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Waste Site Cleanup & Reuse in New England
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 Troy,  New Hampshire
 Cheshire County
 Street Address: Off Rockwood Pond Road
 Zip Code: 03465

 EPA ID #: NHD980520217
 Site ID #: 0101127
 Site Aliases: Rockwood Brook Landfill

 Site Responsibility: Federal

 Proposed Date 04/30/2003
 Final Date 09/29/2003

Site Description
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The Troy Mills Landfill Superfund site is located about 1.5 miles south of the center of Troy, New Hampshire. It is situated off a dirt road and on the wooded portion of a larger 270-acre parcel of property. Sand Dam Pond, a recreational pond used for swimming and fishing, is located on Rockwood Brook approximately one mile downstream from the Troy Mills Landfill Superfund site. The two-acre Troy Mills Landfill Superfund site was used from 1967 to 1978 by Troy Mills, Inc., a local fabric manufacturer, as a drum disposal area for an estimated 6,000-10,000 drums of liquid wastes and sludge. The wastes included and contained solvents, vinyl resins, plasticizers, pigments, and top-coating products. Immediately to the north of the former drum disposal area is a separate eight-acre solid waste landfill, regulated by the New Hampshire Department of Environmental Services (NHDES), which was used until 2001 for the disposal of waste fabric scraps and other miscellaneous solid waste generated by manufacturing operations at the Troy Mills, Inc. complex. The solid waste landfill is not part of the Superfund site.

Threats and Contaminants
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EPA and the State have identified elevated levels of metals, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs) which originated from the former drum disposal area and have impacted groundwater. In 1980, the New Hampshire Water Supply and Pollution Control Division collected samples from the site which indicated the presence of inorganic constituents above background concentrations and regulatory standards. Additional studies in the 1980s and 1990s, conducted by Troy Mills, Inc., identified crushed drums and drummed liquid and sludge wastes in the two-acre drum disposal area. Sampling of these wastes identified metals, SVOCs, and VOCs, including xylenes up to 19,000 parts per billion (ppb), bis (2-ethylhexyl) phthalate up to 110,000 ppb, benzyl butyl-phthalate up to 13,000, di-n-octyl phthalate up to 6,200 ppb, and cadmium, chromium, and zinc at varying concentrations. Elevated levels of iron and manganese were detected in groundwater and leachate samples, and 1,1,1-trichloroethane, ethylbenzene, toluene, trichloroethylene, 1,2-dichloroethane, 1,1-dichloroethane, benzene, diethylene chloride, and tetrachloroethylene were also detected in the groundwater. Leachate from the landfill discharges into an adjacent wetland. Current monitoring results from wetland soils show elevated concentrations of manganese and bis (2-ethylhexyl) phthalate.

In 2005, EPA completed a Remedial Investigation (RI) at the site. As part of the RI, EPA collected and analyzed surface water, sediment, and wetland soil samples from nearby Rockwood Brook and the surrounding wetland. EPA also evaluated current and historical groundwater data, collected and analyzed air and soil samples from locations throughout the former drum disposal area. The RI found a plume of groundwater contamination, approximately 8-9 acres in size. Organic contaminants such as alkylbenzenes, chlorinated solvents, phthalates, and toluene are the primary chemicals of concern in the groundwater. The RI also documented the presence of floating free product and contaminated leachate at the site.

Cleanup Approach
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Contaminated groundwater and floating free product was detected in groundwater monitoring wells at the two-acre drum disposal area. In 2003, EPA implemented an interim system to collect the free product in a series of interceptor trenches, and in 2004 EPA commenced a drum removal action. In 2005, the drum removal action was completed and EPA issued a Record of Decision (ROD) which outlines the long-term cleanup actions to be taken at the site.

Response Action Status
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Initial Action In 2003, EPA completed construction of a series of interceptor trenches to collect floating free product that was emanating from the two-acre drum disposal area and began maintaining the system.

