214 Carnegie Center Suite 103 Princeton, NJ 08540
Community Involvement Plan Chlor-Alkali Facility (Former) Superfund Site
Berlin, New Hampshire
July 31, 2015
Prepared for Georgia-Pacific Consumer Products LP and Fort James LLC 133 Peachtree Street Atlanta, Georgia 30303
K/J Project No. 1540002.00
Page i Table of Contents
List of Figures...... i List of Appendices ...... i
Section 1: Introduction ...... 1 1.1 Purpose of This CIP ...... 1 1.2 CIP Overview ...... 2
Section 2: Site Background ...... 3 2.1 Site Description ...... 3 2.2 Site History ...... 3 2.3 Previous Investigations ...... 4
Section 3: Community Background ...... 6 3.1 City of Berlin Community Profile ...... 6 3.2 City of Berlin Community Demographics ...... 7 3.3 Past Community Involvement Efforts ...... 7
Section 4: Community Engagement and the Superfund Process ...... 9
Section 5: Community Involvement Goals and Activities ...... 10 5.1 Specific Community Involvement Activities ...... 10 References ...... 12
List of Figures
1 The Superfund Process 2 Site Locus
List of Appendices
A Site Information Repository and Administrative Record B List of Contacts
Page 1
Section 1: Introduction
Georgia-Pacific Consumer Products LP (GP) and Kennedy/Jenks Consultants, Inc. (Kennedy/Jenks) prepared this Community Involvement Plan (CIP) for the Chlor-Alkali Facility (Former) Superfund Site (the Site) in Berlin, New Hampshire. This CIP describes how the community’s concerns and information needs are considered as Site activities progress.
1.1 Purpose of This CIP This CIP was prepared to support environmental investigation and cleanup activities at the Site. It describes the plan to address community interest and concerns and to keep residents informed about decisions regarding the Site cleanup. The following Site milestones provide an opportunity for community involvement:
1. Supplemental Remedial Investigation (SRI). Additional Site data will be collected to complete the remedial investigation and feasibility study (RI/FS). These data will then be used to evaluate and select a remedy and meet requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP).
2. Risk Assessment. If, based on data collected during the SRI, GP believes it appropriate to update risk assessments prepared for the Site, it will notify the United States Environmental Protection Agency (EPA) and will prepare work plans outlining the methods and deliverables.
3. Feasibility Study. GP will develop a range of alternatives to address Site conditions that may pose a risk, which will be used by EPA to determine a final cleanup plan for the Site.
This CIP is a working document that will evolve as the investigation and cleanup process continues and input is received from the community. It is intended to be flexible, adaptable and used as a guideline for communication with the public.
If there are comments or questions regarding this CIP, please contact:
United States Environmental Protection Agency
Sarah White [email protected] Work: 617-918-1026 Office of Site Remediation & Restoration (OSRR) 5 Post Office Square Mail Code: ORA20-1 Boston, MA 02109-3912 Georgia-Pacific Consumer Products LP
Page 2
Gail Smith [email protected] Work: 404-652-4738 133 Peachtree Street NE Atlanta, GA 30303-1847
1.2 CIP Overview The remainder of this CIP contains the following sections:
• Section 2.0 Site Background: Provides background information about the Site’s location and history
• Section 3.0 Community Background: Provides community demographics and summarizes the community’s history
• Section 4.0 Community Engagement and the Superfund Process: Gives an overview of the step-by-step process the EPA follows to identify the best way to clean up a site and lists opportunities for community involvement throughout the process
• Section 5.0 Community Involvement Goals and Activities: Describes the plans and timeline for conducting Site-specific activities to keep residents and local officials informed and involved during Site activities.
Figures are presented to support the text. Appendix A presents the Site information repository and administrative record location. Appendix B provides a list of contacts.
Page 3
Section 2: Site Background
2.1 Site Description The Site occupies approximately 42 acres along the eastern bank of the Androscoggin River, in the City of Berlin, Coos County, New Hampshire (Figure 2). The main part of the Site, which is referred to as the cell house parcel (CHP), is a 4.6-acre parcel with a closed landfill that contains debris and remnants of a former chlor-alkali facility/chemical plant that operated primarily in that same location.
