Superfund Record of Decision: Old Springfield Landfill, VT

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-66-
In addition to the FML, which prevents water from
entering from above, the presence of a sandy soil layer
beneath the low-permeability soil layer prevents this layer
from becoming saturated from water entering from below.
Permeable materials (~, sandy soils) prevent the movement
of water (by capillary action) from underlying saturated
materials.
Tschebotarioff, 1973.
Accordingly, the low-permeability soil layer that
underlies an FML and overlies permeable soil would remain
unsaturated and not susceptible to damage from frost pene-
tration.
Elimination of the excess 12 inches of clean fill
layer would provide equivalent protection and be more cost-
effective.
An example of a design without this excess fill
is included in Figure 4, Detail D (attached).
If an FML
liner were retained in Waste Areas 2 and 3, the elimination
of the excess fill in those areas would result in a savings
of an estimated $80,000 or more, based on the pricing infor-

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-67-
VI.
THE DESIGN PROPOSED FOR THE FRENCH DRAIN TO BE LOCATED
UPGRADIENT OF WASTE AREA 4 IS FLAWED AND SHOULD BE
REPLACED WITH A DESIGN THAT IS MORE EFFECTIVE, MORE
IMPLEMENTABLE, AND LESS COSTLY

EPA's Proposed Plan includes a french drain to be
constructed around Waste Area 4 to prevent shallow subsur-
face and surface water from entering Waste Area 4.
There is
some confusion in the Administrative Record concerning the
proposed french drain design.
EPA's Proposed Plan includes
a diagram of. the french drain detail which contains, for
example, a 6-inch pipe and non-woven geotextile fabric on
the drain faces.
The SFS, however, depicts the french drain
with a l2-inch pipe and an FML on the downgradient face of
the drain.
FFS, Section 5.3.1, at 24.
To the extent EPA
intends to retain the design contained in the SFS, that
design is less effective, more difficult to construct, and
involves greater construction and operating costs than nec-
essary to achieve its intended objectives.
The disadvantages of the SFS design relate primar-
ily to the decision to combine surface water and groundwater
flows in the french drain.
This combining of flows will
result in wide fluctuations in flow volumes and therefore

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-68-
(i.e., pumps and pipes) than for a drain handling groundwa-
ter alone.
The combining of flows also could lead to the
commingling of uncontaminated surface water with groundwater
from Waste Area 4 so that the combined flow might require
treatment of large quantities of water prior to discharge.
To protect against that possibility, the SFS design includes
an FML on the downgradient face of the drain to act as a
hydraulic barrier to groundwater infiltration from Waste
Area 4.
The installation of an FML in a vertical trench,
however, involves a very difficult construction procedure.
In addition, the presence of the FML makes it much more
difficult to achieve EPA's objective of dewatering Waste
Area 4 prior to cap placement.
In contrast to the SFS design, the design proposed
by Remcor in Figures 2 and 4, Detail C (attached) would
provide a separate shallow surface water collection ditch
along the uphill (western and southern) sides of Waste Area
4 for surface water diversion.
This alternative design
would eliminate the combination of surface and groundwater
flows, reduce the size of the required hydraulic system,

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-69-
dient face of the french drain, and allow use of the french
drain for dewatering of Waste Area 4.
A.
The Size of the Hydraulic System Can be Reduced
The combining of surface water and groundwater
flows in the french drain creates a number of disadvantages,
including an unnecessary increase in the size of the hydrau-
lic system for pumping the combined flows from the drain.
During a peak rainfall/runoff event, surface runoff rates
are much greater than groundwater flows.
Using the widely
accepted rainfall-runoff calculation methodology developed
by the U.S. Department of Agriculture, Soil Conservation
Services (Barfield, et. aI, 1981), the surface runoff is
calculated to be 60,000 gallons per day (gpd), or about 40
gallons per minute (gpm), for the upland drainage area at
Waste Area 4 (13 acres) during a "design storm" (25-year,
24-hour) event.
If the design storm event were to coincide
with initial spring runoff from snowmelt, the peak surface
water flow rate could be 16 million gpd.
This surface run-
off compares to the average (and relatively constant)
groundwater flow of 1,150 gpd, as predicted by the hydrolog-
ic modeling presented by Remcor in the FFS.
FFS, Section

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-70-
For these reasons, the hydrau.lic requirements for
a system designed to pump both surface water and groundwater
(as proposed in the SFS) are much larger than those for a
system ~dpable of pumping groundwater alone (as proposed by
Remcor) .
In the design presented in the SFS, the specifica-
tions include a 12-inch diameter pipe in the french drain
and two 25-gpm pumps to pump the water from the drain to a
discharge line.
SFS, Section 5.3.1, at 26 and Figure 5-2.
With a separate surface water diversion ditch, however, as
Remcor has proposed, the piping in the french drain can be
reduced from 12-inch to 6-inch diameter and the pumps can be
reduced from 25-gpm to approximately 5-gpm capacity.
Fur-
thermore, these reductions are not offset by increased hy-
draulic requirements associated with the surface water di-
version ditch, which can be designed for gravity flow rather
than pumping of storm water flows.
Reliance on gravity flow
would also minimize operation and maintenance requirements
and assure surface water diversion even when the pumps were