Drum Removal Action In July 2004, a drum removal action was initiated to excavate an estimated 6,000 to 10,000 drums buried at the site. The drum removal action was completed in Summer 2005 with the excavation and off-site disposal of 7,692 buried drums, 29,924 gallons of flammable liquid waste, 3,099 cubic yards of sludge, and 26,244 tons of heavily contaminated soil. The interceptor trenches were maintained throughout the period of the drum removal action. Following completion of the drum removal action, a permeable soil cap was constructed over the drum excavation area.

Remedial Action On September 30, 2005, the Final ROD was issued for the Troy Mills Landfill Superfund site. The ROD sets forth the selected remedy for the site which involves allowing naturally occurring processes to reduce contaminant concentrations in groundwater (i.e., monitored natural attenuation); continuing the capture and removal of free product from groundwater using the interceptor trenches installed by EPA in 2003; maintaining the permeable soil cap that was constructed by EPA in July-August 2005 over the drum excavation area; and the establishment of institutional controls. Long-term monitoring of groundwater, surface water, sediment, leachate, and wetlands will be necessary to ensure the effectiveness of the remedy.

LNAPL Interceptor Trench In 2013, EPA decommissioned and removed three LNAPl interceptor trenches that had been constructed during the 2004 drum removal action. The trenches were installed to collect residual LNAPL that was present on the surface of the groundwater table. EPA determined that LNAPL was no longer present at the Site and that the trenches were no longer required, in accordance with the 2005 ROD.

Environmental Progress
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Completing the drum removal action has greatly reduced the risk posed to public health and the environment from potential uncontrolled releases from the buried drums. As a result, EPA determined that this site did not pose any further, immediate threat to human health and the environment. EPA then issued a long-term cleanup plan for the site in 2005 which required the restoration of the groundwater to safe drinking water levels. A Five-Year Review of the remedy was conducted in 2010 as required by statute. The Five-Year Review concluded and reiterated that the drum removal action and construction of the permeable soil cap, in conjunction with the naturally occurring reduction of contaminants in groundwater, continues to be protective of human health and the environment. The second Five-Year Review is ongoing and is scheduled for completion in September 2015.

Current Site Status
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Following issuance of the September 2005 ROD, long-term remedial actions have included periodic inspections and semi-annual environmental monitoring of groundwater, surface water, and sediment quality in and around the site, including within Rockwood Brook and nearby wetlands. These long-term remedial actions are being conducted by NHDES via a cooperative agreement with EPA. The first Five-Year Review, conducted in 2010, concluded that the remedy continued to be protective of human health and the environment, but identified a number of issues and made several recommendations to ensure continued protectiveness. The issues and recommendations, along with their current status, are outlined below:


    Effectiveness of Institutional Controls (ICs), including violations of the State’s existing Restrictive Covenants on the Site (ATV/Dirt bike/snowmobile trespasser use over landfill cap), and evidence of vandalism (damage to select monitoring wells/and pumps, damage to inner access gate);
    Further evaluation is needed regarding the persistence of LNAPL east of the interceptor trenches;
    Further hydrogeologic investigation is needed to evaluate the potential for two overburden groundwater flow systems (upper ablation and lower lodgment) as unique sub units within the till. In addition, further characterization of groundwater flow direction and contaminant migration in bedrock is needed to further evaluate the MNA remedy relative to the bedrock unit; and
    Determine the approximate dimensions and area of sediment in Rockwood Brook or wetland soil where ground water discharges to surface water.
      Recommendations and Follow-up Actions:
        With regard to the effectiveness of ICs at the Site, report violations and vandalism to the State and the Town for response with appropriate follow-up monitoring and enforcement actions. Repair damaged wells with new locking caps, post warning signs for inner gate and former drum disposal area, and consider fencing the former drum disposal area to restrict access by all terrain vehicles. Implementation of these actions has been completed as of 2014.
        Conduct a supplemental investigation of residual LNAPL source area and further evaluate effectiveness of the LNAPL trenches in capturing remaining LNAPL. An investigation of residual LNAPL and LNAPL impacted soils has been conducted and decommissioning of the LNAPL trenches has been proposed. The residual LNAPL investigation was completed and the LNAPL trenches have been decommissioned as of 2014.
        Perform supplemental hydrogeologic studies to confirm hydrostratigraphy and the COC fate and transport in groundwater to confirm the effectiveness of the MNA management of migration remedy at the Site and to better forecast time to cleanup. These studies have been initiated and have provided data that is being used to modify monitoring well locations and depths and to evaluate the effectiveness of the MNA remedy.
        Perform a hydrologic evaluation within the transition zone between groundwater and surface water in the Rockwood Brook Wetland Study area and Rockwood Brook. Review existing data from nearby groundwater monitoring wells relative to appropriate benchmark ecological risk screening values, applied to receptor exposures within the ground water – surface water transition zone. This evaluation has been conducted and the results will be included in the second Five-Year Review.

