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Waste Site Cleanup & Reuse in New England
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  KEEFE ENVIRONMENTAL SERVICES


Map this site in Cleanups in My Community
 Epping,  New Hampshire
 Rockingham County
 Street Address: EXETER RD
 Zip Code: 03042
 Congressional
 District(s):

01
 EPA ID #: NHD092059112
 Site ID #: 0101114
 Site Aliases: KES

 Site Responsibility: Federal, State

 NPL LISTING HISTORY
 Proposed Date 10/23/1981
 Final Date 09/08/1983

Site Description
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The Keefe Environmental Services site, covering 7 acres in Rockingham County, was operated as a chemical waste storage facility from 1978 until 1981, when the company filed for bankruptcy. Waste storage containers that were present on the site at that time included 4,100 drums, four 5,000-gallon and four 10,000-gallon aboveground storage tanks, and a 700,000-gallon synthetically lined lagoon. Solvents, acids, caustics, heavy metals, paint sludges, waste oils, and organic chemicals were disposed of at the site. Soil and groundwater on and off the site have been contaminated. The site is located in a State-protected watershed with wetland areas draining to the Piscassic River. The site is located in a semi-rural area. There are approximately 12 houses, with a population of 30 people, located along Exeter Road, south of the site. The groundwater aquifer is used as a water supply for ten residences located nearby and is the major source of drinking water for approximately 2,000 people within a 3-mile radius of the site. The Town of New Market has a water supply intake on the Piscassic River, 7 miles downstream from the site.

Threats and Contaminants
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The groundwater at the site is contaminated with chlorinated volatile organic compounds (VOCs) including trichloroethene (TCE), perchloroethene (PCE), 1,1-dichloroethene (1,1-DCE), 1,2-dichloroethane (1,2-DCA), 1,4-dioxane and benzene. Soils adjacent to the lagoon were contaminated before cleanup was completed. Drinking contaminated groundwater poses a potential threat to workers or others at the site.

Cleanup Approach
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On March 21, 1988, EPA issued a second Record of Decision (ROD) for the groundwater cleanup which included the extraction and treatment via air stripping and carbon adsorption. On June 8, 1990, EPA issued an Explanation of Significant Differences (ESD) for the site, to remove the 1988 ROD requirement for additional treatment utilizing soil vapor extraction. Soil vapor extraction was intended to remove contaminants from shallow soils; however, additional soil sampling indicated lower concentrations than had been expected. An ESD was also written in 2005 to change the groundwater treatment technology from air stripping to a HiPOx system which uses ozone and hydrogen peroxide to reduce contaminant concentrations. The new HiPOx system began operating in 2005, with a two year shutdown/rebound study being performed between 2007 and 2009. In 2009, the extraction system was modified and the HiPOx system was placed back into continuous operation through December 2011. The system was shut down again in January 2012 to perform another two year rebound study. At the time of the 2012 shut down, concentrations in the both the influent and effluent met the groundwater cleanup levels.

Response Action Status
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Initial Action In 1981, when the site operations ceased, the EPA declared an emergency at the site after determining that the waste lagoon was about to overflow. The EPA and the State initiated emergency actions that included drawing down the lagoon to lessen the threat of a spill. In continuing emergency response actions during 1983 and 1984, the EPA and the State removed more than 4,000 drums, four 5,000-gallon aboveground tanks, and four 10,000-gallon aboveground tanks of hazardous waste.

Lagoon The actions for cleanup of the lagoon included removing the contents of the lagoon and lagoon liner, and removing the highly contaminated soil adjacent to the lagoon for disposal at a regulated facility. These cleanup activities were completed in 1984.

Groundwater The groundwater cleanup activities chosen by EPA in the 1988 ROD included: treatment by pumping the contaminated groundwater, filtering volatile contaminants by aerating the groundwater with air, and capturing the airborne chemicals by carbon adsorption. Treated groundwater was to be discharged into a groundwater recharge area adjacent to the wetland along the site border. In 1990, the State completed the design for the groundwater remedy. Construction of the groundwater treatment facility began in 1990 and was completed in the spring of 1993. The treatment system was changed from air stripping to HiPOx (ozone/hydrogen peroxide) to address 1,4-dioxane which is not treated through air stripping. Currently, long-term operation and maintenance activities of the groundwater treatment facility are being performed by the State, following transfer of site responsibilities from EPA to the State in June 2005. EPA and NHDES shut off the system again in December 2011 to perform a two year rebound study.