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B.
The Flexible Membrane Liner Can be Eliminated
There is another, more significant, negative con-
sequence of the SFS proposal to combine the surface water
and groundwater flows in the french drain upgradient of
.
Waste Area 4.
In order to prevent the uncontaminated sur-
face water from becoming contaminated and requiring treat-
ment of large quantities of water, a hydraulic barrier is
required to prevent contaminated groundwater flow from Waste
Area 4 back into the drain.
To provide such a hydraulic
barrier, the SFS design includes an FML on the downgradient
vertical face of the french drain.
The installation of an FML in a vertical trench,
however, is fraught with technical difficulty.
FML materi-
als were not designed for this type of installation.
Tear-
ing of the material and breaking of seams are significant
problems during installation, especially during the with-
drawal of sheet piling or other trench shoring.
Further-
more, in vertical trench installations the FML cannot be
inspected for integrity once it is in place.
The separate diversion of surface water, as Remcor
has proposed, will avoid the need for a hydraulic barrier
and thus avoid these technical difficulties.

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needed for the drain to function properly, and with separate
diversion of surface water, the more effective design is to
collect the relatively small quantity of groundwater in the
drain (from upgradient of Waste ~rea 4 and from Waste Area 4
back into the drain) and convey it to the Springfield POTW
or any wastewater treatment facility constructed as an ele-
ment of the management of migration remedy.
The flow of
potentially contaminated groundwater to the french drain is
estimated to average less than 5 gpm, which would have no
material effect on the design of any wastewater treatment
facility.
In short, with the ready availability of the
Springfield POTW or a wastewater treatment facility, there
is little additional burden associated with treating the
comparatively small quantities of contaminated groundwater
that would be withdrawn from Waste Area 4 in the early
stages of the operation of the french drain.
C.
Dewatering of Waste Area 4 Can be Improved
Another, related problem associated with the
french drain design proposed in the SFS is that it does not
allow for effective dewatering of Waste Area 4 prior to
capping.
The SFS provides for the initial dewatering of
Waste Area 4 through the use of pumping wells.

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-73-
5.3.1, at 26 and 28.
Based on the results of Remcor's field
studies at the site, however, attempts to dewater Waste Area
4 using pumped wells would likely be ineffective.
During the FF5, Remcor. installed Well MW-325 in
the waste in Waste Area 4, intending to use it as a pumping
well in aquifer testing.
During a pumping test at Well MW-
325, the finely divided products of decomposition of the
municipal solid waste in this area quickly clogged the sand
pack and screen of the well, effectively preventing the well
from dewatering the waste trench in which it was placed.
Apparently, suspended and flocculated solids in the water in
the waste matrix choked the sand pack around the well and
plugged the well screen.
While proper design of the dewa-
tering wells could reduce the problems associated with foul-
ing and plugging, Remcor's permeability testing of the waste
in Waste Area 4 indicated very low waste permeability (~,
2.50 X 10-5 and 1.55 X 10-5 at Borings RTB-19 and RTB-20.
respectively).
FF5, Table 15.
These low waste permeability
values would preclude efficient dewatering by pumped wells.
Remcor's alternative design for the upgradient
perimeter french drain would allow dewatering of Waste Area
4 without the use of pumping wells.

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-74-
the downgradient face of the french drain and allowing flow
from-Waste Area 4 into the drain would aid considerably in
dewatering of Waste Area 4.
This dewatering, combined with
the upgradient surface water diversion and preliminary grad-
ing of Waste Area 4, would provide sufficient stabilization
of this area to allow placement of a cap.
Proper sequencing
and scheduling of construction activities would ensure ade-
quate time for this area to be dewatered prior to cap con-
struction.
In sum, for a number of reasons, Remcor's alterna-
tive design for the french drain would be more effective and
more implementable than EPA's design.
In addition, it would
provide equal or better protection at a cost savings esti-
mated to be $50,000 or more, based on the pricing informa-
tion provided in the FFS.~/
~/ The actual cost savings could be significantly higher,
because some of the costs estimated in the FFS (~, the cost
of an FML liner in the french drain, including installation)
may be artificially low. Remcor estimates that the actual cost