The Site consists of three separate operable units (OUs) as defined by EPA:
1. OU-1 is the 4.6-acre CHP. In 1999, Crown Paper Company, the facility’s owner at that time, conducted closure activities in the CHP under the oversight of New Hampshire Department of Environmental Services (NHDES). Buildings remaining in the CHP were demolished and a landfill was built within the CHP for debris. A slurry wall was constructed on the eastern and southern sides of the landfill and a cap was placed over the debris. OU-1 is limited to the area that encompasses the CHP, comprising Lot No. 262 on Berlin Tax Assessor Map No. 128 (Nobis 2014).
2. OU-2 consists of 37.4 acres located to the south and east of the CHP. This area comprises a portion of Lot No. 55 on Berlin Tax Assessor Map No. 129 (Nobis 2014).
3. OU-3 consists of shallow and deep groundwater in OUs1 and 2 and surface water and sediments of the Androscoggin River adjacent to OUs 1 and 2 between Sawmill and Riverside Dams, as defined in the 2014 Remedial Investigation Report (RIR) (Nobis 2014).
2.2 Site History The former chlor-alkali chemical plant was built during the late 1890s and was operated through much of the 20th century by the Brown Company. Electrolytic diaphragm cells were installed in cell houses to produce chlorine and sodium hydroxide for pulp and paper manufacturing. The chemical plant also produced other chemicals including chloroform, carbon tetrachloride, carbon disulfide and calcium arsenate. The chemical plant, rail yard and other structures were gradually dismantled over a number of years with demolition debris often consolidated into former building structures and left on Site. The CHP landfill was closed in 1999 with the installation of a low- permeability cap covered by 2 feet of wood chips. A slurry wall was added to keep groundwater from migrating into the capped landfill area.
In 1999, mercury was discovered in/near bedrock fractures and depressions in the riverbed adjacent to the CHP. The NHDES completed several removals of mercury and mercury- impacted debris from the Androscoggin River together with the then-owners of the former chemical plant and surrounding pulp and paper mill property. Reportedly, from 1999 to 2006,
Page 4
14.5 pounds of elemental mercury or mercury amalgam (i.e., approximately 1 pint) was removed from the Androscoggin River adjacent to the Site.
At the request of NHDES, the Site was proposed for listing on the National Priorities List (NPL) on April 27, 2005; EPA placed the Site on the NPL on September 14, 2005. In 2009, EPA began an RI/FS at the Site. After EPA identified GP as a potentially responsible party for the Site based on GP’s relationship with the one of the prior owners, GP agreed to take over performance of the SRI/FS.
2.3 Previous Investigations After the landfill was closed in 1999, the following environmental investigations occurred at the Site:
• April-July 1999: Two Site investigations were conducted on behalf of Pulp and Paper of America, the Site owner at the time. Investigation activities included collection of surface and subsurface soil samples, overburden and bedrock groundwater monitoring well installations and sampling, and surface water and sediment sampling.
• 1999: Following the two investigations by Pulp and Paper of America, and as part of the closure plan for the former cell house area, one additional overburden and two additional shallow bedrock monitoring wells were installed and sampled.
• 1999-2000: A Conceptual Design and Closure Plan for the CHP was prepared, and groundwater sampling, sampling of retaining wall discharge pipes, and surface water sampling of the Androscoggin River was conducted in March and June 2000.
• 2002-2003: The United States Geological Survey (USGS) performed investigation activities in the vicinity of the CHP, including bedrock geology mapping, geophysical surveying, and extended monitoring of groundwater and surface water elevations.
• 2003-2004: NHDES performed an investigation to identify potential mercury source(s) and migration pathways. The investigation consisted of soil borings, installation of overburden and bedrock monitoring wells, hydrogeologic testing of overburden and bedrock monitoring wells, and groundwater sample collection.
• 2005: EPA directed the preparation of a Combined Preliminary Assessment/Site Inspection (PA/SI) for the Site. PA/SI activities included collection of subsurface soil samples, installation and sampling of overburden and bedrock monitoring wells, and mercury removal along the Androscoggin riverbank abutting the CHP.
• 2008-2012: EPA directed the RI of the CHP and surrounding areas, including a 24-mile Androscoggin River study area. Samples of soil, building debris, air, groundwater, sediment, surface water and biota (both terrestrial and aquatic) were collected and analyzed (Nobis 2014). Test pits in the CHP were also excavated.
