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Waste Site Cleanup & Reuse in New England
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 Site Type: Long Term/National Priorities List (NPL) Click to see more about Site Type and how it is used?


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 Nashua,  New Hampshire
 Hillsborough County
 Street Address: FAIRMONT STREET
 Zip Code: 03060

 EPA ID #: NHD981889629
 Site ID #: 0101188
 Site Aliases:

 Site Responsibility: Federal, State

 Proposed Date 05/11/2000

Site Description
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The former Mohawk Tannery facility (a.k.a. Granite State Leathers) is located on approximately 30 acres in Nashua, Hillsborough County, New Hampshire. The currently inactive facility produced tanned hides for leather between 1924 and 1984. The site was proposed to the National Priorities List (NPL) on the basis of past disposal practices which included the direct discharge of wastewater containing such hazardous substances as chromium, zinc, and phenol into the Nashua River and the disposal of sludge containing such hazardous substances as chromium, pentachlorophenol, phenol, and 2,4,6-trichloropehenol into a number of unlined disposal areas at the site. Two of the largest disposal areas are located directly next to the Nashua River; with one of these areas within the 100-year flood plain. These disposal areas were not designed, constructed, operated, and maintained to prevent the washout of hazardous substances in the event of a flood. The confluence of the Nashua and the Merrimack Rivers is located approximately 3.5 miles downstream of the site. Both the Nashua River and the Merrimack River are fished extensively and wetlands are located along both rivers. Approximately 5,025 people receive drinking water from ground water wells within a 4-mile radius of the Site. However, a majority of the people living near the site are being supplied with potable water through the local water district.

The Site is comprised by two contiguous, approximately 15 acre parcels of land: a developed "northern parcel" that was historically used for tannery and waste disposal operations, and a "southern parcel" that is undeveloped and does not appear to have been used by the former tannery.

Threats and Contaminants
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Analytical data from the former tannery property documents the presence of elevated levels of metals (e.g., chromium) in ground water, soil, and (in a limited area) in sediments within the Nashua River. Other contaminants detected in the sludge placed within the unlined disposal areas at the site include pentachlorophenol, 4-methylphenol, 2,4,5-trichlorophenol, and dioxins. People could be exposed to contaminants by coming into direct contact with contaminated soils and sludges at the site. In the past, New Hampshire Department of Environmental Services (NHDES) personnel have observed children riding bikes along an on-site dirt trail between the river and the two largest on-site surface impoundments.

Cleanup Approach
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The site is still proposed on the National Priorities List (NPL). EPA has undertaken some initial actions to address the threats posed by the site and, in 2002, proposed a Non-Time-Critical Removal Action (NTCRA) for the sludge disposal areas. At the request of the City of Nashua, EPA did not move forward with the final NPL listing and the proposed NTCRA was put on hold. Additional response actions for the site are uncertain at this time.

Response Action Status
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Initial Action EPA began a removal action in September 2000 to remove and dispose of asbestos-containing material from the old tannery building; to characterize and dispose of contamination contained in drums and tanks on-site; and to remove empty drums, containers, and tanks and dispose of them at an off-site facility. This work was completed in January 2001. In an effort to further secure the site during the removal action, EPA repaired a number of gates and posted warning signs about the dangers of trespassing. These gates and fences are currently maintained by the former property owner under an agreement in 2006 with EPA and NHDES.

Sludge Disposal Areas In July 2002, EPA completed and released an Engineering Evaluation/Cost Analysis (EE/CA) report for the site. The EE/CA provided a detailed analysis of a select few cleanup options for the six waste disposal areas at the site and also identified EPA's recommended cleanup approach for these disposal areas at that time. After releasing the EE/CA, EPA held a 30-day comment period to provide interested parties with an opportunity to comment upon EPA's recommended cleanup approach. During the comment period EPA held a public information meeting and a public hearing. Most of the comments provided during the public comment period were supportive of the proposed excavation and off-site disposal approach recommended by EPA. A copy of the comments as well as EPA's responses are attached to the Action Memorandum. The Action Memorandum, which is the decision document prepared by EPA describing the Non-Time-Critical Removal Action (NTCRA) for the disposal areas at the site, was completed in October 2002 and is still currently on hold per the request of the City of Nashua.

Groundwater and Other Potential Areas Under a cooperative agreement with EPA (which was approved and funded in September 2001), the NHDES took the lead role in carrying out the RI for the remaining areas at the site. The NHDES subsequently hired Sanborn, Head & Associates to prepare the RI which involved investigations of the groundwater, the soils outside the sludge disposal areas, and several structures still remaining on-site. The field work for the RI was completed in August of 2003 and the draft RI report was issued in the summer of 2005.
Subsequent groundwater and a very limited sediment sampling effort were undertaken by EPA staff in late 2006-2007, and again in 2010.

Enforcement HighlightsBetween 2005 and August 2006, EPA and the NHDES commenced and completed settlement negotiations with the property owner (Chester Realty Trust) and Mr. Warren Kean (Trustee). The settlement is described in detail in U.S. EPA Docket No. CERCLA 1-2005-0053.