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-75-
VII.
EPA'S PROPOSAL TO STABILIZE THE OUTSLOPES OF WASTE
AREAS 2 AND 3 IS ILL-CONSIDERED AND, IF SLOPE STABILI-
ZATION IS REQUIRED AT ALL, SHOULD BE SUBSTANTIALLY
MODIFIED
EPA'S Proposed Plan provides for the stabilization
of the side slopes of Waste Areas 2 and 3 to protect the cap
and the leachate collection system in Operable Unit 1 and to
minimize the potential for slope collapse.
With respect to
the outslope of Waste Area 3, however, Remcor has deter-
mined, after careful analysis, that stabilization is not
necessary to ensure against slope failure.
Further, if
slope stabilization is required in Waste Area 3, Remcor's
proposal to construct a buttress/fill in this area is more
effective, more implementable, and involves significantly
reduced risks than the design proposed by EPA.
With respect
to the outs lope of Waste Area 2, EPA has not even provided a
conceptual design.
However, Remcor's design for Waste Area
3 can be easily adapted to Waste Area 2 to provide similar
benefits.
A.
Stabilization of the Outslopes of Waste Area 3 is Not
Necessary to Ensure Stability against Mechanical Fail-
ure
without performing any analysis of slope stability

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-76-
of any stabilization measures the caps might induce insta-
bility on the side slopes."
SFS, Appendix F, at F-2.
The
SFS also states that "the long-term factor of safety
[against slope failure] after re~ediation should be at a
minimum 1.3."
Id. at F-2.
After performing the required
analysis of slope stability, however, Remcor has determined
that, with the management of migration remedy (Operable Unit
1) in place, the outslopes of Waste Area 3 will be stable --
with a factor of safety against slope stability exceeding
1.3 -- and, therefore, slope stabilization is unnecessary.
Remcor performed a slope stability analysis for
the outslopes of Waste Area 3 based on widely accepted geo-
technical principles.
Soil located on a sloping surface has
a tendency to move downward and outward under the influence
of gravity.
If this tendency is counteracted by the shear-
ing resistance of the soil, the slope is stable and will not
fail.
Terzaghi and Peck, 1967.
The geomechanical proper-
ties of the soil (~, grain size, particle shape and in-
terlocking, and cohesion) and groundwater conditions deter-
mine the shearing resistance of any native soil or fill
material located on a sloping surface.
In general terms,

-------
-77-
the magnitude of gravitational forces is expressed in terms
of a factor of safety.
Theoretically, if the factor of
safety is greater than 1, the slope is stable; conversely,
if the factor of safety is less than 1, the slope would be
unstable.
Because of the uncertainties associated with the
properties of natural soils or fill materials, however,
engineering practice typically requires safety factors in
the range of 1.25 to 1.50.
Schuster and Krizek, 1978.
Remcor performed its slope stability analysis
using the STABL5 computer program developed by Purdue Uni-
versity and specifically identified in the SFS as a means
for evaluating static and pseudostatic slope stability con-
ditions.
Table 1 (attached) presents the input data used by
Remcor in this exercise.
The computer analysis methodology
involves the calculation of a large number of potential
failure mechanisms and the determination of a minimum factor
of safety for the overall slope.
Using this methodology,
Remcor calculated the factor of safety against slope failure
-- under existing conditions -- to be approximately 1.2.
Therefore, although the slopes would not be predicted to
fail, the margin of safety is just below the prefe~~ed range

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-78-
In connection with the implementation of the man-
agement of migration (Operable Unit 1) remedy, however, a
drain will be constructed to collect seepage from Waste Area
3 (Seep LSE03).
As described in. the FFS, Remcor's prelimi-
nary design for the management of migration remedy provides
for constructing this drain largely as above-grade fill in
the ravine below LSE03.
FFS, Section 1.1.4, at 1-6.
Me-
chanically, this fill would act as a buttress at the toe of
the slope.
Remcor's slope stability analysis was performed
assuming that the Operable Unit 1 drain is in place and the
plateau portion of Waste Area 3 is capped with a 7-foot
thick cap.
These conditions represent the reasonable
"worst-case" design conditions for the Waste Area 3 outs-
lopes.
While capping Waste Area 3 would lower the water
table in Waste Area 3 and thereby increase the shearing
resistance of the soils and the fill, these contributions to
slope stability would be more than offset by the surcharge
imposed at the top of the slope by the weight of the cap.
Under these conditions, Remcor calculated a mini-
mum factor of safety for the Waste Area 3 outslopes of 1.34
-- within the required margin of safety and above the 1.3
factor recommended in the SFS.

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of the outslopes of Waste Area 3, beyond that to be provided
in the management of migration remedy, is required.
B.
If Stabilization of the Outslopes of Waste Area 3 is
Required, a Buttress/Fill Should be Constructed and
EPA's Proposed Regrading Should be Avoided

If stabilization of the outs lopes of Waste Area 3
is required at all, the preliminary design described in the
SFS involves significant risk that can be avoided with an
alternative design. EPA's Proposed Plan states that "[t]he
exact method of side slope stabilization would be determined
during the remedial design stage," which indicates some 
flexibility on this issue. The SFS, however, describes a
side slope stabilization design in which the outs lopes of
Waste Area 3 would be extensively regraded to establish a
slope of 3 horizontal to I vertical (i.e., a slope of 3:1),
with an intervening bench at Elevation 440 feet mean sea
level (ft-msl).
There is no justification for such regrading,
which would involve significant waste excavation with atten-
dant short-term exposure risks from uncontrollable vapor
releases, fugitive dust, and contaminated rainfall runoff.
As described in the SFS, "[s]tringent environmental monitor-