Groundwater - 1,4-Dioxane In 2003, a new chemical of concern was detected in the groundwater at the site. This compound, known as 1,4-dioxane, is typically associated with the use of 1,1,1-trichloroethane (TCA) which was also found at the site. EPA and State initiated a full analysis of the groundwater and nearby residential wells in March of 2004 to determine the extent of this contaminant. The compound was not detected in any nearby residential wells. The EPA and State reviewed the groundwater data and determined that a change in the treatment component of the current groundwater treatment system was required. The States contractor, Woodard and Curran, reviewed potential technologies available to treat both the 1,4-dioxane and the other VOCs found in the groundwater at the site. EPA selected a High Pressure Oxidation System which was installed in the Fall of 2004. Operation of this new system was tested through June of 2005. Since the site lead has been transferred to the State for long-term operation and maintenance activities, the system has operated as intended; the overall area and concentration of contaminants have decreased and no problems have been encountered with the new system. In 2007, the system was shut down to allow EPA and the State to access whether there is any rebound of the groundwater concentrations in the absence of continuous groundwater pump and treat activities. While the system was not operating, groundwater data was being collected (including the nearby residential drinking water wells), to ensure that no adverse response to the shut down is observed. The results of this rebound study were evaluated and released in a report in March 2009. The results (also discussed below) indicated that while contaminant concentrations have been reduced across the site, 1,4 dioxane appears to have migrated towards the boundaries of the site under non-pumping conditions at levels just above cleanup levels. As a result NHDES restarted the pump and treat system, adding additional wells to the pumping circuit to try to further reduce the 1,4-dioxane concentrations across the site and added 7 additional wells to be monitor boundary conditions. The pump and treat system was started again in March 2009, and operated continuously until it was shut down again in December 2011 for another two year rebound study. At the time of shut down, the treatment plant influent concentrations were below groundwater cleanup levels; however concentrations in various areas of the plume remained just above cleanup levels. Degradation products for most contaminants are seen in groundwater sampling data, primarily the chlorinated compounds. 1,4-dioxane does not appear to degrade. Concentrations of 1,4-dioxane attenuate through dispersion and via discharge to surface waters and exposure to sunlight. Very small amounts of 1,4-dioxane were seen in nearby surface water (small streams) suggesting that some dispersion of the 1,4-dioxane is upward and toward these small streams. In deeper areas of the Site, 1,4-dioxane is seen above groundwater cleanup levels in bedrock wells. EPA and NHDES are monitoring the bedrock wells across the Site and at the boundaries to further understand the 1,4-dioxane migration within the bedrock.

Transfer of Site Responsibilities from EPA to State In June of 2005, the EPA transferred full responsibility for the remainder of the cleanup of the site to the State of New Hampshire. The activities undertaken to complete this transfer, included the removal of the leaching system and contaminated soils from the former lagoon area, the regrading of the former lagoon area, the demolition and disposal of the former drum storage and decontamination pad areas, and the restoration of the wetlands abutting the site.

Results of the 2007-2009 Rebound Study The NHDES's contractor, Woodard and Curran, recently completed a 2+ year rebound study. While the overall VOC mass has been significantly reduced through the pump and treat operation, the relaxation of the water table (under non-pumping conditions) appears to have allowed the most mobile contaminant, 1,4 dioxane to migrate to the site's established boundary as approved in the Groundwater Management Zone (GMZ) permit. In addition, a few bedrock wells which had previously not shown contamination were now indicating low levels of site contaminants and certain monitoring (overburden) wells showed little to no change in concentrations, indicating a concern regarding the current ability of the pump locations to capture and treat some areas of groundwater contamination. Subsequently, EPA and the NHDES determined that the pump and treat system should be placed back in operation and supplemented with additional pumps placed in wells to capture all areas of the plume. The system was back in operation by the end of March 2009. Seven additional wells were installed in January 2010 to continue to monitor the groundwater in the areas it may migrate to under non-pumping conditions. Pump and treat operation will continue through December 2011 at which time an additional rebound study is expected to be performed.