        Site Photos
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        SDMS 452961
        Construction of free product collection system

        SDMS 452962
        Drum removal

        SDMS 452964
        Drum Removal

        SDMS 452965
        Drum Removal

        SDMS 452963
        Soil cap over the drum excavation area

        Links to Other Site Information
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        Disclaimer Instructions about PDF

        Newsletters & Press Releases:
        Recent Press Releases about this project (if any)  
        Press Release: Cleaning Up New England - Site Update, November 2013 (1.69 MB)  

        Federal Register Notices:
        Proposed NPL Listing  
        Final NPL Listing  

        Administrative Records:
        Removal Action Administrative Record (AR) Index, November 2002 (144 KB)  
        Removal Action Administrative Record (AR) Index, September 2004 (171 KB)  
        Administrative Record (AR) Index for Record of Decision (ROD), Operable Unit 01, September 2005 (217 KB)  
        Supplemental Removal Action Administrative Record (AR) Index, February 2008 (109 KB)   
        Supplemental Removal Action Administrative Record (AR) Index, February 2008 (112 KB)  
        Explanation of Significant Differences (ESD) Administrative Record (AR) Index, April 2014 (460 KB)  

        Reports and Studies:
        Proposed Plan, Operable Unit 01, July 2005 (2.6MB)  
        Reuse Assessment, July 2005 (525KB)  
        Preliminary Closeout Report (PCOR), September 30, 2005  
        First Five Year Review Report, September 29, 2010 (15.3 MB)  
        First Five Year Review Report Appendix C: Sampling Data Report - June 2009 through June 2010 (Opening file is 70.3 MB with links to additional files)   
        Sampling and Analysis Plan for the Spring 2011 Monitoring Round, May 1, 2011 (4.53 MB)  
        Sampling and Analysis Plan for LNAPL Laser Induced Fluorescence / Membrane Interface Probe Investigation, July 20, 2012 (26.1 MB)  
        June 2013 Monitoring Report, Volumes 1 and 2, April 9, 2014 (24.1 MB)  
        Second Five Year Review Report, September 18, 2015  

        Decision Documents:
        View Records of Decision (RODS) on-line (EPA HQ)  
        Record of Decision (ROD), September 30, 2005 (14.7 MB)  
        Explanation of Significant Differences (ESD), March 26, 2014 (1.64 MB)  
        Institutional Controls at this site  

        Other Links:
        NPL Site Narrative at Listing:  
        Site Progress Profile  
        Removal Program Web Site  

        Site Repositories
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        Gay-Kimball Library, 10 South Main Street, Troy, NH 03465 (603) 242-7743

        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: Richard Hull
        Site Responsibilities: Remedial Project Manager
        Address: US Environmental Protection Agency
        5 Post Office Square, Suite 100
        Mail Code OSRR07-1
        Boston, MA 02109-3912
        Phone #: 617-918-1882
        E-Mail Address: hull.richard@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
        Address: New Hampshire Department of Environmental Services
        P.O. Box 95
        29 Hazen Drive
        Concord, NH 03302-0095
        Phone #: 603-271-7378
        E-Mail Address: robin.mongeon@des.nh.gov

        On-Scene Coordinator (Removal Action) Tom Hatzopolous
        Phone #: 617-918-1284
        E-Mail Address: hatzopoulos.athanasios@epa.gov


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