SDMS DocID 7811

TABLE

ACTION-SPECIFIC ARABS

ALTERNATIVE 2 Limited action natural attenuationbiorestoration and ground water monitoring 7i

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

G r o u n d Water

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

We 604 Abandonment of Wells

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to monitoring at hazardous waste facilities

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Imposes requirements for closure of wells

Action to be Taken to Applicable or Attain Requirement Relevant and Appropriate

Groundwater monitoring must Relevant and appropriate comp ly wi th subs tan t i ve requirements of Subtitle C regulations

Management of hazardous waste as See following section by section part of the CERCLA response must analysis comply with the substantive standards of these rules

Implement a ground water Relevant and appropriate m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate Relevant and appropriate implement ground water monitoring as specified If ground water wells are Applicable abandoned requirements for closure must be followed

RMWV88-041U9FS1CTBL Uun 28 1993IPge 1 0(8

TABLE J bull

ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS

RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCR

Applicable or Relevant and Appropriate

Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMWa8-04U1laquotFS1CTBL Uon 28 1B83IPlaquoolaquo1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extrs ion with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements

Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Relevant and appropriate Waste facilities implement ground water monitoring

as specified

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility

Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must Include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facil ity must comply with

requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119FS1CTBI IJun 2B 19931 Praquo0lt 2 of 8

1 laquo

TABLE

ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWaS-041U9FS1CTBl |Jun 28 19931 Plaquogo 3 o( 8

TABLE shy

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Plaquoolaquo 1 el B

TABLE

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements

Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure

Applicable to the operation of a hazardous waste treatment facility

See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1993) Pg 2 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extrs ion with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements

Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Relevant and appropriate Waste facilities implement ground water monitoring

as specified

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility

Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must Include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facil ity must comply with

requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119FS1CTBI IJun 2B 19931 Praquo0lt 2 of 8

1 laquo

TABLE

ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWaS-041U9FS1CTBl |Jun 28 19931 Plaquogo 3 o( 8

TABLE shy

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Plaquoolaquo 1 el B

TABLE

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements

Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure

Applicable to the operation of a hazardous waste treatment facility

See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1993) Pg 2 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

1 laquo

TABLE

ACTION-SPECIFIC ARARS

Alternative 3 Limited action landfill cover natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWaS-041U9FS1CTBl |Jun 28 19931 Plaquogo 3 o( 8

TABLE shy

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Plaquoolaquo 1 el B

TABLE

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements

Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure

Applicable to the operation of a hazardous waste treatment facility

See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1993) Pg 2 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE shy

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Plaquoolaquo 1 el B

TABLE

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements

Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure

Applicable to the operation of a hazardous waste treatment facility

See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1993) Pg 2 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements

Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure

Applicable to the operation of a hazardous waste treatment facility

See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1993) Pg 2 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARABS

Alternative 4 Limited action landfill cover enhanced in-situ biorestoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Page 3 ol 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE _ f]

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System

STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance

Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 18931 Praquoolaquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Action to be Taken to Applicable or

Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements t Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements

Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Wheremdashrelevant^andmdashappropriate Waste facilities Implement ground water monitoring

as specified-laquo r^tt m- r-j

Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Applicable to operation of a Waste closure of hazardous waste treatment facility requirements not with procedural hazardous waste facility relevant

requirements and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to operation of a Waste vVA IAlaquo hazardous waste treatment facility hazardous waste treatment facility ^bullbullyVv Air RSA Cht l 25-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air J SL Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs

Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable Rules Env-A 1002 must include precautions to prevent abate and remediation

control fugitive dust emissions

yAir J 0 Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable

Requirements emitting regulated substances facility must comply with requirements of section

S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water amp- Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMWA88-04M19FS1CTBL IJun 28 19931 Praquofllaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 5 Limited action landfill cover enhanced in-situ chemical restoration natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d ] Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

ISA 4 8 5 - A 1 2 Enforcement of classification J

485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04119FS1CTBL Uun 28 19931 Plaquofllaquo 3 ot 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