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-80-
toring)" would be necessary.
SFS at 39.
Monitoring would
be the only means to determine whether contaminant releases
were so severe as to require evacuation of workers or local
residents.
In addition, airborne releases of contaminants
could require remedial workers to be suited in supplied-air
breathing apparatus and construction equipment to be fitted
with pressurized cabs and supplied air.
In the FFS, Remcor
likewise discussed the almost certain severe adverse envi-
ronmental impacts from waste excavation.
FFS, Section
3.3.2.4, at 3-44 and 3-45.
To avoid the need for waste excavation and the
serious adverse environmental impacts associated with it,
Remcor developed an alternative design for stabilization of
the outslopes at Waste Area 3, which is depicted in Figures
2 and 3 (attached).
The design provides both for stabiliza-
tion of the outslopes against mecbanical failure and a cover
over existing surface materials of 3.5 feet of clean soil
fill.
In Remcor's design, select clean fill would be placed
in the ravine downslope of Waste Area 3, spread into rela-
tively thin lifts (~, 9 to 12 inches), ~nd compacted.
Lifts of soil would be sequentially added until a uniform
grade of 2.5:1 was achieved.

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at approximate Elevations 440 and 470 ft-msl for drainage
and erosion control and stability, and the established sur-
face would be revegetated to protect it from excessive soil
erosion.
This design would provide a stable slope with a
long-term factor of safety against mechanical failure in
excess of 1.5.
Remcor's alternative design would have other ad-
vantages over the design presented in the SFS.
In contrast
to the SFS design in which the soil cover "would not signif-
icantly reduce infiltration through the side slope areas"
(SFS, Section 5.3.2, at 31), Remcor's design would reduce
rainwater infiltration by an estimated 62 percent.~ The
effect of this reduction in rainwater infiltration, which
appears to be an EPA objective, would be to reduce contami-
~/ This calculated reduction in rainwater infiltration is
based on the Hydraulic Evaluation Landfill Performance (HELP)
modeling that Remcor performed in the FFS (FFS, Section
2.5.1.1, at 2-78 through 2-80) and the assumption that the
permeability of the soils used in the upper portion of the fill
would be equivalent to the HELP model default value for ."silt"
soil (Schroeder, et al., 1984). This assumption is reasonable
because, in Remcor's design, the fill composition would be
carefully selected and would change with depth in the fill.
Coarser materials (~, sands) would be used at depth and
finer-grained soils~, clayey silts) would be placed in the

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-82-
nant loading to LSE03 downgradient of Waste Area 3 and to
reduce contamination of the eastern bedrock.
To the extent EPA remains concerned about landfill
gas emissions (a concern with which we strongly disagree),
the Remcor design also would significantly reduce the poten-
tial for such emissions from the outslopes of Waste Area 3.
Using the landfill gas emission model described in the ICF
EA (l988a) and based on the increased depth of soil cover in
the Remcor design, landfill gas emissions would be reduced
by 86 percent.
See FFS, Table 35.
In short, the Remcor design is more effective and
implementable than the SFS design for the stabilization of
the outslopes of Waste Area 3.
The alternative design
avoids the need for waste excavation and the associated
risk.
The mechanical stability of the outslopes would be
enhanced and both rainfall infiltration and potential land-
fill gas emissions would be reduced.
The design is based on
conventional technology and is compatible with the prelimi-
nary design for collection of leachate from Seep LSE03 below
Waste Area 3.
The cost of the alternative design would be

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-83-
c.
A Buttress/Fill Also can Be Used to Stabilize the
Outslopes of Waste Area 2 and Avoid the Risks Associ-
ated with Regrading or Other Major Construction Activ-
ities
Neither EPA's Proposed Plan nor the SFS presents a
conceptual design for stabilization of the outslopes of
Waste Area 2.
The SFS states that "[d]ue to the topographic
complexities of the topography of Waste Area 2, a detailed
side slope stabilization plan for Waste Area 2 can only be
developed after the pre-design geotechnical investigation,
including la~oratory testing and stability analyses."
Section 5.3.1, at 31.
SFS,
It is apparent, however, that EPA and its contrac-
tor believe that extraordinary measures must be implemented
to stabilize the Waste Area 2 outslopes.
The SFS states
that "[t]he side slope stabilization in Waste Area 2 has
been assumed to potentially require construction of major
retaining structures (such as steel sheet piles, concrete
cantilevered retaining wall, reinforced diaphragm walls,
etc.) at the toe of the waste area."
SFS, Section 5.3.1, at
31.
The SFS states further that "[c]reating a 3:1 stable
slope in Waste Area 2 would require excavating significant
amounts of waste."
SFS, Section 5.3.1, at 31.

