TROY.FNL 7 09/25/96

Two confirmed source areas were verified by WESTON during the SIP. The two areas consist of the landfill proper, which primarily contains a variety of mill and fabric scrap material, and the former drum disposal area (Figure 2). Previous environmental assessments segregated the property into the two separate source areas based on variations found in the plume characteristics downgradient from each source area. The groundwater downgradient from the landfill primarily contains chlorinated solvent contamination, while the groundwater downgradient from the former drum disposal area contains a variety of phthalates and other SVOCs.

Table 1 presents identified structures or areas on the Troy Mills Landfill property that are documented or potential sources of contamination, the containment factors associated with each source, and the relative location of each source [20].

Table 1

Source Evaluation for Troy Mills Landfill

Source Area Containment Factors Spatial Location

Landfill None Center of Lot

Drum Disposal Area None South end of the Landfill

Table 2 summarizes the types of potentially hazardous substances which have been disposed, used, or stored at the Troy Mills Landfill property [1,3,5].

Table 2

Hazardous Waste Quantity for Troy Mills Landfill

Quantity Years of Years of Substance or Volume/Area Use/Storage Disposal Source Area

Drums Approx. 5,000 Unknown 1967-1978 Drum disposal area

Fabric Scraps Approx. 10 acres Unknown 1967-present Landfill

There are no confirmed sources of contamination within one mile of the property [8]. No RCRA, CERCLA, or National Priority List (NPL) properties within one mile of the property were observed in the Comprehensive Environmental Response and Compensation Liability Information System (CERCLIS) or NHDES files [1, 21, 22]. One or more unconfirmed sources of contamination, consisting of former drum disposal areas, may be located along Rockwood Pond Road. However, during the WESTON on-site reconnaissance, no evidence of drums, discolored soil, stressed vegetation, or other indication of hazardous material were observed in the vicinity of this area [20].

CNH\PRO JECTS\ 10971002\065\TRO Y. FNL 09/25/96

WASTE/SOURCE SAMPLING

Two confirmed source areas were verified during the WESTON on-site reconnaissance. The two areas consist of the landfill proper, which primarily contains a variety of mill and fabric scrap material, and the former drum disposal area (Figure 2). No other treatment, storage, or disposal activities are known to have occurred at the property which have resulted in additional source areas.

Previous source area sampling was conducted by NAI from 1983 to 1984. Samples were collected for VOC, SVOC and metals analyses. Analytical methods were not available from existing file information. Analyses performed on six drum samples (both liquids and sludges) and four samples of associated uncontainerized wastes (sludges and stained soils) revealed the presence of VOCs, base/neutral extractable priority pollutants and metals. Predominant VOCs detected were benzene, toluene, xylene and ethylbenzene, with lower concentrations of trichloroethylene, 1,1-dichloroethane, 1,1,1-trichloroethane, and methylene chloride. Total VOC concentrations were as high as three percent. The base/neutral extractable compounds detected consisted ofphthalates with lower concentrations of naphthalene. Total base/neutral extractable concentrations were as high as 13 percent [15]. No reference soil samples were collected during these sampling events for comparison with the detected concentrations.

No waste/source sampling was conducted by WESTON during the SIP. The previous work at the Troy Mills Landfill property characterized the source area adequately for the purposes of this SIP. The previous waste/source characterization conducted by NAI correlates with the manufacturing operations at the Troy Mill, Inc. facility and the disposal history of the Troy Mills Landfill property.

GROUNDWATER PATHWAY

Geology at the property is characterized as outwash sand and gravel, and till deposits overlying bedrock. The uppermost unit consists primarily of fine to medium sand, with layers of silty and gravelly sand. The sand unit thickness ranges from approximately three to fifteen feet, increasing in thickness to the west toward Rockwood Brook. The till unit consists of dense silty, gravelly sand, and ranges in thickness from 5 to 63 feet. Bedrock beneath the property is mapped as the upper member of the Rangeley Formation, a Silurian-age, rusty weathering, pelitic schist [1]. Depth to bedrock beneath the property is ranges between approximately 10 and 80 feet.

The water table at the facility is typically found at or below the base of the upper sand unit. Depth to groundwater is less than ten feet, particularly in the western part of the facility toward Rockwood Brook. Based on the geology beneath the property and depth to groundwater measurements, groundwater flow is to the west-northwest, with groundwater discharging to surface water at Rockwood Brook. Groundwater seeps have been observed west of the drum disposal area [1].

An estimated 2,297 people are served by private groundwater sources within a four-mile radius of the Troy Mills Landfill property. The nearest drinking water wells are private residential wells approximately 0.4 miles south on Rockwood Pond Road. Private well users within a four-mile

CNH\PROJECTS\10971002\065\TROYFNL 9 09/25/96

radius of the property were estimated using equal distribution calculations of CENTRACTS data identifying population, households, and private water wells for "Block Groups" which lie wholly or in part within individual rings measured radially, from potential sources on the property. Attempts were made to verify the information provided by CENTRACTS data through telephone calls to local health and or water departments when possible.