Residential Sampling NHDES and their contractor Woodard and Curran collected and analyzed nearby residential private wells for site related contamination since the fall of 2009. There have been no site related contaminants found in any residential well tested. Residential sampling is conducted yearly. Residential Well sampling has continued through 2011 and no site related contaminants have been detected. Residential sampling will continue though 2013.

Groundwater Management Zone The NHDES established a Groundwater Management Zone (GMZ) around the Site in 2005. Within this zone, groundwater is monitored to ensure that contaminants do not migrate beyond the boundaries and over time, reach groundwater cleanup levels across the Site. In 2012, NHDES wrote to the Town of Epping proposing that the 2005 Groundwater Management Zone boundaries be expanded to account for: 1) the migration/dispersion of 1,4-dioxane in both the northwest and southeast portions of the Site (under non-pumping conditions), and 2) potential consideration by NHDES of a lower 1,4-dioxane groundwater cleanup standard in the future (0.35 ug/l versus the current standard of 3.0 ug/l).

Enforcement HighlightsA Consent Agreement was entered into with 119 parties potentially responsible for site contamination in 1986. The EPA filed suit against the non-settling parties in 1989. A Unilateral Administrative Order (UAO) was issued in 1990. In late 1991, the State took over the cleanup of the site from the potentially responsible parties. A final Consent Decree, with approximately 150 potentially responsible parties, was settled in court in late 1992, requiring the parties to perform the selected cleanup actions.

Environmental Progress
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Construction of all remedies has been completed at the Keefe Environmental Services site. The potential for direct contact with contaminated soil has been eliminated, and groundwater contamination is being reduced as treatment continues.

2008 Five-Year Review: EPA conducted the fourth Five-Year review of the site to ensure that the remedial actions remained protective of human health and the environment and functioning as intended. At the time of this review, the treatment system had been shut down and rebound effects were being evaluated. This Five Year Review was conducted because groundwater concentrations at the site remain above drinking water standards. The review indicated that an evaluation of the need for and the cost effectiveness of restarting the pump and treat system over monitored natural attenuation of the groundwater would be beneficial at this time. While concentrations of VOCs have decreased through extraction and treatment, the effectiveness of continued operation is uncertain. In addition, the 1,4-dioxane concentrations have decreased; however, 1,4-dioxane appeared to have mobilized towards the boundaries of the site just above drinking water standards, indicating a potential need to restart the treatment unit to both reduce the source area concentrations and to provide containment within the existing groundwater management zone (i.e., groundwater institutional control). In the meantime, exposure pathways that could result in unacceptable risks are being monitored both on the site and in residential wells off-site. The next Five year Review is due in 2013.

Current Site Status
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Groundwater concentrations for VOCs have been significantly reduced by the actions undertaken at the site to date, yet concentrations still remain at levels above health-based standards for drinking water consumption. Groundwater under the site is not currently used for drinking water, but is classified as a potential drinking water source. The principal contaminants of concern in the groundwater are the VOC chlorinated compounds, including 1,1-DCE, 1,2-DCA, benzene, PCE, TCE, 1,1-DCA, and tetrahydrofuran (THF) -- see 1,4-dioxane discussion in next paragraph. The areal extent of the VOC contamination in groundwater has shrunk in size and is now contained underneath and just to the south of the former Keefe operating facility.

EPA and the State are continuing to review groundwater data from the site to determine the extent of 1,4-dioxane in the groundwater. EPA and the State installed a new treatment system which addresses both the VOCs and the 1,4-dioxane found in the groundwater during the Fall of 2004. EPA transferred responsibilities for the site to the State of NH in June of 2005. Activities performed prior to the transfer and documented in the June 2005 ESD included additional soil sampling, decommissioning and dismantlement of wells no longer used at the site, excavation and off-site disposal of contaminated soils in the former lagoon area, demolition and disposal of the former drum storage and decontamination pad areas and wetland restoration measures.

