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Record of Decision System (RODS)



Address:  21 ELM ST. 
City & State:  MILFORD  NH  03055
EPA ID:  NHD001079649
EPA Region:  01
NPL Status:  Currently on the Final NPL
ROD Type:  Record of Decision
ROD ID:  EPA/541/R-98/124
ROD Date:  09/30/1998
Operable Unit(s):  01
Media:  Debris, Groundwater, Sediment, Soil, Surface Water
Contaminant:  Base Neutral Acids, Metals, PAH, PCBs, Pesticides, VOC
Abstract:  Please note that the text in this document summarizes the Record of Decision for the purposes of facilitating searching and retrieving key text on the ROD. It is not the officially approved abstract drafted by the EPA Regional offices. Once EPA Headquarters receives the official abstract, this text will be replaced.

The Fletcher's Paint Works and Storage Facility Superfund Site consists of approximately 12 acres of land in the town of Milford, Hillsborough County, New Hampshire. The site is divided into two operable units (OUs). The Fletcher's Paint Site is located in a residential and light commercial/industrial area within the Souhegan River Valley. The Milford area is characterized by three unconfined aquifers which provide the majority of the area's municipal water supply needs. In addition to these unconfined overburden aquifers, there are fractured bedrock aquifers. Both bedrock wells and overburden wells provide domestic water supplies in the Milford area. The Fletcher's Paint Site study area is situated along the southeastern extent of the Milford-Souhegan Aquifer.

Fletcher's Paint was in operation from approximately 1948 until 1991 as a manufacturer and retail distributor of paints and stains for mostly residential uses. The paints were primarily water-based latex paints and organic-based solvent paints. The company's annual production was 25,000 to 35,000 gallons. Following the closure of the Fletcher's Paint Works, a cosignment shop has operated in the front brick portion of the building. Parking for this shop is limited as a result of a 1991 fence installation.

The Fletcher Paint Works and Storage Facility Superfund Site was proposed for inclusion on the National Priorities List (NPL) in June 1988; and finalized in March 1989. In April of 1996, the Environmental Protection Agency (EPA) completed a Remedial Investigation/Feasibility Study (RI/FS). The RI and other studies revealed that soils, sediments, surface waters and groundwater were contaminated with volatile and semi-volatile organic compounds, metals, polychlorinated biphenyls (PCBs), and pesticides.

The first OU of the Fletcher's Paint Site is comprised of three general areas: (1) Fletcher's Paint Works, located at 30 Elm Street, and referred to as the "Elm Street Site"; (2) the former Fletcher's Paint Storage Facility on the northern side of Mill Street, immediately west of the Cottage Street intersection, referred to as the "Mill Street Site"; and (3) the drainage ditch/culvert system that flows northward from the Mill Street Pond, along the Hampshire Paper Company property to Draper Mobil property, where it then flows beneath Elm Street and the Elm Street Site, and discharges into the Souhegan River. All three areas of the site are located within 700 feet of each other.

The Elm Street Site occupies approximately 70,600 square feet and is situated along the southern bank of the Souhegan River. The property is characterized by a single story brick and cinder block building situated in the southeast third of the property. The majority of the Elm Street Site is located within the 100-year flood plain of the Souhegan River. A total of five underground storage tanks (USTs) exist on the Elm Street Site, and five discharge pipes extend out from the banks of the site, discharging to the Souhegan River. Land use at the site prior to 1949 included agricultural farming in the 1800's, hide storage for the nearby tannery, a turn of the century blacksmith and carriage painting business, an armory (1913 to 1926), the town burning dump (1929 to 1947), and an automotive dealership (1920 to 1949).

At the Elm Street Site, various fill materials have extended the property over time, pushing back the Souhegan River from its former position adjacent to Elm Street, to its current position several hundred yards away from Elm Street. The parking area and a portion of the former manufacturing facility is situated on top of an old municipal burning dump, which operated from 1927 until 1945.

The Mill Street Site is an approximately 10,000-square-foot parcel located on Mill Street, 700 feet south of the Elm Street Site. This property housed grain elevators and a grist mill. The Fletcher's Paint Site contained two sheds that were used by Fletcher Paint as warehouses for bulk paint pigments for over twenty-five years. Previously, they had been used for grain storage. The Mill Street Site currently sits vacant. Residential areas are located south and west of the site. Commercial areas are located to the north, east, and west of the site. The Mill Street Pond is located approximately 250 feet southwest of the site.