The nearest public wells are gravel pack wells operated by the Town of Troy, approximately 3.5 miles northwest of the property and served an estimated 805 people [13, 14, 15, 19]. No wells within four miles of the Troy Mills Landfill property have been closed due to potential contamination related to the property. Table 3 lists the estimated population receiving drinking water from public and private groundwater sources within a four-mile radius of the Troy Mills Landfill property.

Table 3

Estimated Drinking Water Populations Served by Groundwater Sources within Four Miles of Troy Mills Landfill

Total Estimated Radial Distance from Estimated Population Population Served by Troy Mills Landfill

(miles) Served by Private

Wells Estimated Population

Served by Public Wells Groundwater Sources

within the Ring

0.00 < 0.25 0 0 0

0.25 < 0.50 31 0 31

0.50 < 1.00 92 0 92

1. 00 < 2.00 410 0 410

2.00 < 3.00 713 0 713

3.00 < 4.00 1,051 805 1,856

TOTAL 2,297 805 3,102

Groundwater sampling was conducted at the Troy Mills Landfill property by NAI from 1981 to 1983. Four wells were installed and sampled at the property during the Phase II site investigation. Sampling by NAI documented elevated levels of iron and manganese downgradient of the landfill; as well as the presence of several VOCs, including toluene, benzene, and chlorinated compounds in on-site groundwater. No reference samples were collected for comparison to these results since upgradient wells were not installed at the property at the time.

Groundwater sampling was also conducted by GEI during the RI. Groundwater samples were collected for VOC and SVOC analyses during five separate sampling events between 1987 and 1990. Samples were analyzed for VOCs using EPA Method 624, base/neutral extractables using EPA Method 625, phenols using EPA Method 420, and select metals (iron, manganese, zinc, chromium, lead, and cadmium) using EPA Method 6010. Groundwater samples were compared with results from monitoring well MW-109s which was considered the reference well by WESTON since it reported no target VOCs (with the exception of toluene), no SVOCs and the fewest inorganic substances during each sampling event. A summary of maximum concentrations

CNH\PROJECTS\10971002W65\TROY FNL 10 09/25/96

of compounds detected in groundwater samples is shown in Table 4. Sample results are compared to reference concentrations detected in MW-109s. If the compound or element was not detected in the reference sample, the analytical detection limit (DL) is used for comparison.

Table 4

Summary of Analytical Results, Groundwater Sample Analysis Maximum Concentrations Detected in Groundwater

Samples Collected by GEI from 1987 to 1990

Maximum Reference Chemical Compound Concentration Concentration Comments

VOCs (ug/L)

1,1,1 -Trichloroethane 270 5.0 U 54 x DL

1,1-Dichloroethane 92 5.0 U 18.4x DL

1, 1 -Dichloroethene 9 5.0 U 1.8x DL

1,2-Dichloroethene 33 5.0 U 6.6 x DL

Chloroethane 31 5.0 U 6.2 x DL

Acetone 77 25.0 U 3.1 xDL

Benzene 3.9 5.0 U 0.78 x DL

Carbon Disulfide 30 5.0 U 6.0 x DL

Chloromethane 32 10.0 U 3.2 x DL

Methylene chloride 94 20.0 U 4.7 x DL

o&p-Xylene 58 5.0 U 11.6xDL

m-Xylene 8 5.0 U 1.6 x DL

Tetrahydrofuran 97 25.0 U 3.9 x DL

Ethylbenzene 110 5.0 U 22.0 x DL

Toluene 1,300 8.0 163 xREF

SVOCs (ug/L)

Phenols, total 280 10.0 U 2 8 x D L

Di-n-butylphthalate 24 10.0 U 2.4 x DL

Naphthalene 18 10.0 U 1.8 x DL

bis(2-Ethylhexyl)phthalate 1,000 10.0 U 100 x DL

INORGANICS (mg/L)

Iron (total) 262 0.28 936 x REF

Cadmium (total) 0.006 0.004 U 1.5 x DL

Chromium (total) 0.233 0.01 U 23.3 x DL

Lead (total) 0.214 0.05 U 4.3 x DL

Manganese, total 14.0 0.051 274 x REF

Zinc, total 0.756 0.02 U 37.8 x DL

REF = Reference Sample Concentration U = The compound was analyzed for, but was not detected. The associated numerical value is the sample

detection limit.