Page 5
As a follow-up to previous RI activities, supplemental activities described in SRI Work Plans will provide additional data and information to further inform remedial decisions at the Site. Activities include, but are not limited to, the following:
• Reviewing existing Site information
• Identifying data gaps
• Performing field sampling and laboratory analyses
• Performing investigation activities
• Reviewing available federal and state applicable or relevant and appropriate environmental statutes and promulgated regulations.
Page 6
Section 3: Community Background
The following section describes the city of Berlin, New Hampshire, and the history of community involvement with the Site.
3.1 City of Berlin Community Profile The city of Berlin encompasses 61.5 square miles along the Androscoggin River in Coos County, New Hampshire. The city is a popular tourist destination known for its history, skiing and outdoor sports. Situated in a heavily forested region, the community developed early into a center for logging and wood industries. Falls on the Androscoggin River provided water power for sawmills. In 1826, a road was built to Gorham. In 1851 the St. Lawrence & Atlantic Railroad entered Berlin, connecting it to other markets. Acquiring water, timber and rail rights in the early 1850s, the H. Winslow & Company built a large sawmill at the head of "Berlin Falls." In 1868, William Wentworth Brown and Lewis T. Brown bought a controlling interest in the business and changed its name to the Berlin Mills Company.
By 1885, the mill town was home to several pulp and paper mills, including the Riverside Mill, Forest Fibre Company and White Mountain Pulp & Paper Company. Because of the need for workers in the mills, immigrants arrived from Russia, Norway, Italy, Sweden, Ireland and Germany. Many others were French Canadians from nearby Quebec. In 1897, Berlin was incorporated as a city, the northernmost in the state.
Berlin's main industry in the early 20th century was pulp and paper manufacturing, which has been in a long decline since that time. As jobs left the area, the population decreased and is now about half its peak of more than 20,000 in the 1930 census. In 1917, the Berlin Mills Company was renamed the Brown Company. A short time after the Great Depression, the Brown Company went into receivership. Surviving with government help, it was bought and sold several times after World War II.
In 2001, American Tissue, which owned the Berlin mill, filed for bankruptcy. Its facilities were purchased in 2002 by Fraser Papers of Canada. In March 2006, Fraser Papers announced the closing of Berlin's pulp mill and the subsequent loss of 250 jobs.
On October 3, 2006, the North American Dismantling Corporation of Michigan announced that it had bought the 121-acre former pulp mill site and would spend a year demolishing structures on the property to enable redevelopment. Laidlaw Energy LLC has since purchased a portion of the property, including a large recovery boiler, which it converted into a 66-megawatt biomass plant in 2010-2011. The plant is currently operated by Burgess Biopower.
Recent economic development in the Berlin community has come from the correctional industry. The 750-bed Northern New Hampshire Correctional Facility was built in 1999 and employs approximately 200 people. In 2012, the Federal Bureau of Prisons opened a 1,200-bed medium security facility, which employs approximately 350 people (www.wikipedia.org).
Page 7
3.2 City of Berlin Community Demographics Based on 2013 U.S. Census data, Berlin has a population of 9,836. The population of Berlin is predominantly white non-Hispanic (95.5%) followed by Hispanic or Latino origin (1.5%). Ancestries in the town include French Canadian and French (66%), followed by United States or American (7%), Irish (7%) and English (6%). The median resident age in the town is 45 years. Approximately 82 percent of households are family households and 82 percent of the population has a high school education or higher (www.city-data.com and www.berlinnh.gov).
3.3 Past Community Involvement Efforts EPA has participated in a number of community events designed to educate the public about the Superfund process and progress at the Site. The events conducted include:
• March 2006 - EPA issued a Community Update.
• May 25, 2006 - EPA and NHDES gave a presentation to the community in Berlin City Hall regarding the Site and introduction to Superfund.
• February 2007 - the Agency for Toxic Substances and Disease Registry (ATSDR) released a Public Health Assessment.
o ATSDR held a training session for local health care professionals, attended by 12 physicians from the Androscoggin Valley Hospital.
o A second meeting was held by ATSDR and EPA for the general public in Berlin City Hall.
o Comments from the two presentations found that the residents of Berlin were aware of issues surrounding the Site, were satisfied that the Site would be cleaned, and that the Androscoggin River was catch-and-release due to contaminants in the fish (signs are posted).