-------
-84-
the SFS contains an astounding $1,000,000 estimate for the
side slope stabilization of Waste Area 2.
SFS, Appendix E,
at E-12.
If any slope stabilization is required, such ex-
traordinary measures to stabilize the outs10pes in Waste
Area 2 are clearly not justified.
Apart from the technical
complexity and excessive cost involved, the approach de-
scribed in the SFS poses the same severe environmental and
health exposures associated with the excavation of waste
from Waste Area 2 as are described above for Waste Area 3.
Therefore, as for Waste Area 3, Remcor developed an alterna-
tive design for slope stabilization in Waste Area 2 which
avoids these severe effects.
The design, as depicted in
Figures 2 and 3 (attached), would stabilize the outslopes in
Waste Area 2 against mechanical failure and cover existing
surface materials with a cover of a minimum of 2 feet of
clean soil fill.
The alternative design for the Waste Area 2 outs-
lopes is very similar to that for Waste Area 3.
Select fill
would be placed in the ravine below Waste Area 2 and spread
into thin horizontal lifts (~, 9 to 12 inches) to achieve

-------
-
-85-
tions 450 and 480 ft-msl.
This slope formation would pro-
vide a minimum factor of safety against mechanical failure
in excess of 1.5.
Fill soils would be selected to provide
for coarser materials at depth and finer-grained soils at
the surface.
The finished grade would be permanently reveg-
etated to provide protection against soil erosion.
As for Waste Area 3, the alternative design for
the outslopes in Waste Area 2 would be effective and imple-
mentable.
It would provide effective slope stability, avoid
the risks associated with waste excavation, and reduce rain-
fall infiltration and potential landfill gas emissions.
The
design also would involve the use of conventional technology
witho~t construction of "major retaining structures" as
suggested in the SFS, and would be compatible with the pre-
liminary design for the leachate collection component of the
management of migration rem~dy.
VIII.
EPA'S CONSIDERATION OF THE COMPLETE EXCAVATION AND
DISPOSAL OF WASTE AREA 2 RATHER THAN CAPPING AND SIDE
SLOPE STABILIZATION IS BASED ON A FLAWED ANALYSIS AND
INVOLVES SUBSTANTIAL ENVIRONMENTAL RISKS
In its Proposed Plan, EPA indicates that it is
considering the complete excavation and disposal of Waste

-------
-86-
based on the assumption that it "may prove to be less expen-
sive."
In the SFS, EPA's contractor also assumes that
,
waste excavation may be less costly, as well as "technically
more feasible and more easily implemented."
SFS, Section
3.5.2, at 49.
Those assumptions, however, and EPA's consid-
eration of waste excavation, are seriously flawed.
They are
based on an incomplete analysis of technical issues, regula-
tory considerations, and cost implications of waste excava-
tion compared with other alternatives for addressing Waste
Area 2.
First, on the issue of implementability, EPA un-
derestimates the environmental risks associated with waste
excavation and exaggerates the technical difficulties as so-
ciated with slope stabilization.
As described in Section
VII.B above, the environmental and health risks associated
with the excavation of waste from Waste Area 2 are enormous.
Both the FFS and the SFS express considerable concern about
the risk to remedial site workers and, possibly, to the
general public of exposure to uncontrollable contaminant
releases.
In contrast, Remcor's proposed-design for slope
stabilization avoids these risks and avoids the technical

-------
-87-
suggested in the SFS.
EPA's failure to consider a slope
stabilization design such as the one proposed by Remcor has
skewed its analysis toward consideration of waste excava-
tion, which is the least desirable option for addressing
Waste Area 2.
Second, EPA gives insufficient consideration to
the regulatory issues associated with the excavation of
waste from Waste Area 2.
EPA indicates that it "would most
...
likely dispose of the excavated material by placing it in
Waste Area 3 depending on whether RCRA land disposal re-
strictions [LDRs] apply."
In the SFS, EPA's contractor also
notes that, if Waste Areas 2 and 3 are defined as separate
units, "movement of materials from Area 2 to 3 would consti-
tute placement and LDR would be triggered."
SFS, at 45.
Having identified the issue, however, EPA does not consider
the consequences of a finding that LDRs would apply to waste
excavation.
As a general matter, based on EPA guidance and the

preamble to the NCP, the movement of excavated waste from
one area of contamination to another would constitute dis-
posal of hazardous waste and trigger LDRs.
OSWER Directive

-------
-88-
Fed. Reg. 8758 (March 8, 1990).
If these requirements were
deemed applicable here, waste excavated from Waste Area 2
would have to comply with treatment standards (or a treat-
ability variance would have to be obtained) and be disposed
of in a RCRA landfill meeting minimum technological require-
ments.
Because Waste Area 3 does not meet these technologi-
cal requirements, however, there is a question whether an
EPA plan to place waste from Waste Area 2 into Waste Area 3
would satisfy ARARs and, therefore, would pass alternative
screening under the threshold criteria established in the
revised NCP.
Further, the cost of compliance with LDRs --
involving the potential treatment of waste, construction of
a RCRA landfill on-site, or disposal off-site -- would be
tremendous.
In short, these regulatory considerations will
have a major impact on the viability of any plan to excavate
waste and on the evaluation of any such plan consistent with
the NCP.
EPA's suggestion that waste excavation is a viable
option, without performing the detailed analysis that it
performed on other alternatives and is required by the NCP,
is ill-considered and contrary to law.
Third, EPA's assumption that the cost of excavat-