OJH\PROJECTS\10971002\065\TROY.FNL 11 09/25/96

The RJ describes an areal distribution of VOCs at the property that follows a pattern relative to the source areas. Groundwater samples from wells below the drum disposal area contained non-chlorinated VOCs which include; toluene, ethylbenzene, xylene, and tetrahydrofuran. VOCs in the wells downgradient of the solid waste area include the chlorinated compounds 1,1,1 -trichloroethane and 1,1-dichloroethane [1]. Four SVOCs were detected in ground water samples between 1.8 and 100 times the detection limit. The SVOC bis(2-ethylhexyl)phthalate was detected at the highest concentration and is associated with plasticizers which have been historically disposed in the landfill. No groundwater sampling was conducted as part of the SIP. Summary tables from the RI analytical results are included in Attachment A.

SURFACE WATER PATHWAY

Topography at the property slopes to the west. No preferred overland flow route was observed at the landfill; however, a defined overland flow route was observed along the west edge of the landfill, between the landfill and the unpaved access road (Figure 2). During the WESTON on-site reconnaissance, a 100 square-foot ponded area located west of the landfill was observed with orange stained sediment and water (Figure 2). The discolored surface water body appeared to be the result of groundwater or leachate seepage along the west edge of the landfill. The ponded area drains via a culvert under the unpaved access road, ultimately discharging to Rockwood Brook approximately 200 feet west of the landfill.

Based on available file information and on observations made by WESTON during the on-site reconnaissance, and for the purposes of this SIP, the ponded area and outflow stream are considered intermittent water bodies, and are therefore included in the overland flow segment of the surface water pathway. Although other groundwater seeps were described in previous reports, no other areas of ponded water, or other defined overland flow routes to Rockwood Brook were observed during the WESTON on-site reconnaissance [20]. As a result, the most likely probable point of entry (PPE) of overland flow to the surface water pathway is located at the confluence of the intermittent stream and Rockwood Brook. Further, the entire segment of Rockwood Brook which bounds the landfill to the west is considered a PPE for groundwater to surface water.

The overland flow PPE is approximately 200 feet west of the landfill property. The first mile of the surface water pathway consists of Rockwood Brook, a minimal stream with a mean annual flow rate of less than 10 cubic feet per second (cfs), which travels north through the center of the Rockwood Brook Valley (Figure 3). No published flow rate calculations or measurements are available for Rockwood Brook. The reported estimated flow rate is based on visual observations and comparisons to water bodies with known flow rates. Based on discussions with a local resident, it is not likely that Rockwood Brook is a recreational fishery [16, 20]. Rockwood Brook travels north through wooded areas, and discharges to wetlands approximately one-half mile north of the PPE. The wetland segment is 0.4 miles long, with 0.8 miles of wetland frontage, and terminates when the brook discharges to Sand Dam Pond and ultimately Village Pond. Sand Dam Pond measures approximately 30 acres, and is a town-operated recreational area used for swimming and boating. Sand Dam Pond is also considered a recreational fishery [16]. Village Pond, which is less than ten acres, is shallower, and does not host the town-sponsored recreational activities. The surface water pathway continues along Rockwood Brook for approximately 0.2 miles past Village Pond and discharges to the South

CNH\PROJECTS\10971002\065YTROYFNL 12 09/25/96

Branch Ashuelot River. The South Branch Ashuelot River has a mean annual flow rate of approximately 50 cfs based on measurements made at a stream gaging station in Swanzey, New Hampshire.

The South Branch Ashuelot River is a stocked recreational fishery which flows northwest along Route 12, north of the center of Troy. Approximately 7.0 miles of wetland frontage are located along this portion of the 15-mile downstream pathway. The 15-mile downstream surface water pathway terminates at the Town of Swanzey, approximately one-half mile before the confluence of the South Branch Ashuelot River and the Ashuelot River (Figure 3) [9-11, 13-15, 18, 20]. Table 5 summarizes the characteristics of water bodies along the 15-mile downstream pathway from the property.

Table 5

Water Bodies Along the 15-mile Downstream Pathway from Troy Mills Landfill

Surface Length of Flow Characteristics Length of Water Body Description Reach (miles) (cfs) Wetlands (miles)

Rockwood Brook Minimal stream 1 < 10 0.8

Sand Dam Pond Small to moderate 0.5 20 -stream

Village Pond Small to moderate 0.3 20 -stream

Rockwood Brook Small to moderate 0.2 20 -stream

South Branch Small to moderate 13 50 7.0 Ashuelot River stream

Sensitive environments located along the 15-mile downstream pathway include the 7.8 miles of wetlands found along Rockwood Brook and the South Branch Ashuelot River. In addition, surface water bodies downstream of the PPE are designated sensitive environments under the Clean Water Act. There are no Federal or State-listed endangered species or habitats along the 15-mile downstream pathway [6, 7]. No drinking water intakes were identified along the 15-mile downstream pathway [13, 14, 15]. There is no available information regarding fishery closures that may be associated with landfill operations [16, 21]. Sensitive environments located along the 15-mile downstream pathway are summarized in Table 6 [12].

