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' 3>, *L Records Center SITE: FREAK: U>_£ SDMS DocID OTHER:. COMMUNITY RELATIONS PLAN SACO MUNICIPAL LANDFILL SITE SAGO, MAINE U.S. ENVIRONMENTAL PROTECTION AGENCY JANUARY 1996 Prepared By: Ed Hathaway EPA Project Manager Sarah White Community Relations Coordinator &EPA New England
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Page 1: COMMUNITY RELATIONS PLAN · 2020-05-04 · COMMUNITY RELATIONS PLAN- SAGO MUNICIPAL LANDFILL. Introduction: Superfund sites suc ash Saco Municipal Landfill, pose not only an environmental

' 3>, *L

Records Center SITE: FREAK: U>_£ SDMS DocID

OTHER:.

COMMUNITY RELATIONS PLAN

SACO MUNICIPAL LANDFILL SITE SAGO, MAINE

U.S. ENVIRONMENTAL PROTECTION AGENCY

JANUARY 1996

Prepared By:

Ed Hathaway EPA Project Manager

Sarah White Community Relations Coordinator

&EPA New England

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COMMUNITY RELATIONS PLAN

SACO MUNICIPAL LANDFILL SITE SAGO, MAINE

U.S. ENVIRONMENTAL PROTECTION AGENCY

JANUARY 1996

Prepared By:

Ed Hathaway ~ EPA Project Manager

Sarah White Community Relations Coordinator

&EPA New England

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COMMUNITY RELATIONS PLAN- SAGO MUNICIPAL LANDFILL

Introduction:

Superfund sites such as Saco Municipal Landfill, pose not only an environmental threat but threaten the health and well being of area residents. By definition NPL sites are among those identified by EPA as the most contaminated sites in the country. It is extremely important therefore that the public be kept both informed and involved in activities at the site. Public participation is a critical element in the Superfund process.

Overview of the Community Relations Plan:

This plan addresses community issues and concerns regarding field activities at the Saco Municipal Landfill in Saco, Maine. It also identifies ways in which area residents can best be kept informed about activities at the site. The information presented in this plan reflects feedback EPA received from Saco residents, community leaders and town officials and will focus on those issues raised.

The community relations plan is a comprehensive program designed to keep the community informed and involved as much as possible in the cleanup process. This is accomplished in a variety of ways including public meetings, site visits/tours, press releases, presentations, information updates and informal contacts. In educating the public about activities at the site, it is the aim of the EPA to maintain positive communication and work cooperatively with the local community toward the goal of a successfully remediated site.

The contents of this plan include:

* A description of Saco Landfill Site and a history of EPA and City of Saco activities on the site to date

* An overview of community relations plan and EPA community outreach strategies

* Community concerns about the site and assessing community concerns

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SITE DESCRIPTION

The Saco Municipal Landfill Superfund Site is located on Foss Road in Saco, York County, Maine. See figure 1 for the Site location. The property is owned by the City of Saco which operated the Site from 1963 to 1989. The City of Saco owns 90 acres of land at the Site of which approximately 30 acres make up four areas of waste disposal that are being investigated as potential sources of contamination.

The land use in the vicinity of the landfill is a mix of residential, agricultural, and industrial. The Site is located downgradient of the Saco Heath which feeds Deep Brook, a tributary of the Saco River. Three small brooks flow through the Site area. Sandy Brook flows between Areas 2 and 3; Big Ledge Brook flows along the southwestern boundary of the Site area; and an unnamed tributary to Deep Brook flows near Area 1 along the north eastern boundary of the Site area. All of these brooks flow into Deep Brook.

The Site is currently the location of the City of Saco transfer station and compost facility.

ENVIRONMENTAL ASSESSMENT HISTORY

There have been numerous field activities and investigations conducted at the Site to evaluate the type and distribution of contamination and to support closing the landfills. The information contained in the Site repository provides a discussion of the previous investigations.

See xx for a list of the previous investigations and activities at the Site.

In 1975, a water line was installed by the Biddeford and Saco Water Company along Buxton Road and along Louden Road. Many residences in the area of the Site were connected to this water supply to alleviate any potential concern with contaminated groundwater affecting residential wells in the area of the landfill.

In 1980, EPA performed a Preliminary Assessment and Site Inspection of the landfill. As a result of these activities, the Saco Landfill was proposed for inclusion on the Superfund National Priorities List. The Site was finalized on the National Priorities List on February 21, 1991.