-------
-89-
slope stabilization is erroneous.
As the SFS makes embar-
rassingly clear, EPA does not even have a design concept for
slope stabilization.
The cost figure of $1,000,000 is ap-
parently chosen at random based on the conclusion that "[i]-
nsufficient conceptual design inputs are available to accu-
rately estimate construction components and quantities."
SFS, Appendix E, at E-12.
On this record, reaching any
determination at all on this element of a source control
remedy -- even by resorting to including two opposing alter-
natives -- is arbitrary and capricious.
In any event, before EPA can even consider waste
excavation as a less costly alternative, it must develop
some cost estimate for slope stabilization.
Remcor's cost
estimate for slope stabilization based on its design is
approximately $170,000, or $830,000 less than the figure
contained in the SFS.
Therefore, the gross overestimation
of cost in the SFS has led EPA to the errant conclusion that
excavation of waste from Waste Area 2 could be less expen-
sive than slope stabilization.
Based on supportable costs,
waste excavation from Waste Area 2 would not be less expen-
sive, but rather at least $600,000 more expensive based on a

-------
-90-
Area 2 (i.e., $769,800), SFS, Appendix E, at E-26, and the
cost estimate for Remcor's proposed stabilization plan.
And
if LDRs are applicable, the cost of excavating waste from
Waste Area 2 could skyrocket.
In sum, excavating waste from Waste Area 2 would

involve much greater short-term risk, would not improve
effectiveness, and would cost substantially more than side
slope stabilization.
Accordingly, EPA should drop waste
excavation from further consideration.
IX.
AN ACTIVE GAS VENTING SYSTEM FOR WASTE AREA 3 IS UN-
NECESSARY AND SHOULD BE REPLACED BY A PASSIVE SYS-
TEM
EPA's Proposed Plan provides for an active gas
collection system in Waste Area 3 and a passive gas collec-
tion system for the other waste areas.
EPA apparently be-
lieves that an active gas collection system is necessary to
"prevent the build-up of methane under the cap" and to "pre-

vent the uncontrolled escape of landfill gases containing
hazardous chemicals."
An active gas collection system in Waste Area 3 is

not required, however, because there is no unacceptable risk
associated with landfill gas exposure at the site.

-------
-91-
even if there were an unacceptable risk, passive gas collec-
tion would be sufficient; the rate of landfill gas emission
as calculated from site-specific data is not sufficient to
warrant active gas collection.
Although EPA apparently
questions whether a passive gas collection system can be
incorporated into its slope stabilization design, a passive
system can be incorporated into Remcor's alternative design
for outslope stabilization in Waste Area 3.
The purpose of a gas collection system, whether
active or passive, is to collect and disperse gas (princi-
pally methane) generated as landfill organic waste decom-

poses, so that the gas does not build up underneath an im-
permeable cap.
If sufficient gas were generated from the
waste and allowed to accumulate, the gas pressure would
eventually rupture the cap if the pressure exerted by the
gas equaled or exceeded the downward pressure exerted by the
weight of the overlying cap materials.
In a passive gas
collection/venting system, a permeable pathway is provided
so that the gas pressure builds up only until the pressure
is sufficient to push the gas through the permeable pathway

-------
.~
-92-
vent through the cap}.
In an active system, vacuum pumps
are used to pump the gas out from under the impermeable cap.
First and foremost, an active gas collection sys-
tern is not required at this Site because, as described above
in Section III.B, none of the studies performed at the site
has demonstrated an unacceptable risk to future site tres-
passers or residents from the inhalation of gases potential-
ly emitted from the landfilled wastes.
The 1988 EA, which
serves as the basis for EPA's finding of unacceptable risk,
failed to consider the characteristics of the municipal
solid waste/soil mixtures on the Site, overstated the emis-
sion source area, exaggerated the rate of landfill gas emis-
sions, and overstated exposure possibilities.
In contrast,
the risk analysis contained in the FFS, which is based on
more recent, site-specific data and EPA guidance, shows no
unacceptable risk from landfill gas inhalation.
Furthermore, even if there were an unacceptable
risk, the rate of landfill gas emission from Waste Area 3
does not justify an elaborate, active gas collection system
with common collection headers, two condensing units and two