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/ END OF 15 MILE / SURFACE WATER

/ PATHWAY

SAND DAM POND (FISHERY AND TOWN RECREATION AREA)

WETLANDS (SENSITIVE ENVIRONMENTS)

LANDFILL PROPERTY BOUNDARY

POTENTIAL ADDITIONAL DISPOSAL AREA

SD-01 SEDIMENT SAMPLE q•o COLLECTED BY WESTON

SURFACE WATER SAMPLE SW-1 A COLLECTED BY GQ/CHEWCYCLE

O DIRT ROAD

WETLANDS Q.

£

PONDED ORANGE STAINED (LEACHATE) WATER. START OF OVERLAND FLOW ROUTE

TROY MILLS LANDF1LL

NOT TO SCALE

WEIR RAILROAD TRACK

TOWN BOUNDARY

SURFACE WATER PATHWAY PERENNIAL STREAM

OVERLAND FLOW ROUTE INTERMITTENT STREAM

o SURFACE WATER PATHWAY

f TROY MILLS LANDFILL p. TROY, NEW HAMPSHIRE

FIGURE 3

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Table 6

Sensitive Environments Along the 15-Mile Downstream Pathway from Troy Mills Landfill

Downstream Flow Rate Sensitive Sensitive Water Body Distance at

Environment Environment Type from PPE Environment Name Type (miles) (cfs)

Rockwood Brook Clean Water Act Minimal stream PPE < 10

Rockwood Brook Wetlands Minimal stream 025 < 10

South Branch Wetlands Small to moderate stream 4 to 7 50 Ashuelot River

South Branch Clean Water Act Small to moderate stream 2 50 Ashuelot River

Three rounds of surface water sampling were conducted by GEI at three locations (SW-1, SW-2, and SW-3) during the RI. Samples were analyzed for VOCs using EPA Method 624, base/neutral extractables using EPA Method 625, phenols using EPA Method 420, and select metals (iron, manganese, zinc, chromium, lead, and cadmium) using EPA Method 6010. In addition, a separate sample from the groundwater seep was collected and analyzed for all EPA priority pollutant metals [1]. Summary tables from the RI analytical results are included in Attachment A.

Surface water sample SW-3 collected from Rockwood Brook during the GEI RI detected VOCs, which include 1,1,1-trichloroethane detected at trace concentrations of less than 5 ug/L and metals, which include dissolved iron and manganese, detected at concentrations ranging from 150 to 900 ug/L and 10 to 240 ug/L, respectively. No concentrations of phenols, chromium, lead, cadmium, or zinc were detected in the RI surface water samples collected by GEI [1].

The leachate seep sample collected by GEI detected several VOCs, including 1,1-dichloroethane (10 ug/L), 1,1,1-trichloroethane (2.7 ug/L), tetrahydrofuran (23 ug/L), and 1,2-trans-dichloroethane (2.7 ug/L). In addition, the leachate seep sample reported trichloroethylene, 1,2-dichloroethene. and 1,1-dichloroethene at trace levels [1]. Trace concentrations of naphthalene and pentachlorophenol were also detected in the leachate seep sample. Barium (31 ug/L) was the only priority pollutant metal detected in the seep sample, and iron and manganese were detected at concentrations ranging from 70 to 23,000 ug/L and 7,500 to 15,000 ug/L, respectively [1].

On August 30, 1995, WESTON conducted sediment sampling along the surface water pathway and at upgradient locations from the Troy Mills Landfill. The purpose of the sampling was to evaluate a release to surface water and characterize potential surface water contamination migration from on-site source areas. Sediment sampling focused on sensitive environments, which included protected areas under the Clean Water Act and wetlands along Rockwood Brook; as well as other surface water receptors, including the recreational fishery at Sand Dam Pond.

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Sediment samples were collected from eight locations in Rockwood Brook and Sand Dam Pond. Two reference samples (SD-01 and SD-02,) were collected from Rockwood Brook upgradient of the landfill. Three samples (SD-04, SD-05, SD-06) were collected from the PPE and wetlands associated with Rockwood Brook. One sample, SD-03, was collected from an area upgradient of the landfill, but downgradient from other potential disposal areas off Rockwood Pond Road (Figure 2). The remaining samples, including one duplicate, were collected from Sand Dam Pond. Table 7 summarizes sediment samples collected by WESTON on August 30, 1995 to evaluate the Troy Mills Landfill property.

Table 7

Sediment Sample Summary: Troy Mills Landfill, Samples Collected by WESTON on August 30, 1995

Sample Traffic Location No. Report No.

