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State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
6 Hazen Drive, P.O. Box 95, Concord, NH 03302-0095

May 28, 1999


CERTIFIED MAIL # Z 535 308 510
RETURN RECEIPT REQUESTED

Mr. Larry Lakey, Vice President
North Country Environmental Services
Permits, Compliance & Engineering
16 State Street
Montpelier, Vermont 05602

SUBJECT: NORTH COUNTRY ENVIRONMENTAL SERVICES LANDFILL
BETHLEHEM, NEW HAMPSHIRE (PERMIT NO. DES-SW-89-009)
GROUNDWATER QUALITY RESULTS- APRIL 1999

Dear Mr. Lackey,

The Department of Environmental Services (Department) is in receipt of the Subject analytical results which were received by the Department May 27, 1999. As noted in the North Country Environmental Services (NCES) cover letter, the concentrations of volatile organic compounds VOCs in monitor well MW-406L were elevated and "seem to be an anomaly when compared to historical data at this location." The Department finds the VOC concentrations very high and of significant concern when compared with historical data. After reviewing the report, the Department has the following concerns/comments regarding the data:

  1. The Department expects NCES to provide for immediate turn around on the May 26 comfirmatory sample from MW-406L and to fax the results to the Department upon receipt from the laboratory.

  2. The Department will look for NCES and its consultant Sanborn, Head & Associates (SHA) to discuss the analytical data and surrounding issues at a meeting on Thursday June 3 1999 at 1:00 p.m. at the Department's offices in Concord.

  3. Past occurrences of relatively low levels of VOCs in monitor well MW-405U&L and MW-406U&L have resulted in the Department requesting NCES to increase the frequency these wells are analyzed for VOCs to three times a year. This increased monitoring represented the beginning steps in assessment monitoring as required by the Groundwater Release Detection (Evn-Wm 1403.21). If the results from the April 1999 sampling round are confirmed, the Department will require NCES to develop a more aggressive and rigorous sampling program.

  4. It is the judgement of the Department that the ultimate source of the VOCs is the lined landfill however, the mode of occurrence of the VOCs in the samples prepared for analysis are uncertain (e.g. VOCs may originate from gas and gas condensate, leachate breakouts, or liner leaks). Therefore, the Department requests that within thirty (30) days from receipt of this letter, NCES submit for reveiw a corrective action plan which includes investigative and remediation approaches for each potential mode of occurrence.

  5. Please verify for the Department the date NCES received the April 1999 analytical results from SciTest Laboratory Services. The New Hampshire Code of Administration Rules (Rules) relating to Groundwater Management and Groundwater Release Detection (Env- Wm 1403.21) require that the permittee notify the Department within 10 days of receipt of such results of detection monitoring. The dates on the laboratory sheets indicate that all analysis had been completed by SciTest Laboratory Services by April 29, 1999.

The Department will look for confirmation of the meeting by NCES and its consultant Sanborn, Head & Associates. If there are any questions regarding this letter please contact Mr. John Cotton or myself at the Solid Waste Management Bureau, Waste Management Division.

Sincerely,

James W. Berg
Waste Management Specialist III
Solid Waste management Bureau


State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
6 Hazen Drive, P.O. Box 95, Concord, NH 03302-0095

August 22, 1997


Mr. Larry B. Lackey, P.E.
North Country Environmental Services, Inc.
16 State Street
Montpelier, VT 05602

SUBJECT:BETHLEHEM - NORTH COUNTRY ENVIRONMENTAL SERVICES LANDFILL: MONITORING DATA FOR DETENTION PONDS; CONSTRUCTION AND MONITORING DATA FOR MW-701; AND APRIL 1997 WATER-QUALITY MONITORING RESULTS (DES #70433)


Dear Mr. Lackey:

The Department of Environmental Services (Department) has reviewed the subject reports. Data on the detention ponds and MW-701 were received on July 23, 1997, and data on the April monitoring results were received on July 28. As you know, the April monitoring results were due June 15, over 40 days before they actually arrived. The Department reminds North Country Environmental Services (NCES) that timely submission of required documents is necessary to remain in compliance with the terms of the Groundwater Management and Release Detection Permit (Permit). Please be certain that the information arrives on time in the future.

The Department is particularly concerned about the presence of VOCs in detention ponds No. 2 and No.3, and the presence of lead and chromium in all three ponds. However, we will reserve comments until we have reviewed the July analyses. The Department anticipates receiving the July results within the next 25 days.

The analytical data for MW-701 for two sampling rounds (April and June) did not include Safe Drinking Water Act metals as requested. These analyses must be done promptly, with two analyses completed by early November. Please be advised that the Department may have additional comments following review of the July results.

The Department is concerned about the analytical results for VOCs for MW-406U and L. Sanbom, Head & Associates (SHA) suggest that the April samples for MW-406L and MW-406U may have been reversed. Perhaps there is a possibility of mislabeling those samples with samples from the 600-series wells. More important, the Department is extremely concerned by the manner in which the reported information was handled. As required by the Groundwater Protection Rules and the Permit, this matter should have been reported to the Department within 10 days of your knowledge of the results. The correct course of action was to immediately resample the appropriate wells. The decision by NCES to wait until the July sampling round was not in keeping with the manner the Department would have handled the situation if it had been properly advised of the findings. The Department insists that NCES follow the rules in the furture. Line graphs for each VOC that has been detected in MW-405U and L and MW-406U and L are to be included in the September summary.

The cover letter with the Permit Revision, dated January 3,1996, requested "that information from the material descriptions in logs of the monitoring wells in the 400 and 600 series be used to update the geologic cross sections that were included in the March 1987 report by GZA GeoEnvironmental, Inc... These updated cross sections can be included in the next annual report in September 1996." The cross sections were not included in that annual report and are to be included in the September 1997 report. The data from MW-701 shall also be used.

The existing Groundwater Management and Release Detection Permit expires on November 8, 1997. As you know, Condition 2 of that Permit requires that an application to renew the Permit be submitted 90 days prior to the expiration date. NCES' failure to meet this requirement represents an outstanding obligation as well as a permit violation. The application for permit renewal must include a thorough review of water quality conditions over the previous 5-year period. The annual September summary for this year may be incorporated in the 5-year review provided that the Department receives the application for permit renewal by September 30, 1997.

NCES presently holds NPDES Baseline lndurtrial Storm Water Permit No. NH R00A283 (not NH R004283) which expires on September 9, 1997. Under EPA rules, NCES will have to file a Notice of Intent (enclosed) for a NPDES Mulit-Sector Permit before that date. Additional information may be obtained from Thelma Hamilton (EPA, Region I Storm Water Coordinator) at (617) 565-3569 or calling the EPA Consultant at (202) 260-7786 and specifying that NCES needs copies of the general rules, rules for Sector L, and the fact sheet (all from the Federal Register).

The items in the preceding paragraphs reflect a need for NCES to become more proactive with respect to operating in compliance with the terms of the Groundwater Management and Release Detection Permit. Should you have questions, please contact me at the Department at (603) 271-2925.

Sincerely,

John Cotton, Hydrogeologist
Waste Management Division

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