• December 11, 2007 - EPA began a four-part series of meetings to discuss the reuse potential for the 4.6-acre CHP that was the focus of the effort at that time.
• January 22, 2008 – Reuse meeting #2.
• March 5, 2008 – Reuse meeting #3.
• July 2, 2008 – Reuse meeting #4.
• December 1, 2008 – Release of Planning for the Future: Reuse Planning Report for the Cell House Property of the Chlor-Alkali Superfund Site. E2 Inc., a collaborative product by EPA, NHDES, and the residents and City officials of the City of Berlin.
Page 8
• April 20, 2009 - EPA updated the Berlin City Council regarding progress at the Site and plans for the future.
• October 9, 2009 - EPA updated City of Berlin official with respect to the Site investigation.
• June 18, 2011 - EPA had a booth at the Androscoggin River Days, a public event by the Androscoggin River Watershed Alliance. The Site Manager, Darryl Luce, and Community Involvement Coordinator, Sarah White, answered questions about the progress of the investigation at the Site.
• May 29, 2014 - EPA presented and explained the results of the Remedial Investigation in a public meeting at City Hall in Berlin.
Berlin officials have expressed a concern regarding on-going education to prevent the eating of fish from the river. The river contains small-mouthed bass, a popular sport fish. EPA has regularly checked both stream-side postings and the New Hampshire Department of Fish and Game regulations to ensure that the public is notified of the contamination in the fish. The EPA Site Manager has questioned individual fishermen on the river about the catch-and-release requirements and met with the City Manager in the next downstream community, Gorham, New Hampshire, to provide updates.
An information repository has been established for the Site at Berlin Public Library, located at 270 Main Street. The repository contains electronic copies of Site-related documents such as technical reports, sampling results and other information. Documents are available for public viewing and copying during the library’s hours of operation (Appendix A).
Page 9
Section 4: Community Engagement and the Superfund Process
EPA follows a step-by-step process to identify an approach for Site cleanup that is protective of human health and the environment. The Superfund program encourages active dialogue between communities affected and the agencies responsible for carrying out or overseeing cleanup actions. EPA considers community involvement to be an important part of the Superfund program and opportunities for community involvement occur throughout the process (See Figure 1).
Current Step
Figure 1. The Superfund Process (http://www.epa.gov/superfund/community/process.htm)
Page 10
Section 5: Community Involvement Goals and Activities
The objective of a community involvement program is to engage the public in activities and decisions related to Site investigation and cleanup activities. To be effective, the program must meet the community’s need to know, give information in a timely manner and accommodate their willingness to participate. EPA regulations require that certain community engagement activities be conducted at milestones during the investigation and cleanup process. Although the City of Berlin is the primary target, the next downstream community, Gorham, New Hampshire, will also be notified and updated as to Site progress. To keep the community informed during the Site cleanup process, the following objectives have been established:
• Encourage residents to get involved
• Listen to community concerns and respond accordingly
• Keep the community informed of ongoing Site activities
• Adjust planned activities, where warranted, based on community input
• Update the information repository regularly
• Hold public meetings, when necessary, within the community to give residents the opportunity to attend.
5.1 Specific Community Involvement Activities This section outlines activities that will be conducted to address community concerns and questions. Through these activities, the goal will be to inform, involve and engage the community during site cleanup efforts and decisions.
• Maintain point of contact. Sarah White is the primary liaison between the EPA and the Berlin community. Ms. White serves as the point of contact for community members and media and fields general questions about the Site. For technical issues, Ms. White coordinates with EPA’s project manager Darryl Luce. EPA will notify the community if the contacts change.
• Provide Site information on the Internet. Information on the Site is provided on the following EPA website and will be updated as needed: http://www.epa.gov/region1/superfund/sites/chloralkali.
• Establish and maintain a site-specific information repository. The EPA has set up an information repository at the Berlin Public Library, located at 270 Main Street. The repository is a collection of Site information available for public reading and printing/photocopying.