MATRIX: Sediment

SD-01 AJN01 MAGH77

SD-02 AJN02 MAGH78

SD-03 AJN03 MAGH80

SD-04 AJN04 MAGH79

SD-05 AJN.05 MAGH81

SD-06 AJN06 MAGH82

SD-07 AJN07 MAGH83

SD-08 AJN08 MAGH84

SD-09 AJN09 MAGH85

Matrix: Aqueous

RB-01 AJN10

TB-01 AJN12

Time

1255

1240

1220

1220

1130

1100

0915

1015

1015

0700

1705

Remarks

Grab

Grab

Grab

Grab

Grab

Grab

Grab

Grab

Grab

Grab

Grab

Sample Depth

12 to 18 inches

12 to 18 inches

12 to 18 inches

12 to 18 inches 12 to 18 inches

12 to 18 inches 12 to 18 inches 12 to 18 inches 12 to 18 inches

N/A

N/A

Sample Source

Rockwood Brook, below Rockwood Pond Dam. Designated as a reference sample. (MS/MSD for quality control) Rockwood Brook, 100 feet from downstream of SD-01 . Designated as a reference sample. Rockwood Brook weir, 250 feet upstream of landfill PPE, but downstream of potential additional disposal area.

Rockwood Brook at PPE

Rockwood Brook Wetlands

Rockwood Brook Wetlands

Sand Dam Pond, south end

Sand Dam Pond, north end

Duplicate of SD-08 for quality control

Sampling equipment reinstate blank for quality control.

Trip blank for quality control

MS/MSD = Matrix Spike/Matrix Spike Duplicate. N/A = Not applicable.

Note: The upper 12" at the sampling locations were primarily vegetative material and not representative of stream sediments.

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Table 8 is a summary of organic compounds and inorganic elements detected through CLP analyses of WESTON sediment samples. For each sample location, a compound or element is listed if it is detected at three times or greater than the reference sample concentration. However, if the compound or element is not detected in the reference sample, the reference sample's quantitation limit (SQL) (for organic analyses) or detection limit (SDL) (for inorganic analyses) is used as the reference value. These compounds or elements are listed if they occurred at a value equal to or greater than the reference sample's SQL or SDL and are designated by their approximate relative concentration above these values. Complete analytical results of WESTON sediment samples, including quantitation and detection limits are presented in Attachment B.

Table 8

Summary of Analytical Results Sediment Sample Analysis for Troy Mills Landfill

Samples Collected by WESTON on August 30, 1995

Sample Reference Sample Location Compound/Element Concentration Concentration Comments

SD-03 PESTICIDES/PCBs AJN03 MAGH80

Methoxychlor 1.6 Jppb 0.48 J ppb 3.3 x REF

INORGANICS

Aluminum 14,000 ppm 4,350 J ppm 3.2 x REF

Arsenic 6.1 ppm 1 .5 U ppm 4.0 x SDL

Barium 103 ppm 22.6 ppm 4.5 x REF

Cobalt 17.1 ppm 2.3 J ppm 7.2 x REF

Lead 42.7 ppm 3.9 U ppm 10.9 x SDL

Manganese 438 ppm 128 ppm 3.4 x REF

Nickel 15.7 ppm 3.7 U ppm 4.2 x SDL

Selenium 1.7 J ppm 1.2 U ppm 1.4 x SDL

Vanadium 38.5 ppm 8.3 ppm 4.6 x REF

Zinc 123 ppm 36.7 U ppm 3.3 x SDL

SD-05 INORGANICS AJN05 MAGH81

Aluminum 17,600 J ppm 4,350 J ppm 4.0 x REF

Barium 101 J ppm 22.6 J ppm 4.4 x REF

Chromium 18.7 J ppm 5.9 J ppm 3.2 x REF

Cobalt 12.1 J ppm 2.3 J ppm 5.2 x REF

Lead 29.6 J ppm 3.9 U ppm 7.6 x SDL

Nickel 15.9 J ppm 3.7 U ppm 4.3 x SDL

Vanadium 37.0 J ppm 8.3 ppm 4.4 x REF

SD-06 INORGANICS AJN06 MAGH82

Lead 13.7 ppm 3.9 U ppm 3.5 x SDL

Zinc 42.9 ppm 36.7 U ppm 1.2 x SDL

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Table 8

Summary of Analytical Results Sediment Sample Analysis for Troy Mills Landfill

Samples Collected by WESTON on August 30, 1995 (concluded)

Sample Reference Sample Location Compound/Element Concentration Concentration Comments

SD-07 INORGANICS AJN07 MAGH83

Lead 40.0 ppm 3.9 U ppm 10.2x SDL

Zinc 62.3 ppm 36.7 U ppm 1.7 x SDL

SD-09 PESTICIDES/PCBs AJN09 MAGH85

Methoxychlor 2.3 J ppb 0.48 J ppb 4.8 x REF

INORGANICS

Lead 4.4 ppm 3.9 U ppb 1.1 xSDL

REF = Reference sample SDL = Sample Detection Limit ppm = parts per million ppb = parts per billion J = The associated numerical value is an estimated quantity. U = The compound was analyzed for, but, was not detected. The associated numerical value

is the sample quantitation limit.