5 2shy

TABLE i~ (~

ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation ooff hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate -las effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RWW88-04119FS1CTBL (Jun 28 18931 Plaquo00 1 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to Attain Requirement

Construct any hazardous waste treatment facility In accordance with design requirements Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state In case of warning status No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified faci l i ty must comply with requirements of section Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL (Jun 28 19931 PlaquoBlaquo 2 o 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 6 Limited action landfill cover slurry wall (partial or perimeter) natural attenuationbiorestoration groundwater extraction (with on-site and off-site treatment) ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-04U19FS1CTBL IJun 28 19931 Piga 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE r ^

ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off -site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-1 2R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate n lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9f S1CTBL IJun 28 19931 Pge 1 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE ACTION-SPECIFIC ARARS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must Include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL [Jun 28 19931 Praquoglaquo 2 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE ACTION-SPECIFIC ARABS

Alternative 7 Limited action landfill cover groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMWV88-04HI9fS1CTBL Uun 28 19931 Page 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

Fl ^r cfv-lt bull=bull

if TABLE I-

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative) i

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates In lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-04U19FS1CTBL Pun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Action to be Taken to Applicable or Medium Potential Requirement Synopsis of Requirement Attain Requirement Relevant and Appropriate

Hazardous Env-Wm 70209 General Design All hazardous waste and transfer facilities are Construct any hazardous waste Applicable Waste Requirements to meet specified design requirements treatment facility in accordance with

design requirements Hazardous Env-Wm 70211 Ground Water Monitoring Specified types of hazardous waste treatment Implement a ground water Relevant and appropriate Waste facilities must monitor migration of hazardous m o n i t o r i n g p r o g r a m p e r

waste as specified requirements Hazardous Env-Wm 70212 Other Monitoring Requires groundwater monitoring by certain Where relevant and appropriate Waste facilities implement ground water monitoring

as specified Hazardous Env-Wm 70802 Operation Requirements Variety of requirements relating to operation and Comply with substantive specified Waste closure of hazardous waste treatment facility requirements not with procedural Applicable to operation of a

requirements hazardous waste facility relevant and appropriate as to closure

Hazardous Env-Wm 70803 Technical Requirements Imposes various requirements for operation of a Comply with specified requirements Applicable to the operation of a Waste hazardous waste treatment facility hazardous waste treatment facility Air RSA Ch 125-C Air Pollution Control NH Air pollution controls as specified below See below See below

Admin Rules Env-A 100-1300 as specified below

Air Env-A 50502(e) Emergency Procedures Imposes obligations on sources of air pollution in Comply with directions of state in Applicable cases of pollution emergency case of warning status

Air Env-A 902 Malfunctions of Air Pollution Provides limited relief from other requirements in No action required Provides relief Relevant and appropriate Control Equipment case of malfunction Notification requirements from other ARARs

are not ARARs Air Fugitive Dust Emission Control NH Admin Activities such as construction and excavation Maintain dust control during site Applicable

Rules Env-A 1002 must include precautions to prevent abate and remediation control fugitive dust emissions

Air Env-A 1305 Impact Analysis and Permit Requires air quality impact analysis of devices Discharge from any new or modified Applicable Requirements emitting regulated substances facility must comply with

requirements of section S u r f a c e R S A 4 8 5 - A 8 S u r f a c e W a t e r Prohibits disposal to Class B waters unless Surface water discharge from any Applicable Water Classifications treated to prevent lowering below classification response action must comply with

these requirements

RMW88-04119F61CTBU |Jun 28 19931 Plaquoglaquo 2 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 8 Limited action landfill cover slurry wall (partial or perimeter) groundwater extraction (with on-site and off-site treatment) natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A 13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wflpoundr 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within dlscharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater -

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives Involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and-appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL IJun 28 1B93I Pglt 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

2shy

TABLED

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below

Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable If treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