A cost effectiveness evaluation for pump and treat, along with an evaluation regarding the potential for monitored natural attenuation at the site have been conducted. These reports were released in 2009. The rebound study indicated that the contamination in the groundwater has been contained to the Site and has decreased through the pump and treat operations. The relaxation of the groundwater table during non-pumping conditions appears to have allowed the more mobile contaminant, 1,4-dioxane, to migrate to the GMZ boundary above the 3 ug/l standard set by the NHDES (see Site figure below). As a result, the pump and treat operations were restarted in March of 2009. Seven additional wells were installed at the site (January 2010) to continue to monitor groundwater at the perimeters of the site. Additional pumping has been employed at several monitoring wells to increase the capture of the contaminated groundwater at the site. Pump and treat operations were then continuously performed through December 2011 and the system was shut off in early January 2012. Data collected in the fall of 2011 indicates that, while the concentrations of 1,4 dioxane have been further reduced, concentrations remain at the GMZ boundaries which are above the 3.0 ug/l cleanup level. NHDES is expected to expand the GMZ towards or just beyond the newest boundary wells (the MW 50 series), all of which meet the cleanup standards. This will be done in part to establish and monitor the areas (northeast and southwest of the Site) where 1,4-dioxane may migrate to under non-pumping conditions and to account for NHDES's review of a potential change in the groundwater cleanup level for 1,4-dioxane in the future from 3.0 ug/l to 0.35 ug/l. Monitoring was performed in the spring of 2012 at the boundary wells and is expected to be performed in the fall of 2012, and spring and fall of 2013 to support the upcoming, September 2013 Five Year Review report and to meet monitoring requirements of the Groundwater Management Permit.

Site Photos
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SDMS #480741

Links to Other Site Information
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Disclaimer Instructions about PDF

Newsletters & Press Releases:
Press Releases about this project  

Federal Register Notices:
Final NPL Listing  

Reports and Studies:
Five Year Review Report, February 22, 1993 (229KB)  
Second Five Year Report, September 29, 1997 (800KB)  
Third Five Year Report, March 26, 2003 (2,224KB)   
Fourth Five Year Review Report, July 31, 2008 (opening file is 28.7MB with links to external PDF files)  
Fifth Five Year Review Report, September 9, 2013 (69.8 MB)  

Decision Documents:
View Records of Decision (RODS) on-line (EPA HQ)  
Explanation of Significant Differences for OU 02, June 30, 2005 (1.2MB)  
Institutional Controls for this site  

Other Links:
NPL Site Narrative at Listing:  
Site Progress Profile  

Site Repositories
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Harvey-Mitchell Memorial Library, 52 Main Street, Epping, NH 03042

OSRR Records and Information Center, 1st Floor, 5 Post Office Square, Suite 100 (HSC), Boston, MA 02109-3912 (617) 918-1440


Contacts
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EPA Remedial Project Manager: Cheryl Sprague
Address: EPA New England, Region 1
5 Post Office Square, Suite 100
Mail Code OSRR07-1
Boston, MA 02109-3912
Phone #: 617-918-1244
E-Mail Address: sprague.cheryl@epa.gov

EPA Community Involvement Coordinator: Rodney Elliott
Address: US Environmental Protection Agency
New England Regional Laboratory
11 Technology Drive
Chelmsford, MA 01863-243
Phone #: 617-918-8372
E-Mail Address: elliott.rodney@epa.gov

State Agency Contact: Robin Mongeon
Address: NHDES
29 Hazen Drive, PO Box 95
Concord, NH 03302-0095
Phone #: 603-271-7378
E-Mail Address: robin.mongeon@des.nh.gov

Contractor for NHDES Dave Dedian
Project Manager
Address: Woodard and Curran
41 Hutchins Drive
Portland. ME 04102
Phone #: 1-800-426-4262
E-Mail Address: ddedian@woodardcurran.com

 


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Last updated on Monday, September 23rd, 2013
URL: http://www.epa.gov/region1/superfund/sites/keefe