No VOCs were detected in WESTON sediment samples collected along Rockwood Brook on August 30, 1995. One pesticide substance, methoxychlor, was detected in sediment samples SD-03 and SD-09 at concentrations of 1.6 ppb and 2.3 ppb, respectively. Eleven inorganic elements were detected in WESTON sediment samples ranging in concentrations from 4.4 to 17,600 ppm. The concentrations associated with several substances detected in samples listed above were estimated or J'd. WESTON has included the detected concentrations of these substances in Table 8 to remain consistent with technical directives provided by EPA-New England.

No target compounds or elements were detected in WESTON sediment sample SD-04 collected from the most likely overland flow PPE. The absence of target compounds and elements in sediment sample SD-04 may be attributed to various causes, including sample medium variability (the composition of sediment at this location may contribute to the absence of target substances); and the sediment sample may have been collected from a section of the brook where a higher flow rate, relative to other sediment sample locations, may have kept undissolved particles in suspension. As indicated, other PPE areas may be present along Rockwood Brook which are available to both overland flow from the landfill or by groundwater to surface water discharge. Based on EPA-New England guidance, as well as available file information and prior analytical results of on-site sampling, substances detected in other downstream WESTON sediment sample locations may be considered attributable to the property for the purposes of this SIP.

CNH\PROJECTS\10971002\065\TROY.FNL 18 09/25/96

SOIL EXPOSURE PATHWAY

Troy Mills, Inc. employs one part-time on-site worker, who periodically buries stockpiled waste at the landfill [20]. No residents, schools, or day care facilities are located within 200 feet of an area of observed contamination. The waste sources in the landfill are covered with a sandy fill; therefore, no contact with the wastes are anticipated [1, 20], However, wastes may be present within two feet below ground surface (bgs). No information was available to determine the exact thickness of sandy fill. There are no occurrences of rare or endangered species on-site that are expected to be impacted by near-surface waste sources. Approximately 123 people live within one mile of the Troy Mills Landfill property [8].

In 1985, NUS/FIT conducted soil sampling at the property as part of the SI [5]. Samples were collected from depths of between one and two feet bgs using a hand auger. Samples were screened for presence of VOCs using a gas chromatograph and metals using X-ray fluorescence. No VOC concentrations were detected above ten ppb, the screening method detection limit. Concentrations of manganese, chromium, barium, copper, zinc, and lead detected by NUS/FIT were interpreted as being within expected background values [5]. As a result of the previous soil sampling and due to the difficulty in characterizing buried landfilled materials through limited soil sampling efforts, no soil samples were collected by WESTON during this SIP.

AIR PATHWAY

The nearest individual, excluding the part time worker, is approximately one-quarter mile south of the property. An estimated 3,103 people live within a four-mile radius of the Troy Mills Landfill property. The nearest school or daycare is approximately one mile north of the landfill. No odors or complaints of adverse health affects on-site or in the vicinity were noted during the WESTON on-site reconnaissance or documented in regulatory file information. Table 9 summarizes the estimated population within four miles of the property [8].

Table 9

Estimated Population within Four Miles of Troy Mills Landfill

Radial Distance from Troy Mills Landfill (miles) Estimated Population

On-site 1*

0.00 < 0.25 0

0.25 < 0.50 31

0.50 < 1.00 92

1. 00 < 2.00 410

2.00 < 3.00 713

3.00 < 4.00 1,856

TOTAL 3,103

* One on-site employee.

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There are no sensitive environments on-site. Sensitive environments within four miles of on-site sources include wetlands and occurrences of rare and endangered plant and animal communities. Approximately 3,080 acres of wetlands are within a four-mile radius of the property. Eight occurrences of state-listed rare/endangered species communities are listed within a four-mile radius of the Troy Mills Landfill property. No known air sampling has been conducted at the Troy Mills Landfill property. Table 10 summarizes the sensitive environments located within four miles of the Troy Mills Landfill property.