Environmental Progress
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Removing asbestos-containing material and drums/containers from the site has reduced the potential for exposure to these hazardous substances. Efforts by EPA (and the property owner) to further secure the site have also reduced the potential for exposure to hazardous substances. EPA has determined that this site does not pose an immediate threat to human health, and will continue to monitor the site for any changes that may trigger additional action.

Current Site Status
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The site was proposed on the NPL in May 2000. Removal activities were completed by EPA in January 2001. EPA completed and released an Engineering Evaluation/Cost Analysis (EE/CA) report to the public in July 2002 for the six waste disposal areas on the site. EPA prepared an Action Memorandum in support of a Non-Time-Critical Removal Action (NTCRA) for these six waste disposal areas in October 2002. Subsequent to the release of this Action Memorandum, City of Nashua officials at that time requested that EPA not move forward with the Final NPL listing so that other funding mechanisms for site cleanup could be pursued. In addition, the proposed NTCRA was put on hold at that time. In the interim, the NHDES (through a cooperative agreement with EPA) took the lead on the Remedial Investigation (RI) for the developed northern parcel in 2001, and released their findings in a draft RI report in June 2005.

Only limited investigations have been undertaken at the site since June 2005 (other than a treatability study of the sludge lagoons completed in 2009) until a resolution of the funding mechanism (e.g. private developer or finalization of site on NPL) for site cleanup is reached. In June 2012, the City of Nashua funded the complete demolition and asbestos abatement needed to remove the remains of the former tannery buildings (excluding the slabs). See photo below. These buildings had become an attractive nuisance and had been suspiciously burned on several occasions prior to demolition in 2012.

EPA and NHDES initiated several field investigation activities in the summer/fall of 2012 within the southernmost, 15-acre parcel of the overall 30-acre tannery property. The purpose of these investigations was to evaluate whether all or a portion of this undeveloped, 15-acre southern parcel can be considered for de-proposal from the rest of the NPL site. The outcome of these investigations/activities was documented in the Summary of Field Documentation and Analytical Data and Risk Summary Tables and Figures in July 2013 (see this document at the Reports and Studies section below).

A local developer has showed interest in acquiring the Site with the idea of remediating the northern parcel and putting the entire property back into productive use. The developer is in the process of securing tenants, meanwhile EPA is in the process of re-defining the boundaries of the Site to largely reflect those of the northern parcel. This re-definition of the Site boundaries will be based on the July 2013 report noted above, and will potentially allow for: a) EPA and NHDES to focus their efforts on remedial actions for the northern parcel, and b) allowing the City of Nashua to acquire the southern parcel for potential conservation/recreation purposes.

Currently the developer is preparing a Remedial Action Work Plan that describes how they will address the contamination problems that remain on the Site. This remedial action plan will be reviewed by EPA and NHDES. If the redeveloper withdraws from their remediation and re-development plans, EPA, NHDES and the City will need to discuss the future steps required to cleanup this Site.

Site Photos
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SDMS 452947
Area 1 Disposal Lagoon

SDMS 507288
Former Tannery Buildings

Links to Other Site Information
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Disclaimer Instructions about PDF

Newsletters & Press Releases:
Press Releases about this project  
Fact Sheet: EPA Plans Cleanup for Waste Disposal Areas, July 2002 (214 KB)  
September 2012 Site Update (882 KB)  

Federal Register Notices:
Proposed NPL Listing  

Administrative Records:
Non-Time-Critical Removal Action Administrative Record Index, October 29, 2002 (391KB)  

Reports and Studies:
Removal Program After Action Report, April 1, 2001 (4.77 MB)   
Engineering Evaluation/Cost Analysis, July 2002  
Emergency Response Activities, December 13, 2007 (1.57 MB)  
Solidification/Stabilization Bench-Scale Treatability Study, December 1, 2009 (1.25 MB)  
Summary of Field Documentation and Analytical Data and Risk Summary Tables and Figures, July 1, 2013 (54.5 MB with a link to an additional file)  

Decision Documents:
View Records of Decision (RODS) on-line (EPA HQ)  
Action Memorandum - Non-Time-Critical Removal Action, October 29, 2002  

Settlement Documents:
Settlement Agreement, April 28, 2006 (2.0 MB)  

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

Site Repositories
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Nashua Public Library, 2 Court Street, Nashua, NH 03060 (603) 594-3412

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

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EPA Remedial Project Manager: Gerardo Millán-Ramos
Address: US Environmental Protection Agency
5 Post Office Square, Suite 100
Mail Code OSRR07-1
Boston, MA 02109-3912
Phone #: 617-918-1377
E-Mail Address: millan-ramos.gerardo@epa.gov

EPA Community Involvement Coordinator: Rodney Elliott
Address: US Environmental Protection Agency
New England Regional Laboratory
11 Technology Drive
Chelmsford, MA 01863-2431
Phone #: 617-918-8372
E-Mail Address: elliott.rodney@epa.gov

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


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Last updated on Wednesday, November 4th, 2015
URL: http://www.epa.gov/region1/superfund/sites/mohawk


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