vacuum blower units, a vapor phase activated carbon treat-

-------
-93-
SFS, Appendix C, at C-l3.
To the contrary, Remcor's calcu-
lations based on data developed by EPA's contractors show
that gas buildup under the cap in Waste Area 3 would be well
within the maximum pressure that a passive gas collection
system could accommodate.
Remcor used the landfill gas velocity reported in
the 1988 EA (Table C-4), i.e., 1 X 10-10 em/see, to calcu-
late the rate at which landfill gases, primarily methane,
would likely be generated under the capped portion of Waste
Area 3.~/ The SFS shows a capped area in Waste Area 3 of
approximately 115,000 square feet (ft2), i.e., 1.07 X 108
square centimeters.
SFS, at 24 and Appendix E, at E-9.
Therefore, based on data supplied by the EA and the SFS, the
total gas generation (flux) rate for the capped portion of
Waste Area 3, which can be calculated by multiplying the
landfill gas velocity by the landfill area, is 1.07 X 10-2
cubic centimeter per second (i.e., 1.07 X 10-5 liter per
second).
~/ This landfill gas velocity was calculated in the ICF EA
(1988a) from measurements of methane gas concentrations in
certain boreholes drilled through waste areas at this site.
Remcor d~d not verify this landfill gas velocity value in the

-------
-94-
Next, Remcor calculated the potential effect of
this gas generation rate on gas buildup under the cap.
order to evaluate the need for an active gas collection
In
system rather than a passive system, Remcor assumed the

presence of a passive system in making its calculations.
For Waste Area 3, the gas venting layer is taken as a layer
of 12 inches (30 centimeters) of sands with an estimated gas
permeability of 1.6 X 10-3 em/see (i.e., 16 times the water
permeability of 1 X 10-4 cm/sec)_~ The cap configuration
presented in the SFS indicates that the maximum distance the
gas would have to flow to reach the perimeter of the cap
would be no more than 80 feet.
Based on simple fluid me-
~/ This water permeability is considered quite conserva-
tive (underestimating) for the sand fill materials that would
be regraded to form the subgrade under the cap in Remcor's
proposed design as described in Section V above and Figure 4
(attached). See also FFS, Section 2.3.2.1, at 2-45 and Section
2.3.2.2, at 2-46.~e permeability of this sand layer for a
fluid other than water (~, landfill gas) is determined by
two factors: (1) the intrinsic permeability of the material,
and (2) the viscosity and density of the fluid (both the vis-
cosity and density can be described together as "kinematic
viscosity"). The gas permeability to water ratio is calculated
by dividing the kinematic viscosity of air (assumed to be rep-
resentative of the landfill gas) by the kinematic viscosity of
water. Todd, 1959. At 20 degrees celsius, the kinematic vis-
cosities for air and water are 1.8 X 10-5 and 1.1 X 10-4 square
feet per second, respectively. Streeter, 1971.

-------
-95-
chanics, Remcor calculates that the pressure required to
induce flow under these circumstances is less than 0.003
pound per square inch (psi).
By contrast, the downward
pressure exerted by the 5 feet of material comprising the
overlying cap (based on Remcor's design described in Section
v above and an average unit weight of 100 pounds per cubic
foot [lbs/ft3] of material) is 5 feet x 100 Ibs/ft3 = 500
Ibs/ft2 or 3.5 psi.
Accordingly, Remcor estimates the maxi-
mum gas buildup pressure to be less than 0.1 percent of the
downward pressure exerted by the overlying materials.
Clearly, therefore, even if the data provided in
the EA are not entirely accurate, a passive gas collection
system is adequate to remove whatever gas is generated with-
in Waste Area 3.
Further, Remcor's alternative design for
outslope stabilization in Waste Area 3 can easily accommo-
date such a passive system as shown in Figures 2, 3, and 4,
Detail G.
Therefore, to the extent EPA shares the concern
expressed in the SFS that the slope may not provide a stable
base or access for equipment needed to install gas venting
systems on the outslopes, that concern is misguided.
Simi-
larly, landfill gas emissions along the outslopes should not

-------
-96-
Remcor's design will reduce uncontrolled gas emissions by an
estimated 86 percent.
In sum, the inclusion of an active gas collection
system in Waste Area 3 results in excessive capital costs of
$263,000, based on pricing information provided in the SFS,
and operating expenses without any benefit.
A passive sys-
tern is effective, more implementable because it avoids the
complexity of an active system, and less costly.
x.
A SINGLE SOURCE CONTROL WELL IS SUFFICIENT TO INTER-
CEPT THE GROUND WATER DISCHARGING FROM THE TILL BE-
NEATH WASTE AREA 3
EPA provides in its Proposed Plan for the instal-
lation of source control wells through Waste Area 3 to in-
tercept the groundwater discharging from the till into the
sand and gravel unit to the west and into the weathered
bedrock to the east.
The SFS proposes two such source con-
trol wells based on the assumption that "[u]sing a minimum
of two wells with variable pumping rates and schedules will
provide an extra measure of control on the capture zone
configuration."
SFS, Appendix D, at D-l.
Based on current-
ly available data, however, one source control well may