Table 10

Sensitive Environments Located within Four Miles of Troy Mills Landfill

Radial Distance from Troy Mills Landfill (miles) Sensitive Environment/Species

0 < 0.25 Rockwood Brook (Clean Water Act)

Rockwood Brook Wetlands (6 acres)

0.25 < 0.50 Rockwood Brook Wetlands (48 acres)

0.50 < 1.00 Rockwood Brook Wetlands (71 acres)

1. 00 < 2.00 Giant Rhododendron

Rockwood Brook Wetlands (520 acres)

2.00 <3.00 Squirrel Com

Rockwood Brook Wetlands (1,007 acres)

3.00 < 4.00 Green Adder's - Mouth

Eastern Pond Mussel

Incurved Umbrella ­ Sedge

Sprout Muhlenbergia

Fringed Gentia

Wellington Reservoir Wetlands (1,428 acres)

SUMMARY

The Troy Mills Landfill property is located on an unpaved access road off Rockwood Pond Road in Troy, Cheshire County, New Hampshire. With the exception of a solid waste landfill, the 200-acre property is undeveloped. The surrounding area is heavily wooded and remote, the nearest residence is located approximately 0.4 miles south of the property. The property owner, Troy Mills, Inc. is currently operating a solid waste disposal facility on the property for landfilling waste acrylic fabric, wood scraps, broken tools and empty, damaged 55-gallon fiberboard drums. The disposal area at the Troy Mills Landfill property is approximately ten acres. The property is roughly square-shaped, with six to eight-foot terraces constructed during landfilling operations.

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Drummed wastes and empty steel drums were transported to the landfill by a local hauler. The number of drums disposed at the property from 1967 to 1978 averaged between 15 and 20 per week. A total of approximately 5,000 drums were disposed of at the landfill; however, estimates on the number of drums disposed have been as high as 11,249. Previous studies indicate that drum disposal was limited to a one-acre area at the southern section of the landfill.

Two confirmed source areas were identified during this SIP. The two areas consist of the landfill, which primarily contains a variety of mill and fabric scrap material, and the former drum disposal area. Previous environmental studies segregated the property into two separate source areas based on variations found in plume characteristics downgradient from these source areas. The groundwater downgradient from the landfill primarily contains chlorinated solvent contamination, while the groundwater downgradient from the former drum disposal area contains a variety of phthalates and other semi-volatile organic compounds. An alleged additional drum disposal area was investigated during the Roy F. Weston (WESTON®) on-site reconnaissance, but could not be verified.

Geology at the facility consists of outwash sand and gravel, and till deposits overlying bedrock. The water table at the facility is typically found at or below the base of the upper sand unit. Depth to groundwater is approximately less than ten feet, particularly in the western part of the facility toward Rockwood Brook. Based on this information, groundwater flow is to the west-northwest, with groundwater discharging into surface water at Rockwood Brook. Groundwater seeps have been observed west of the drum disposal area.

An estimated 2,297 people are served by private groundwater sources within a four-mile radius of the Troy Mills Landfill property. The nearest drinking water wells are private residential wells approximately 0.4 miles south on Rockwood Pond Road. The nearest public wells are gravel pack wells operated by the Town of Troy, and are located approximately 3.5 miles northwest of the property. No known drinking water wells within four miles of the Troy Mills Landfill property have been closed due to contamination related to the landfill.

The most likely probable point of entry (PPE) of the surface water pathway is approximately 200 feet west of the landfill. The first mile of the surface water pathway consists of Rockwood Brook, a minimal stream with a mean annual flow rate of less than 10 cubic feet per second (cfs). Rockwood Brook travels north through the center of the Rockwood Brook Valley. Based on available information, Rockwood Brook is not a recreational fishery. Rockwood Brook discharges to wetlands approximately one-half mile north of the PPE. The wetland segment is approximately 0.4 miles long, with 0.8 miles of wetland frontage, and terminates when the brook dicharges to Sand Dam Pond and ultimately Village Pond. The southernmost, upstream pond, Sand Dam Pond, is approximately 30 acres and is a town-operated recreational area used for swimming and boating. Sand Dam Pond is also considered a recreational fishery.

On August 30, 1995, WESTON personnel conducted sediment sampling along the surface water pathway and at upgradient locations from the Troy Mills Landfill property. The purpose of the sampling was to characterize potential surface water contamination migration from on-site source areas. Sediment sampling focussed on sensitive environment targets, including the wetlands along Rockwood Brook, and the Sand Dam Pond recreational fishery. Sediment samples were collected from eight locations in Rockwood Brook and Sand Dam Pond.

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No volatile organic compounds (VOCs) were detected in sediment samples collected by WESTON. One pesticide substance, methoxychlor, was detected in sediment samples SD-03 and SD-09 at concentrations of 1.6 parts per billion (ppb) and 2.3 ppb, respectively. Eleven inorganic elements were detected in WESTON sediment samples ranging in concentrations from 4.4 to 17,600 parts per million (ppm).

There is one part-time, on-site worker, who periodically buries the waste generated by Troy Mills, Inc. No residents, schools, or daycare facilities are located within 200 feet of an area of observed contamination.

The nearest individual, excluding the part time worker, is approximately one-quarter mile south of the property. An estimated 3,103 people live within a four-mile radius of the Troy Mills Landfill property, including one on-site worker. The nearest school or daycare is approximately one mile north of the landfill. No odors or complaints of adverse health affects on-site or in the vicinity were noted during the WESTON on-site reconnaissance or documented in regulatory file information.