Page 11
• Establish and maintain the Administrative Record. A copy of the Administrative Record for the Site can be found at Berlin Public Library. The Administrative Record will be updated as necessary. The Administrative Record provides documents EPA relied on, or considered, to reach cleanup decisions.
• Hold public meetings. A public meeting provides an opportunity to present specific information and a proposed course of action to the community. EPA and GP representatives will be available to provide information and answer questions. A public meeting is an opportunity to exchange information. Public meetings may be held at various times throughout the investigation and cleanup process. Meeting schedules are flexible to account for technical milestones and public interest.
• Write and distribute news releases and public notices. EPA will prepare and release announcements to local media, as needed, to share information about events such as significant Site investigation findings, completion of major milestones, significant scheduling information and other pertinent Site-related information. EPA typically publishes news releases and public notices to announce major events such as comment periods, public meetings and major milestones. Copies of the news releases and public notices will also be available in the information repository.
Page 12
References
Nobis Engineering, Inc. 2014. Remedial Investigation Chlor-Alkali Facility (Former) Superfund Site, Berlin, New Hampshire Remedial Investigation/Feasibility Study, Volumes I-III.
³
SITE LOCATION Path:P:\Princeton\2015\1540002.00_Chlor-Alkali\GIS\Maps\SRI work Plan\1540002_DRAFT_Site Locus June 2015.mxd
0 1,000 2,000 4,000 Kennedy/Jenks Consultants Chlor-Alkali Facility (Former) Superfund Site Feet Berlin, New Hampshire
Site Locus Community Involvement Plan Source: USGS 7.5 Minute Topographic Quadrangle obtained from NH GRANIT on-line K/J 1540002.00 GIS database. "Berlin, NH" Quadrangle is July 2015 dated 1970 (revised 1989). MAP LOCATION Figure 2
Appendix A – Site Information Repository and Administrative Record
The information repository and administrative record are located at:
Berlin Public Library 270 Main Street Berlin, NH 03570 Phone: 603-752-5210 Fax: 603-752-8568
Denise Jensen, Head Librarian
Library Hours: Mon., Tues., Thurs. and Fri. 10 a.m. – 6 p.m; Wed. 12 p.m. – 7 p.m. Sat. and Sun. Closed
Site-related documents are also provided at: http://www.epa.gov/region1/superfund/sites/chloralkali
Appendix B – List of Contacts
U.S. EPA Region 1 Project Contact Darryl Luce, Ph.D. Remedial Project Manager US Environmental Protection Agency 5 Post Office Square, Suite 100, OSRR 07-1, Boston, MA 02109-3912 Phone: 617-918-1336 [email protected]
New Hampshire Department of Environmental Services Project Contact Andrew Hoffman, P.E. New Hampshire Department of Environmental Services Waste Management Division Hazardous Waste Remediation Bureau 29 Hazen Drive, P.O. Box 95 Concord, NH 03302 Phone: 603 271-6778 [email protected]
Federally Elected Officials Senator Kelly Ayotte 1200 Elm Street, Suite 2 Manchester, NH 03101-2503 Phone: 603-622-7979
144 Russell Senate Office Building Washington, D.C. 20510 Phone: 202-224-3324
Senator Jeanne Shaheen 1589 Elm Street, Suite 3 Manchester, NH 03101 Phone: 603-647-7500
506 Hart Senate Office Building Washington, DC 20510 Phone: 202-224-2841
Representative Frank Guinta 33 Lowell Street Manchester, NH 03101 Phone: 603-641-9536
326 Cannon House Office Building Washington, DC 20515 Phone: 202-225-5456
State Elected Official Governor Maggie Hassan State House 107 North Main Street Concord, NH 03301 Phone: 603-271-2121
Local Officials Coos County Clerk Rick Samson 804 Piper Hill Road Stewartstown, NH 03576 [email protected] Phone: 603-246-3570
City of Berlin Mayor Paul Grenier 168 Main Street Berlin, NH 03570 Phone: 603-752-4693
City Clerk Debra Patrick 168 Main Street Berlin, NH 03570 Phone: 603-752-2340
City Manager James Wheeler 168 Main Street Berlin, NH 03570 Phone: 603-752-7532
Community Development Director Pamela Laflamme 168 Main Street Berlin, NH 03570 Phone: 603-752-8587