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From September 1992 to April 1994, EPA and the United States Geological Survey (USGS) performed a series of limited investigations to better understand the extent of contamination at the landfill. Investigations of the overburden soils, shallow groundwater quality, surface water and sediment quality, and groundwater and surface water flow were performed. Two reports were prepared based upon these investigations. One is entitled, Final Site Summary Report, Saco Municipal Landfill, Saco, Maine, by Halliburton NUS Corporation, April 1994. The other is entitled, Geohydrology, Water Quality, and Conceptual Model of the Hydrologic System, Saco Landfill Area, Saco, Maine, by USGS. Both the reports are available at the information repository located at the Dyer Library on Maine Street in Saco, Maine.

In March 1995, EPA notified 14 parties of their potential liability and invited these parties to initiate discussions with EPA to perform the remaining investigations. From March 1995 to September 1995, EPA, Maine DEP, and the City of Saco held discussions that resulted in an agreement called an Administrative Order by Consent (AOC). Under the requirements of the AOC, the City of Saco, and its consultant Woodard and Curran, will perform the remaining investigation activities under the oversight of EPA and Maine DEP. A copy of the administrative order with attached statement of work can be found in the information repository.

AREAS OF CONTAMINATION

Four areas have been used for the disposal of municipal solid waste, construction debris, tannery sludge, and industrial waste during the operating history of the landfill. Three of the areas are landfills and one was a waste pile of Nike wastes.

Area 1 is a landfill that is approximately 10.3 acres in size and was operated from 1960 to 1974. Various waste materials, including municipal solid waste and tannery sludge, were disposed in Area 1 during the period of operation. To reduce groundwater contamination, Area 1 was covered with a clay cap in 1976. A second clay cap was installed in 1985 to repair the original cover.

Area 2 is a landfill that is approximately 6.4 acres in size and was operated from 1975 to 1985. Area 2 received mostly construction debris, brush, and industrial waste. Area 2 was also covered with a clay cap in 1985. Several gas vents were installed in the cap to release landfill gas. The most common landfill gasses are methane and carbon dioxide. In addition, a

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leachate recirculation system was installed in Area 2 during 1985. The recirculation system is no longer operational. The leachate collected in the leachate collection trench is currently being shipped to the City of Saco Publically Owned Treatment Works (POTW).

Area 4 is a landfill that is approximately 8.6 acres in size and was operated from 1974 to 1989. Area 4 received mostly municipal solid wastes and Area 3 served as the location for the temporary storage of Nike materials that were shipped to the Maine Energy Recovery Company.

There are several areas of Sandy Brook that have orange/rust color due to leachate entering the brook. An unnamed tributary to Deep Brook north east of area 1 has also been impacted at the Site. Groundwater is contaminated in the immediate area of the landfill. Further delineation of the groundwater is the purpose of the RI/FS.

HISTORY OP COMMUNITY INVOLVEMENT

The Site is owned by the City of Saco, Maine. As such, most previous activities at the Site were performed under the control of the City. Citizens were able to obtain information regarding the Site from Town Officials.

The first public meeting was held by EPA on December 6, 1995. EPA provided an overview of the Superfund process, an update of Site activities, and explained the opportunities for public involvement. EPA also requested that individuals complete a survey to provide EPA with a better understanding of their concerns.

On January 12, 1996, EPA notified the nine residences that were sampled as part of the residential well sampling program of the results of the analyses on their water. No residential wells were found to be impacted by the landfill.

A January 16, 1996 City Council meeting included an update of Site activities by the consultant to the City, Woodard and Curran. The results of the residential well testing were presented at the meeting.

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CHRONOLOGY OF EPA ACTIVITY AT SACO MUNICIPAL LANDFILL SITE:

Completed Activities

1980 EPA Performs preliminary site assessment i

i 1989 Saco Municipal Landfill proposed for NPL List

i 1990 Saco Landfill placed on Superfund NPL List

1992- EPA and USGS perform site investigations 1994

i

1995 (September) EPA signs AOC requiring the City of Saco to j investigate

| 1995 (November) remedial investigations and sampling activities

i

1995 (December) Public information meeting held* i

i 1995 (December) Residential Well Sampling conducted

Planned Activities

1996 (Spring) Public Meeting ii

1996 (Spring) Sampling Event

i

1996 (June) Remedial Investigation report and risk assessment j to be completed

| 1996 (September) Completion of Feasibility study and EPA

proposed plan

* EPA will schedule additional public meetings as field work progresses on site

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COMMUNITY INVOLVEMENT STRATEGIES AND PUBLIC RELATIONS ACTIVITIES

Newsletters:

In November 1995, an information update was mailed to approximately 700 area residents. The update which was prepared by Woodard and Curran with input from the EPA project manager and community relations coordinator included an overview of the Superfund process as it applies to Saco Municipal Landfill, a chronology of EPA activities at the Landfill, a description of areas under investigation, site map and a listing of the meeting date, time and place. It is the intent of the project manager to issue these updates on as activities at the site progress.

Press releases/ advisories:

Prior to the December 6, 1995 public information meeting a media advisory was issued to notify residents about the meeting via local newspapers and radio stations. As a result of the advertisement, 19 residents including the Mayor of Saco and the Chairman of the Saco Conservation Commission attended.

Public Meetings:

The EPA used various strategies in an effort to involve the community in the activities at the Landfill. A public meeting was held on December 6, 1995 at the Saco Middle School. The focus of the meeting was to orient residents to the superfund process, update them on past and current activities at the Landfill and answer any questions and concerns they may have regarding the site.

The EPA Project Manager plans to schedule additional public meetings to update the public as activities unfold at the Landfill. The EPA Project Manager will also schedule presentations upon request for the community. Contact Ed Hathaway, EPA Project Manager for more info at: (617) 573-5782.

Homeowners surveys:

In an effort to obtain additional feedback, a homeowners survey was passed out at the meeting which included questions on community concerns. Approximately seven residents responded to the survey. (See attachment)

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Site tour/ visit:

On December 6, 1995 a tour of the Landfill was conducted by EPA Project Manager Ed Hathaway for a reporter from the Portland Press Herald. The project manager pointed out the various areas of contamination, explained the status of cleanup and monitoring activities at the site. An article appeared in the (Date) edition of the Portland Press Herald. The Saco Journal Tribune was also provided a tour of the landfill at an earlier occasion.

A separate site/tour was also held for several City Council members.

Informal contacts with residents and local officials:

In addition to public meeting, press releases and information updates, the EPA project manager has been in contact with community leaders and area residents on a regular basis. During a well monitoring test, the City Planner, Rich Roedner, spoke personally with residents whose wells were being tested to answer questions and address concerns about activities at the site. He reported area residents did not express major concerns with activities at the site.

Community Involvement in Reuse Issues for the Site:

Reuse is a key concern to any community located in the vicinity of an NPL site. In determining reuse options, he EPA welcomes public input/discussion on issues related to reuse of the Saco Municipal Landfill. While criteria such as cost and safety are considered in reuse options, it is essential that reuse option appropriate to the community be developed that is an option that meets the needs of and is acceptable to the community. At this time no reuse plans have been developed for Saco, community input is encouraged.

EPA Technical Assistance Grants (TAG) and community involvement:

EPA has grant (TAG) money available to initially $50,000. to any community group who would like to apply for a technical assistance to help communities interpret data and technical information at superfund sites. The EPA will award only one TAG grant per site. To receive grant application information, the group should contact the EPA Grant Coordinator, Mike McGagh at (617) 223-5534. At this time no grant applications have been received for technical assistance at the Saco Municipal Landfill.

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Information repositories:

Information repositories have been established at the Dyer Library in Saco, Maine and at the EPA Records Center in Boston. These repositories contain administrative records and documents available for public review which are associated with activities at the site.

ASSESSING PUBLIC CONCERNS

The EPA has employed various strategies for assessing public concerns regarding the cleanup of Saco Municipal Landfill including holding public meetings and talking with area residents directly about their concerns. During the meeting on December 6, a homeowner survey was distributed to those attending the meeting. The information from the survey is being used to determine citizens issues/ concerns and focus on topics for future public meetings.

KEY COMMUNITY CONCERNS AND ISSUES

During the public meeting and in informal meetings with the project manager, residents raised a variety of concerns about activities at the Landfill. Among the concerns/ issues discussed include:

* Quality of drinking water and monitoring of water quality

* Surface water and sediments in the Brooks flowing near the landfill

* Will remedy be safe and longlasting?