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REFERENCES TROY MILLS LANDFILL

[1] Chemcycle Corporation. 1988. Draft Remedial Investigation. October.

[2] Chemcycle Corporation. 1988. Data Sufficiency Report. February 10.

[3] GEI Consultants. Inc. 1992. Draft Feasibility Study. Rockwood Brook Landfill Troy. New Hampshire. December 17.

[4] Menzie Curie Associates, Inc. and GEI Consultants, Inc. 1991. Risk Assessment. Rockwood Brook Landfill. November 27.

[5] NUS Corporation (NUS/FIT). 1985. Troy Mills Landfill Site Inspection Report. February 26.

[6] U.S. Department of the Interior, Fish and Wildlife Service. 1995. Federally Listed Endangered Species in New Hampshire.

[7] New Hampshire Department of Resources and Economic Development. 1995. New Hampshire Natural Heritage Inventory, Element Occurrence Record and Natural Heritage Inventory.

[8] Frost Associates. 1995. CENTRACTS report for Troy Mills Landfill, Troy, NH. May 9.

[9] USGS (United States Geological Survey). 1984. Monadnock Mountain New Hampshire, 7.5 x 15 Minute Quadrangle Map.

[10] USGS (United States Geological Survey). 1984. Winchester New Hampshire ­Vermont, 7.5 x 15 Minute Quadrangle Map.

[11] USGS (United States Geological Survey). 1988. Winchendon Massachusetts - New Hampshire, 7.5 x 15 Minute Quadrangle Map.

[12] Rydel, S. (WESTON). 1995. Notes to project file, wetlands areas and frontages. June 8. TDD No. 9401-60-CWX.

[13] Rydel, S. (WESTON). 1995. Phone conversation record with the receptionist at the Town of Jaffrey, NH, Public Works, Re: water supplies for the Town of Jaffrey, NH. May 3. TDD No. 9401-60-CWX.

[14] Rydel, S. (WESTON). 1995. Phone conversation record with the Town of Richmond, NH, Selectman's office, Re: water supplies for the Town of Richmond, NH. May 3. TDD No. 9401-60-CWX.

CNH\PROJECTS\1097I002\065\TROY.FNL 09/25/96

REFERENCES TROY MILLS LANDFILL

(Concluded)

[15] Rydel, S. (WESTON). 1995. Phone conversation record with Town of Troy, NH, Treatment Plant Operator. Re: water supplies for the Town of Troy, NH. TDD No. 9401-60-CWX.

[16] Eichhorn, R. (WESTON). 1995. Phone conversation record with Luis Morales (Troy Mills, Inc.), Re: fishery status of Sand Dam Pond. July 14. TDD No. 9401-60-CWX.

[17] Eichhorn. R. (WESTON). 1995. Phone conversation record with Don Smith (US EPA), Re: sampling locations for Troy Mills Landfill SIP. TDD No. 9401-60-CWX.

[18] Eichhorn, R. (WESTON). 1995. Phone conversation record with Chandler Keirstead (USGS), Re: Mean annual flow rate for S. Branch Ashuelot River. July 25. TDD No. 9401-60-CWX.

[19] Rydel, S. (WESTON). 1995. Phone conversation record with the Town of Marlborough, NH, Town Clerk's office, Re: water supplies for the Town of Marlborough, NH. May 3. TDD No. 9401-60-CWX.

[20] Eichhorn, R. (WESTON). 1995. Logbook for on-site activities. Logbook TDD No. 9401-60-CWX.

[21] Eichhorn, R. (WESTON). 1995. Notes to file, NHDES file review. May 11.

[22] U.S. EPA (United States Environmental Protection Agency). 1995. CERCLIS database report. July 13.

[23] Quigley, D., et al. (WESTON). 1995. Letter to C. Clark (U.S. EPA), Re: Case No. 23971, SDGNOS. AJN01 & AJN10 (organic analyses). November 22. TDD No. 9401-60-CWX.

[24] Quigley, D., et al. (WESTON). 1995. Letter to C. Clark (U.S. EPA), Re: Case No. 23971, SDG NO. MAGH77 (Inorganic Analyses). November 2. TDD No. 9401-60-CWX.

CNH\PROJECTS\10971002\065\TROY FNL 09/25/96

ATTACHMENT A

TROY MILLS LANDFILL

GROUNDWATER AND SURFACE WATER SAMPLE ANALYTICAL RESULTS GEI

Samples collected 1987-1988

CNH\PROJECTS\10971002\065\TROYDFT A-l 07/05/96

ATTACHMENT B

TROY MILLS LANDFILL

SEDIMENT SAMPLE ANALYTICAL RESULTS ROY F. WESTON, INC.

Samples collected August 30, 1995

CNH\PROJECTS\10971002\065\TROYDFT A-l 07/05/96