The drainage ditch/culvert system extends from the Mill Street Pond to the Souhegan River. The flow is carried under Mill Street from the pond, under the Draper Energy Coal Yard, along the Hampshire Paper Company property, where it enters a culvert system behind the Mobil station. The culvert channels the flow under Cottage Street and Elm Street, then under the Elm Street Site, where it discharges to the Souhegan River.
From May through October 1988, the EPA conducted removal actions at both the Elm Street and Mill Street locations. At Elm Street, the main activities performed by EPA were the staging, sampling, analysis, and disposal of 863 drums of hazardous substances and the covering of the contaminated soils of the parking lot with geotextile fabric and fill. At Mill Street, EPA covered contaminated soils, inventoried bags of pigment in the storage shed, and disposed of 12 bags of asbestos contained in the shed.

In November and December of 1991, EPA conducted a second removal, installing a fence at the Elm Street portion of the site and removing laboratory containers found in the building on that portion of the site.

A third removal action was completed by EPA at the Mill Street and Elm Street Sites during the summer of 1993. The removal action included characterization and disposal of wastes found in the Elm Street and Mill Street buildings, demolition and disposal of the Mill Street building, and repair of the caps on both the Mil Street and Elm Street properties. Approximately 500 bags of dry paint pigments, 100 cardboard drums of dry resins, and numerous various-sized containers of unknown materials were found in the Mill Street building. Approximately 327 drums of hazardous substances, 750 bags of paint pigments, 10 bags of friable asbestos, and 2,500 small containers of miscellaneous substances were removed from the Elm Street building. A total of 512 drums and 99 wrangler boxes were disposed of during this action. The Elm Street cap was repaired, and re-graded with 64 tons of crushed stone and 132 tons of ? inch washed stone. A geotextile liner was placed at the Mill Street Site where the shed was formerly located, and 3 to 6 inches of sand fill and 6 to 8 inches of topsoil were placed over the liner. The Mill Street Site was then hydro-seeded.

In the summer of 1995, a fourth removal was completed. PCB-contaminated soil was removed from surface soil, under lawns, and on dirt driveways of three residential properties across from the Mill Street Site. A 10-foot wide paved apron was added to the Mill Street Site at the end of the action to prevent further degradation and wear of the edge of the cap and Mill Street itself was re-paved to direct surface water runoff toward the Fletcher Paint property and away from the residences.

In August of 1996, a voluntary soil cleanup of the small piece of land east of, and adjacent to the Fletcher Paint building was conducted.
A Record of Decision (ROD) was completed in September 1998 addressing OU1.

In December 1995, EPA Region I made the decision to split the Keyes Municipal Well Field and the Souhegan River into a second operable unit (OU2) in order to conduct further investigations of the contamination at those locations.

A 10-acre municipal recreation area, called Keyes Field, is located along Keyes Drive, and encompasses the western portion of the Elm Street Site. The Keyes Field consists of tennis and basketball courts, ball fields, a playground, and a community swimming pool. The pool and playground areas are used heavily by children of all ages. The ball fields and tennis courts are also used by local sport leagues and high school extracurricular sports.

The Souhegan River runs adjacent to the Elm Street Site and the Keyes Field and is used for recreational swimming and fishing. Studies show that the Souhegan River has surface water and sediment contamination, as well as potential impact to certain fish and biota within the river as a result of the contamination.
Remedy:  Phase 1 - Mill Street Cleanup:

To address the current and future risks associated with contaminated surface and subsurface soil at the Mill Street Site, approximately 1,500 cubic yards of surface soils (0 to 1 foot) at the Mill Street Site will be excavated to a depth of 1 foot, wherever polychlorinated biphenyl (PCB) concentrations are greater than 1 mg/kg.

To address the future risk associated with contaminated groundwater at the Mill Street Site as a result of leaching, approximately 12,000 cubic yards of subsurface soils at the Mill Street Site (1 to 20 feet [bedrock] below surface), approximately 3,000 cubic yards of which are located below the water table, will be excavated wherever PCB concentrations remain that exceed 1 mg/kg. Or excavation of soils to a PCB concentration at which leaching models and/or soil column testing show that infiltration through the remaining PCB soil concentrations will not result in future groundwater concentrations in excess of 0.5 ug/l maximum contaminant level (MCL) groundwater concentration for PCBs. The determination of a subsurface soil cleanup level other than 1 mg/kg PCB, will be in the sole direction of the Environmental Protection Agency (EPA).