-------
III
-97-
Further, if EPA disagrees that one well would be
sufficient, it should at least await the results of addi-
tional testing to be performed in connection with the design
of the management of migration remedy before making a deci-
sion.
During the FFS, the short-term pumping of Well MW-41G
had a significant influence on the sand and gravel unit.
Additional aquifer pumping tests will be performed in the
predesign of the extraction well(s) to be installed as a
component of the management of migration remedy.
Those
tests may demonstrate that the extraction well(s) will pro-
vide sufficient hydrodynamic control beneath Waste Area 3 to
obviate the need for two or even one source control well.
Apart from the appropriate number of wells, the
SFS proposes to use stainless steel risers in constructing
the source control wells.
Contaminant levels in the ground
water and soils within Waste Area 3, however, are insuffi-
cient to warrant use of stainless steel riser pipes. Mild
steel or polyvinyl chloride (PVC) would be acceptable mate-

-------
-98-
XI.
THE SCHEDULE FOR IMPLEMENTATION OF THE SOURCE
REMEDY SHOULD BE INTEGRATED WITH THE SCHEDULE
IMPLEMENTATION OF THE MANAGEMENT OF MIGRATION
REMEDY
CONTROL
FOR
Although EPA has chosen to separate remedial ac-
tion at the Old Springfield Landfill into two separate reme-
dies -- the management of migration remedy and the source
control remedy -- the schedule for implementation of the two
remedies should be integrated to achieve the best results.
From a technical or engineering perspective, the division of
the remedy into two parts is artificial.
Failure to consid-
er the effect of one remedy on the other may result in inef-
ficiencies at best and in outright inconsistencies at worst.
There are a number of areas in which the design
and construction of one remedy must be integrated with the
design and construction of the other.
For example, as de-
scribed in Section XI above, the design and installation of
one or more source control wells may have to await at least
the design of the extraction well(s) as part of the manage-
ment of migration remedy.
Perhaps of greater impact, the
design and installation of the seep collection system on the
eastern outslopes cannot be completed until the design of

-------
-99-
likewise completed.
The designs of those two remedial com-
ponents are intertwined, because the soil fill associated
with slope stabilization will likely extend beyond the
points of seep collection on the eastern outslopes.
It may
also be necessary to integrate the actual construction of
the seep collection system with the slope stabilization
measures, for technical reasons and/or to avoid large inef-
ficiencies.
In its Record of Decision for source control, EPA
should acknowledge the relationship between the two remedies

and either specifically integrate the two schedules or indi-
cate the future need to do so.
An integration of the two
remedies is necessary for technical reasons and for effi-

-------
LIST OF REFERENCES
Barfield, B.J., R.C. Warner, and C.T. Haan, 1981, Applied
Hydrology and Sedimentology of Disturbed Lands, Oklahoma
Technical Press, Stillwater, Oklahoma.
Ebasco Services, Incorporated, July 1990, "Draft Final Supple-
mental FS Evaluation, Old Springfield Landfill, Operable Unit
No.2," Contract No. 68-W9-004 EPA Region I, Boston,
Massachusetts.
Hathaway, M., July 1990, "Memorandum to Site File, Detailed
Evaluation and Comparative Analysis of Alternatives (Detailed
Evaluation Memo)," Remedial Project Manager, Maine and Vermont
EPA Region I Superfund Program, Boston, Massachusetts.
ICF Incorporated, June 1988a, "Draft Final Endangerment Assess-
ment Report, Old Springfield Landfill, Town of Springfield,
Windsor County, Vermont," EPA Work Assignment No. 50-lL39, U.S.
Environmental Protection Agency, Region I, Boston, Massachusetts.
ICF Incorporated, June 1988b, "Draft Final Feasibility Study
Report, Old Springfield Landfill, Town of Springfield, Windsor
County. Vermont," EPA Work Assignment No. 50-1L39, U.S. Environ-
mental Protection Agency, Region I, Boston, Massachusetts.
ICF Intorporated, June 1988c, "Draft Final Supplemental Remedial
Investigation Reporti Old Springfield Landfill, Town of Spring-
field, Windsor County, Vermont, EPA Work Assignment No. 50-lL39,
U.S. Environmental Agency, Region I, Boston, Massachusetts.
Olsen, R.L., and A. Davis, June 1990, "Predicting the Fate and
Transport of Organic Compounds in Groundwater: Part 1,"
Hazardous Materials Control, Volume 3, No.4, pp. 39-64,
Hazardous Materials Control Resources, Inc., Silver Spring,
Maryland.
Remcor, Inc., 1990, "Draft Final Focused Feasibility Study, Old
Springfield Landfill Site, Springfield, Vermont," Project No.
89029, Emhart Industries, Inc., Hartford, Connecticut and
Textron, Inc., Providence, Rhode Island.
Schroeder, P.R., A.C. Gibson, and M.D. Smolen, 1984, "The Hydro-
logic Evaluation of Landfill Performance (HELP) Model (Draft),"
EPA/530-SW-84-010, U.S. Army Waterways Experiment Station,
Vicksburg, Mississippi and U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, Washington, DC.

Schuster, R.L. and R.J. Krizek (eds.), 1978, "Landslides,
Analysis'.and Control, