Sanborn: No PFAS disposal coming to Franklin

BERLIN — A plan to take on an environmental liability left behind by 120 years of industrial activity is reliant on revenue derived from bringing in contaminated soil from outside the state. That poses a public relations challenge Mark Sanborn is taking head-on.

“We are committed to maintaining transparency and engaging with the community by actively involving local stakeholders throughout the entire design and permitting process,” he states in a summary of the Dummer Yard Repurposing Project.

A former assistant commissioner of the New Hampshire Department of Environmental Services who also served as former Gov. Chris Sununu’s energy advisor during the establishment of the state Department of Energy, Sanborn now works with North and South Construction of Newington and W.L. French, an excavation, environmental and soil management firm based in North Billerica, Massachusetts. The companies have joined to form LFOD Northwoods LLC, which has a purchase-and-sales agreement to acquire the abandoned site east of the Androscoggin River used as a dumping ground for the pulp mills that once dominated the city.

During a video interview about the project, Sanborn dispelled speculation about plans to dispose of per- and polyfluoroalkyl substances, or PFAS, and other pollutants in the state’s smallest city, Franklin. While the company is separately pursuing an option to establish a facility that would employ new technology to destroy PFAS, Sanborn said it would not be in Franklin.

According to Sanborn, Ohio, Michigan and other parts of the country have begun employing new technology to treat concentrated PFAS, known as “forever chemicals” and linked to harmful health effects in humans and animals.

“This is a safe technology, and it’s an environmental solution,” he said. “It’s a way to not just move PFAS around from location to location, but to actually remove it from our environment and destroy it. The term ‘forever chemical’ is no longer applicable. There are ways to get rid of PFAS compounds and chemicals, but you need to find the right location. Does our group want to find the right location for that? Yes. Are we figuring out the right way to do that? Yes. Does it have anything to do with the Dummer Yard Repurposing Project? No. And right now, do we have any plans of Franklin being the right location for that? No.”

Sanborn said he is confident the Dummer Yard site contains PFAS and, in fact, “all the things you’d be concerned of are there”. That is why he wants to take on the project.

“Because of the poor management of the surface water and rainwater, leachate is being created on contaminated soil that was never properly capped, and the groundwater management system hasn’t been properly maintained,” he said. “We know for a fact the groundwater management needs a ton of improvement to make sure the system is discharging as it properly should.”

Leachate refers to liquid which may contain environmentally harmful substances.

Cautioning they are “truly in the early stage of our concept,” Sanborn said his company needs to do a lot more environmental review work.

“There’s always a double-edged sword where, if you don’t engage early, you know, folks start to wonder what’s happening. But if you do engage early, there are more detailed questions about a full design and full proposal that can’t be answered,” he said. “We are developing a concept. We are doing our due diligence. We’re doing the environmental review work. We’re finding out what state and local permitting requirements are going to be, and we’re finding about what community and stakeholders and impacted parties, their priorities, their concerns, and what they would like to see out of the project.”

Bond depleted

The last owner of the property, Pulp and Paper of America, closed the landfill and provided a $1 million closure bond to maintain and monitor the site when PPA filed for bankruptcy in 1996. That bond has been depleted, and the state took over monitoring of the site.

Among the firms hired by the state to help was engineering firm Sanborn Head and Associates. Sanborn, who says he is unrelated to the firm’s founding principal, Charlie Head, explained, “Strong recent knowledge of the property is one of the reasons they were the firm we’ve engaged with” to help develop the Dummer Yard Repurposing Project.

There are six waste disposal areas on the property, as well as a bark reclamation area, most of which had never been lined. What is lined was designed to old standards weaker then current requirements, and none of it was properly capped.

“What we would be proposing to do is, using previous reports and, in discussions with DES, we would have a remedial action plan that would involve [improving] the capping, to improve the topography, to improve the exposure to rainwater and surface water, and to make improvements to the groundwater management system and the gas monitoring systems, both of which need a lot of improvements and to be brought up to modern standards,” Sanborn said.

The 400-acre Dummer Yard property is adjacent to the Mount Carberry Landfill, which itself had been part of the same dumping ground, separated by the boundary line between Berlin and the township of Success. Access to Mount Carberry, including its weigh station, is through an easement on the Dummer Yard property.

“We would, of course, honor their easement fully,” Sanborn said, “and we would have a separate entrance and separate our operations and have a separate weigh station. It’s in everyone’s interest, including Mount Carberry, ourselves, and DES, that those operations are separate.”

Soil disposal

The property was listed at $1.9 million, with cleanup and ongoing monitoring also being costly. To pay for all that, the Dummer Yard Repurposing Project is depending on taking in soil monofill from development sites across New England.

“Obviously, all of North America is contaminated with various things, including PFAS,” Sanborn said. “So if we’re taking soil from a development site, it’s going to come with a lot of what those materials are.”

To accept that material while respecting public health and the environment, he said, requires testing the material before it arrives onsite to know exactly what is in it.

“OK, how are we improving the environmental situation? Well, you start by the way the contaminants are spread out through water, soil, just sitting there. The reason it’s a problem is it comes in contact with water, and that’s how it spreads,” he said.

That means reducing contact with water through proper capping of the site, and making sure groundwater does not end up in the wastewater treatment system, which cannot treat for PFAS. The Dummer Yard facility would not accept concentrated PFAS liquids, but that doesn't mean other forms of PFAS would not be in imported soil.

“We intend to have pre-treatment of the PFAS and remove it,” Sanborn said. “So that would all be part of our permitting and the rules we would have to follow, which we want to do. So, we would be testing. We would know exactly what’s coming in. Anything we needed to pre-treat, we would pre-treat. And then anything that’s discharged, we would follow all the rules and requirements, so that whatever ends up in the wastewater treatment system can then be treated by that system. And we start to remove these contaminants from our water.”

The site is a couple properties away from the Androscoggin River, but Sanborn conceded, “It is downhill from us, so we totally understand the concern. And both when it comes to standing bodies of water and the abutting residents, we will follow, even in this early concept design, we are comfortable that we will be able to have a viable project that meets all of the new setbacks that have just been passed. And are very comfortable we will not be contaminating local abutters or the bodies of waters in the area.”