Water collected from the dewatering of the excavated soils and water collected as a result of lowering of the water table to conduct the excavation, will be either treated on-site in a mobile unit and appropriately discharged to the Souhegan River or sent off-site to a treatment facility. Approximately 13,500 cubic yards of excavated soils will be treated by ex-situ thermal desorption. Liquid PCB condensate produced from the thermal desorption process will be disposed off-site at an appropriate facility. The Fletcher's Elm Street building will be demolished and disposed prior, or following thermal desorption activities. All soil and debris that is either oversized or cannot be treated through the thermal desorption unit will be disposed off-site. The treated soils will be backfilled back onto the Mill Street Site.

The site will be restored consistent to the anticipated future use of the site. Specifically, the majority of the Mill Street Site will be paved, physically re-aligning Mill Street. The pavement will reduce infiltration of precipitation, control erosion and promote drainage away from the residential properties. The storm drainage ditch system will be regraded and repaired, as necessary, to promote surface water flow away from the site.

Phase 2 - Elm Street Cleanup:

To address the current and future risks associated with contaminated surface and subsurface soil at the Elm Street Site, approximately 2,800 cubic yards of surface soils at the Elm Street Site will be excavated to a depth of 1 foot, where PCB concentrations are greater than 1 mg/kg.

Approximately 1,000 cubic yards of subsurface soils, within the utility corridor(s), at the Elm Street Site at depths between of 1 and 10 feet will be excavated wherever PCB concentrations are greater than 25 mg/kg PCB. Final location of the utility corridor(s) within the site will be determined during design. Approximately 11,600 cubic yards of remaining subsurface soils, with the exception of the 'hot spot' materials, from 1 foot to the seasonally low water table will be excavated, where PCB concentrations remain that exceed 100 mg/kg; or to a PCB concentration at which leaching models and/or soil column testing show that infiltration through the remaining PCB soil concentrations will not result in future groundwater concentrations in excess of 0.5 ug/l MCL groundwater concentration for PCBs. The determination of a subsurface soil cleanup level other than 1 mg/kg PCB, will be in the sole discretion of the EPA. The EB-03 'hot spot will be excavated and disposed in an off-site in an appropriate landfill.

The five underground storage tanks located on the Fletcher's Elm Street property will be removed and disposed.

Approximately 15,400 cubic yards of excavated soils will be treatedby ex-situ thermal desorption. The treated soils will then be backfilled on-site.

Either a final grading of and placement of a 10 inch soil cover over the treated soils, or placement of treated soils within the top foot which can demonstrate PCB concentrations less than or equal to 1 mg/kg PCB, will be implemented. Asphalt would be placed on areas designated for parking, consistent with the final grading plans and the future anticipated use of the site.

Institutional controls, in the form of deed restrictions would be implemented to prevent unauthorized access into the subsurface. Deed restrictions would also have to be implemented to restrict future use of the site, or the modification of the cover or surface drainage structures in ways inconsistent with this remedy or the anticipated future use of the site.


A Groundwater Management Zone (GMZ) under New Hampshire's Comprehensive Groundwater Policy will be established. The GMZ sets plume boundaries within which groundwater will be monitored over time. Institutional controls would have to be implemented to restrict the use of the groundwater within the GMZ while contaminant concentrations are in excess of drinking water standards. Further action may be necessary consistent with the New Hampshire Comprehensive Groundwater Policy.

Interim Groundwater Cleanup Levels must be achieved within the GMZ and maintained for a period of three consecutive years. A risk assessment will be preformed on residual groundwater contamination to determine protectiveness of the remedy. If EPA determined the remedy is not protective, the remedial action shall continue until protective levels are achieved and not exceeded for three years or until remedy is deemed protective or is modified.

Estimated Capital Cost: $ 11,791,615
Estimated Annual O&M Cost: $237,380
Estimated Present Worth Cost: $14,731,975
Text:  View full-text ROD [ 356K ]
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