RMW88-041U9U=S1CTBL IJun 28 19931 Page 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70209 General Design Requirements

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 125-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e Water Classifications

Synopsis of Requirement

All hazardous waste and transfer facilities are to meet specified design requirements

A

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified

Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility Air pollution controls as specified below

Imposes obligations on sources of air pollution in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs

Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Construct any hazardous waste treatment facility in accordance with design requirements

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements

Where relevant and appropriate implement ground water monitoring as specified Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facility must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or Relevant and Appropriate

Applicable

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility See below

Applicable

Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-04119FS1CTBL IJun 28 19931 Ptga 2 of B

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS Alternative 9 Complete excavation removal and off-site disposal of landfilled waste natural attenuationbiorestoration ground water extraction

with treatment from well B-12R and ground water monitoring

(NA = requirement not triggered by this alternative)

Medium

G r o u n d Water S u r f a c e Water

G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 4 8 5 - A 1 2 EnforcementClassification

RSA 485-A13 Permit for discharge

of

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria

Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradatlon Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater

This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to

Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards

Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit

Remedial measures involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements

If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or Relevant and Appropriate

Applicable

Applicable

Applicable if treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Pgd 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

- n IATABLE

ACTION-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

G r o u n d Water

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Potential Requirement

FEDERAL REQUIREMENTS

Hazardous Waste Regulations RCRA Subtitle C 40 CFR Part 264

Discharge of Treatment System Effluent 40 CFR 122 40 CFR 125 40 CFR 131 and 40 CFR 136 National Pollutant Discharge Elimination System STATE REQUIREMENTS RSA Ch 147-A New Hampshire Hazardous Waste Management Act and Hazardous Waste Rules Env-Wm Chapters 100-1000 Specific requirements detailed below Env-Wm 35309 and 35310 Siting requirements for hazardous waste facilities and variances

Env-Wm 70208 Environmental and Health Requirements

Env-Wm 70209 General Design Requirements

Synopsis of Requirement

RCRA Subtitle C establishes standards applicable to treatment storage transport and disposal of hazardous waste and the closure of hazardous waste facilities

Imposes limitations on discharge to surface water

Standards for management of hazardous waste and closure of hazardous waste facilities Operates in lieu of Federal RCRA Subtitle C requirements

Restrictions on siting of hazardous waste facilities

Requires operator of a hazardous waste facility to meet certain standards for surface water ground water air

All hazardous waste and transfer facilities are to meet specified design requirements

Action to be Taken to Attain Requirement

Management of hazardous wastes as part of the CERCLA response must comply with substantive requirements of Subtitle C regulations

Discharge of treated ground water and treated leachate to surface water must comply with these requirements

Management of hazardous waste as part of the CERCLA response must comply with the substantive standards of these rules

Any new hazardous waste facility must comply with the siting requirements or with criteria for a variance Operation of hazardous waste facility must meet relevant standards and criteria NOTE worker protection requirements are not ARAR but OSHA and state law approved under OSHA must be complied with per s 300150(e) of NCP Construct any hazardous waste treatment facility in accordance with design requirements

Applicable or Relevant and Appropriate

Relevant and appropriate Has effect through state hazardous waste requirements which operate in lieu of direct federal regulation See discussion of those requirements below Applicable if treatment effluent discharged to surface water

See following section by section analysis

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBl |Jun 28 19931 Plaquo0laquo 1 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TABLE

ACTION-SPECIFIC ARARS

Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

Hazardous Waste

Hazardous Waste

Hazardous Waste

Hazardous Waste

Air

Air

Air

Air

Air

S u r f a c e Water

Potential Requirement

Env-Wm 70211 Ground Water Monitoring

Env-Wm 70212 Other Monitoring

Env-Wm 70802 Operation Requirements

Env-Wm 70803 Technical Requirements

RSA Ch 1 25-C Air Pollution Control NH Admin Rules Env-A 100-1300 as specified below