* What will be the cost of this project to the City?

* Will residential wells be threatened?

* Reuse issues (restrictions on future use- how useful will the site be in the future?)

As the work proceeds on the site and as information becomes available it is the goal of the EPA project manager to address these concerns and keep the avenues of communication open as new issues arise. The level of interest in activities at the Saco Landfill is high. The residents want to be kept informed about activities on the site. The residents are satisfied with being kept informed via newsletters and public meetings.

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PLAN REVISIONS

The EPA recognizes that concerns may develop that aren't fully addressed in this plan. This community relations plan will be periodically updated and revised. EPA will continue to work closely with the residents of Saco to address issues that arise, reevaluate and amend this community relations plan according to the needs of the community.

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ATTACHMENT A

SITE TEAM

EPA:

Ed Hathaway Remedial Project Manager/ U.S. EPA (mailcode: HBT) JFK Federal Building Boston, MA 02203 (617) 573-5782

Sarah White Community Relations Coordinator/ RPS Superfund Community Relations U.S. EPA JFK Federal Building Boston, MA 02203

(617) 565-9260

Mike McGagh TAG Grants Coordinator U.S. EPA JFK Federal Building Boston, MA 02203

MAINE DEP:

Larry Brown Project Manager Maine DEP State House Station No. 17 Augusta, Maine 04333-6017

(207) 287-4859

Camille Parrish Geologist Maine DEP State House Station No. 17 Augusta, Maine 04333-6017

CITY OF SACO:

Larry Mitchell City Manager City of Saco Town Hall Saco, Maine 04072 207-282-4191

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Rich Roedner Planner City of Saco Town Hall Saco, Maine 04072 (207) 282-3487

Guy Valliancourt Engineer Woodard and Curran 41 Hutchins Rd Portland, Maine 04012

(207) 774-2112

LOCATIONS OF INFORMATION REPOSITORIES

Reference Desk:

Dyer Library Main Street Saco, Maine 04072 (207) 283-3861

Hours: Tues; & Thurs., 10 a.m-8:00 p.m. Wed. & Fri., 10 a.m.- 5 p.m. Sat., 9 a.m. - 12 noon

EPA Records Center 90 Canal Street Boston, MA 02203 (617) 573-5729

Hours: Mon - Fri. 10 a.m. - 1 p.m. 2 p.m. — 5 p.m.

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•s-z PROPOSED BEDROCK MONITORING WELL

•S-US EXACT LOCATION OF PROPOSED SHALLOW OVERBURDEN MONITORING WELL LOCATION WILL BE DETERMINED BASED ON RESULTS OF WELL POINT SURVEY

O MUNICIPAL LANDFILL

SAMPLING LOCATIONS

Flgur» 2

WOODARD A CURRAN INC.

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SACO MUNICIPAL LANDFILL HOMEOWNER SURVEY

Please answer the following questions regarding the cleanup of Saco landfill. EPA will use tfhis information to better serve the needs of area residents'.

Are you a resident? yes no

Where is your home to the landfill in relation to the landfill?

What are your primary concerns with regard to the landfill cleanup?

What topics would you like to see presented at the public meetings?

Please list any specific question? about the EPA activities on the site and the cleanup process?

What other activities would you like to see EPA make available to keep residents informed/ educated about the cleanup?

How did you hear about this meeting?

Newspaper_ (which one?) EPA Newsletter Radio Other

Thankyou!

New England

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/*?­THURSDAY DECEMBER 7, 1995 £ 1W5 Guv Canned Communications

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Agency downplays danger of lane fill • The EPA tells Saco residents the Super-fund site may not be as bad as it looks.

By DAVID CONNERTY-MARIN Staff Writer

SACO - A brook flowing through the city's former landfill runs orange in places. Todd MacDonald won't let his children or pets near it even though it's practically in his front yard.

But a federal Environmental Pro­tection Agency official told neigh­bors of the Superfund site Wednes­day that early indications are it's not that bad.

The EPA held its first public information meeting on the investi­gation and cleanup of the 90-acre site that was listed five years ago as a potential danger. It is one of 13 Superfund sites in Maine, and about 2,000 nationally.

A $573.000 study being paid for by the city began two months ago, and has already shown that besides iron and manganese flowing into the brook, there doesn't appear to be a serious problem at the former landfill.

