CHLOR-ALKALI FACILITY (FORMER)
On this page:
- What Has Been Done to Clean Up the Site?
- What Is the Current Site Status?
- Activity and Use Limitations
On related pages:
The 41-acre Site in Berlin, New Hampshire lies on the east bank of the Androscoggin River bounded to the north by Bridge Street and Sawmill Dam, to the east by Hutchins Street, and to the south by the remainder of the former paper plant, now a biomass energy facility. The Site includes a 4.6-acre landfill containing construction debris, capped by a low-permeability membrane and 2-feet of woodchips. The remainder of the Site is vacant with shrubs and successional trees interspersed with wetlands, dirt roads and isolated industrial debris.
From the 1890s to the 1960s, the Site was a chemical plant that included chlorine-producing cell houses. The chemical plant used chlorine to make chloroform, carbon tetrachloride, and other chlorinated organic compounds. The owners razed most of the chemical plant structures and buried them on the property in the 1960s. In 1999, the owners demolished the last cell house and created the 4.6-acre Cell House Parcel landfill in the area of the former cell houses.
The primary contaminants at the Site include mercury, dioxins, furans, polychlorinated biphenyls (PCBs), and semi-volatile organic compounds. Operations in the chemical plant used or generated these contaminants. In 1999, the New Hampshire Department of Environmental Services (NHDES) discovered mercury in the Androscoggin River directly adjacent to, and along the length of, the 4.6-acre landfill. Despite several removal efforts by NHDES and EPA, mercury continues to appear in bedrock fractures on the east bank of the Androscoggin River adjacent to the 4.6-acre landfill. The beads of mercury generally harden into solid metal amalgams, erosion transports these amalgams further downstream.
The Androscoggin River is currently designated “catch-and-release” from Berlin downstream to the Maine border. People who disregard this designation and eat fish caught in the river may be exposed to elevated levels of PCBs, mercury and dioxin, all of which are toxic. Seven rare bird species are known to live or feed close to the Androscoggin River near the Site and could, therefore, be harmed by the contaminants being released from the site. These species include the bald eagle, peregrine falcon, common nighthawk, northern harrier, osprey, common loon, and Cooper’s hawk.
What Has Been Done to Clean Up the Site?
EPA began a Remedial Investigation (RI) during the summer of 2009 to characterize the nature and extent of contamination and evaluate the risks at and from the Site. EPA issued the RI in March 2014 and found potential risk to human health and the environment in soils and groundwater at the Site. In 2015 Georgia-Pacific took over the investigation and did additional work to characterize the landfill and continue to recover mercury from the river. Georgia-Pacific also repaired the landfill surface and the retaining wall adjacent to the river. Georgia-Pacific is revising a Feasibility Study that should be complete in Fall 2019. EPA will propose a cleanup based on the final Feasibility Study and propose that plan to the public for review and comment. Following public comment on the plan, EPA will then select a remedial strategy for Site cleanup. It is expected that the public meeting and hearing will occur in Fall 2019, and the final remedy will be selected by EPA during the spring of 2020.
In 1999, Crown Vantage Paper Company, which then owned the property, conducted closure activities intended to isolate contamination from the surrounding environment. Crown Vantage demolished the remaining chemical plant buildings and installed a slurry wall from the ground surface to bedrock, approximately 20-feet deep, on the east and south sides of the landfill and a low-permeability cap over the 4.6-acres. After mercury was discovered in bedrock fractures of the Androscoggin River, grout was injected into some of the bedrock fractures. Despite these response activities, mercury is still being found in the Androscoggin River adjacent to the landfill.
Between 1999 and 2006, the property owner (then Pulp and Paper of America, LLC) and NHDES removed over 135 pounds of mercury and mercury-containing debris from the river and its bank.
Monitoring of the Androscoggin River and General Environment
EPA collected surface water and sediment samples from several points along the Androscoggin River from 2006 to 2010 to determine the effect of the discharge of contaminants from the Site. These points included samples upstream of the former facility and along the river through Gorham, New Hampshire. EPA used this preliminary data to better focus additional investigations during the summer of 2009. In July and August 2009, EPA collected samples of surface water, sediment, fish and other organisms within the river to determine the effect on the river environment. EPA used those results to perform a second phase of monitoring in and around the river during the summer of 2010. During the summer of 2010, environmental sampling was expanded to include birds, bats, and insects to determine the distribution of contaminants in the environment surrounding the river.
Characterization of the Site
During the summer of 2009, EPA began investigating soils and groundwater at the Site including the material under the cap at the 4.6-acre landfill. EPA obtained samples of debris, soil, rock, air and groundwater through sampling of existing monitoring wells, test-pitting and drilling. Those data were used to guide the performance of further investigations in 2010 and 2011, resulting in the 2014 Remedial Investigation and guiding the conduct of the current Supplemental Remedial Investigation.
EPA issued a full Remedial Investigation with a Risk Assessment in March 2014. It is publically available both on-line and at the Berlin New Hampshire Public Library. This report contains the sampling results from the multiple field investigations performed between 2006-2011 and describes what current and future potential risks may be posed by the contamination found at and around the Site. Georgia-Pacific did supplemental investigations of the landfill and the river resulting in a Supplemental Remedial Investigation in 2017.
To evaluate and design a remedy for the Site, EPA determined that additional investigations and a waste treatment/disposal pilot study was necessary. These investigations began in summer 2015 and will continue through summer 2016. These investigations will result in a Supplemental Remedial Investigation (SRI) and a Feasibility Study.
EPA will select a remedy from the Feasibility Study and present that proposal in a Proposed Plan to the public for review and comment. EPA will first hold a meeting to discuss the proposal and then after some weeks for review, accept comments from all parties as to the proposal. Following the comment period, EPA will select a remedy based on 9 criteria, the first being protection of public health and the environment and another including community acceptance. EPA will then present that remedy in a Record of Decision (ROD). The Record of Decision will likely be signed by EPA, selecting the final remedy, in summer of 2018.
Enforcement Highlights On April 21, 2015
EPA entered into an Administrative Settlement with Georgia-Pacific to perform additional investigations at the Site to better characterize wastes for disposal. Georgia-Pacific investigated contaminants in the 4.6-acre landfill during summer 2015 and will expand those investigations during summer 2016. This work will result in a Supplemental Remedial Investigation and Feasibility Study.
What Is the Current Site Status?
The Site is secured against accidental trespass by fencing and the landfill is capped reducing the potential for exposure. Current work at the Site has all necessary signage, monitoring and fencing to prevent accidental entry into the area of investigations. The Remedial Investigation found the potential for risk to human health to trespassers that contacted wastes within the landfill and to fishermen that consume fish caught down-stream of Sawmill Dam. The State of New Hampshire prohibits keeping fish caught in this section of the river. The landfill cap is maintained and the retaining wall that separates the landfill from the Androscoggin River was repaired during the Summer of 2017. Georgia-Pacific continues to collect mercury that appears in the river and on the riverbank annually.
Investigations and additional data collection both on the Site and in the river, along with an on-going treatability study, will enable Georgie-Pacific to develop a number of remedies in the upcoming Feasibility Study.
Activity and Use Limitations
At this site, activity and use limitations that EPA calls institutional controls are in place. Institutional controls play an important role in site remedies because they reduce exposure to contamination by limiting land or resource use. They also guide human behavior. For instance, zoning restrictions prevent land uses – such as residential uses – that are not consistent with the level of cleanup.
For more background, see Institutional Controls.
Site control measures include fences and signs that limits exposure and an Activity and Use Restriction on the deed that prevents construction at the Site.