Env-A 50502(e) Emergency Procedures

Env-A 902 Malfunctions of Air Pollution Control Equipment

Fugitive Dust Emission Control NH Admin Rules Env-A 1002

Env-A 1305 Impact Analysis and Permit Requirements

R S A 4 8 5 - A 8 S u r f a c e W a t e r Classifications

Synopsis of Requirement

Specified types of hazardous waste treatment facilities must monitor migration of hazardous waste as specified Requires groundwater monitoring by certain facilities

Variety of requirements relating to operation and closure of hazardous waste treatment facility

Imposes various requirements for operation of a hazardous waste treatment facility

Air pollution controls as specified below

Imposes obligations on sources of air pollutions in cases of pollution emergency

Provides limited relief from other requirements in case of malfunction Notification requirements are not ARARs Activities such as construction and excavation must include precautions to prevent abate and control fugitive dust emissions

Requires air quality Impact analysis of devices emitting regulated substances

Prohibits disposal to Class B waters unless treated to prevent lowering below classification

Action to be Taken to

Attain Requirement

Implement a ground water m o n i t o r i n g p r o g r a m p e r requirements Where relevant and appropriate implement ground water monitoring as specified

Comply with substantive specified requirements not with procedural requirements Comply with specified requirements

See below

Comply with directions of state in case of warning status

No action required Provides relief from other ARARs

Maintain dust control during site remediation

Discharge from any new or modified facil ity must comply with requirements of section

Surface water discharge from any response action must comply with these requirements

Applicable or

Relevant and Appropriate

Relevant and appropriate

Applicable to operation of a hazardous waste facility relevant and appropriate as to closure Applicable to the operation of a hazardous waste treatment facility

See below

Applicable NOTE Other requirements applicable to large sources do not appear applicable to any alternative here Relevant and appropriate

Applicable

Applicable

Applicable

RMW88-041M9FS1CTBL Uun 28 19931 Plaquoolaquo 2 ol 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8

TAFIE

ACTON-SPECIFIC ARARS Alternative 10 Limited action landfill cover compete excavation and on-site reconsolidation of landfilled waste natural

attenuationbiorestoration grounde water extraction with treatment from well B-12R and ground water monitoring

Medium

G r o u n d Water S u r f a c e Water G r o u n d W a t e r S u r f a c e Water

G r o u n d Water

G r o u n d Water

G r o u n d Water

S u r f a c e Water

Potential Requirement

RSA 485 -A 12 Enforcement of Classification

RSA 485-A13 Permit for discharge

Env-Ws 41007 41009 41010 Prohibited Discharge Groundwater Discharge Zone Groundwater Discharge Permit Compliance Criteria Env-Wm 403 Industrial and Municipal Wastewater Discharge Permits

We 604 Abandonment of Wells

Env-Ws Part 437 Antidegradation Policy

Synopsis of Requirement

Any discharge to ground water or surface water that lowers the quality of the water below its classification is prohibited

Discharge or disposal must comply with effluent limitations

Prohibits discharges to ground water without use of BAT requires controls on use of groundwater within discharg zone sets limits on discharges to groundwater This regulation requires a permit for discharge of wastewater

Imposes requirements for closure of wells

Requires existing beneficial uses and the water quality to sustain existing beneficial uses to be maintained and protected Limited degradation as a result of insignificant discharges may be allowed

Action to be Taken to Attain Requirement

Remedial alternatives involving the discharge to ground water or surface water must comply with these standards Remedial measures involving discharges to ground or surface water must comply with these standards On-site discharges do not require permit Remedial measures Involving discharges to ground water must comply with this regulation

Discharge of treated ground water and disposal of treated leachate must comply with these requirements If ground water wells are abandoned requirements for closure must be followed Discharge to surface water must comply with this requirement

Applicable or

Relevant and Appropriate

Applicable

Applicable

Applicable If treatment effluent discharged to ground water

Relevant and appropriate

Applicable

Applicable

RMW88-(Mnl8FS1CTBl Uun 28 19931 Plaquoolaquo 3 of 8