Still, cleanup of two of the four former landfill areas could cost $2 million or more, said Edward Hath­away, project manager for the Environmental Protection Agency.

If the study finds more senous contamination, or a need to recap two other landfill areas that were capped in the 1980s, the cleanup cost couJd reach SI 5 million, making

Please see LANDFILL Page 16A

S A N T A

Cl pr< The New 1

WASHIN Clinton on Republicai balance the years, denoi wrongheade

At the sar present a co eliminating : less severe s smaller tax <

"We must we must do the commiti

Pnu and that keei President Clinton vetoes the Republicans' budget plan with the pen Clinton said Lyndon Johnson used 30 years ago to provide health care for the ceremony.elderly and the poor through Medicare and Medicaid. "With th:

U.S. advance group arrives in Bosnia

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flfite ffUfy^rVncencfpflCs' more flexibility in

fuss after ip to U.S. e means "I can play in the iout worrying about getting

. words got • supportive but Catherine's brought

later said the children's rovided the most touching of his Northern Ireland lie U.S., national TV news ^ of the president's visit both children, but they rl Catherine and her com­rds. out page Wednesday, the Hired its trip for the girl, i. stepfather, sister and irother. A photograph

> I Merino In the cockpit of en route Tuesday to New ng with captain's hat on. her family arrived Wed-Washington, where they <• lighting of the national ree. i1 Mirror article didn't ivid, the switchboard of iin radio talk show lit up alleging an anti-Protes­acy in the media, nnsul-general in Belfast, 'phens, who had known ul the Mirror trip, was nth confused or irate

•tfirta »***» WT^I,MIIP *^r^^^^ • • •• • •* >"*^ W«^«^B^

•administrative effort" that the

LANDFILL Continued/rom Page 1A

it the most expensive project in the city's history.

Residents had only a few ques­tions at Wednesday night's meeting in the Saco Middle School library. Mostly they were glad that work is f ina l ly being done on the site that was a landfill from 1960 to the 1980s.

Solvents and other materials were dumped at the site, enough to convince federal investigators in 1990 that the potential for a hazard exists. The city, which operated and owned the dump, is the primary party responsible for cleaning it up, but 13 other industrial dumpers and/or haulers also may be account­able for paying to clean it up.

Superfund laws say that, even if dumpers did nothing illegal accord­ing to laws at the time of the dumping, they are responsible for cleanup of contaminated sites.

MacDonald wanted to know if there was any immediate danger to his family. He was. told no.

Hathaway said the orange color could indicate a serious problem, but also could be the leakage of iron and manganese from the groundwa­ter. That could easily be remedied by capping the adjacent landfill.

Often it takes three to five years for a project to go from the study

jirtsa tviiT'iv lie1 ff^^lTTm*^^VWPBV^. I

divert the savings to services for any ~. school until March.

„ . , Stoff photo b\ Jack Mllimi Bruce Hansen, left, and BiU Nichols remove a flow meter from a test well at the Saco landfill Wednesday. Both men work for the U 5 Geological Survey. A $573,000 study being paid for by the city began two months ago, and has already shown that besides iron and manganese flowing into the brook, there doesn't appear to be a serious problem at the former landfill.

phase to the action phase, Hath- He said that's because of the away said, but this project is on amount of data already available, target for cleanup work to begin in and the cooperation of trie city, state the fall of 1996. and EPA on the project.

GO!'AC's genera! chairman. "The speaker is cer ta inly a

wounded politician at this point," said Honior, D-Mich., Gingrich's big­gest nemesis on ethics issues.

The outside counsel's investiga­tion only starts a long process that eventually will result in a decision to file formal charges or dismiss the allegations.

If charges are fi led, Gingrich would have a hearing to contest thorn. If Ihe committee finds the speaker guilty of major violations, it would recommend punishment to the House - ranging from a repri­mand to expulsion.

The harshest part of the letter involved Gingrich's book deal with HarperCollins for publication of "To Renew America."

The publisher originally offered Gingrich a $4.5 million advance, an amount Ihe speaker gave up after intense criticism.

The committee said Gingrich's book deal, in which he receives royalties based on . sales, "greatly exceeds the financial bounds of any book contract" contemplated under House rules.

Solicitations for the college course were made by GOPAC staff mem­bers, who went to work for two tax-exempt foundations. Donors were allowed to deduct their contri­butions on their federal income tax returns.

GOI'AC's ftmdraising role in the course, which began in the fall of 199:5, has been well documented in news stories and GOPAC records.

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EPA will hold hearing on landfill By PATTI LANIOAN HORVAT Journal Tribune Slall Writer

SACO — With testing of water, soil and air at (he Foss Road landfill underway, the U.S. Environmental Protection Agency will answer ques­tions at a public forum on Wednesday night.

"The main issue is to find out what people's concerns are," said EPA representative Edward Hathaway. The forum will open with a short presen­tation about the current investigation of the Saco Municipal Landfill, which was added (o the National Priority List (NPL)of contaminated sites eligible for LPA lesponsd in 1990, he said.

People will then be able to look at maps of the 90-acrt) landfill showing the four dump sites in a 30-acre area used for landfill operations from 1963 to 1989, ask questions about the study, and express concerns to representatives from the EPA, the Maine Department of Environmental Protection, and the City of Saco. Results of tests conducted in November and December of this year will not be available until February, and more tests will be conducted in the spring of 1996.

Hathaway said he would be willing to meet monthly with people to discuss ongoing concerns. Otherwise, he said the EPA would hold another public meeting in the early spring.

"We'll always keep them informed about hazards and make sure they're

We don't need to immodiately prevent people from going (to the Saco landfill), but the most important thing is to make sure repeated visits are OK.

protected," he said. "Some of the information we have confirms there is not a trememdous problem (at the Foss Road landfill), but it's much too early lo draw a conclusion."

WARNINGS STARTED IN 1975

According to the EPA,the Maine DEP reported groundwater contamina­tion at the Foss Road landfill in 1975. In 1976 the Maine DEP issued a consent order to the city (o slop leachale from filtering out of the landfill. The city responded by capping one dumpsite with clay in 1976, a procedure approved by state for closing landfills.

Four years later the EPA discovered volatile organic compounds at the Foss Road landfill and proposed the site for inclusion on the NPL for hazardous waste sites. 'Hie city capped a second dump site in 1984 and closed the landfill to dumping two years later. The site was placed on the NPL in 1990 and investigated further by the EPA be-

Edward Hathaway EPA representative

tween 1992 and 1995.

"Supcrfund sites are sites that have the potential !o be bad ... en:Mi(̂ ii '.I-.cl. histoiy lo warrant investigation," Hathaway explained. According to an EPA operational history of the Saco landfill, the dump sites on Foss Road received municipal solid waste, tannery sludge, construction debris, brush, and industrial waste.

"Many old landfills received sol­vents, degreasers, and industrial wastes, especially in the 1960s and 1970s," he added.

CORPORATE USERS' ROLE l:i September the City Council

reached agreement with »he EPA and began remedial investigation of the site. Approximately 14 other potentially responsible parlies that allegedly Jump­ed industrial waste at the municipal landfill proposed a separate settlement with the EPA and (he Maine DEP after failing to reach an agreement with the

cily. Sandy Hrook and Rig Ledge Brook

in the Saco lundlill aie being studied closely, Halhaway said. Orange-stained Icachute has heen seen in the upper p;trl of Sandy Hrook. "Orange typically means iron," Hathaway said, but he said the study will examine its effects on the brook's ability lo s'uslain fish.

Hathaway said it's impossible lo go through each durnpsilc thoroughly enough lo know everything that has ever been put there. Tests on groundwaler, surface water, sediments, soil, and air ;>re aimr ! :i! (Licciing CI.:]'J:III;;;I!AM:. cvuluati ' ig ihe concen­trations, and assessing the risk lo the environment and.particularly to people.

"The key isn't jusl what's in it (a dumpsite), but whether it 's moving," said Hathaway. "We do know (heie's not a level of air contamination that would make us concerned .ibou! a visit (to the Saco landfill) We ilon'l need to immediately prevent |x:o|)le Irom going Iherc, but the n-v ! m>|x>Manl t'l.ing is lo make sure rc|H:aied visits are OK."

Mayor Mark D. Johnston has said he hopes the 90 acres of city-owned property can be used to provide more recreational opixutunilics fur residents. That is a common use of closed landfills that j ,>se go threat to people being on lop of them. Because they can't be excavated, closed landfills are not acceptable as building sites, llallia­way said.


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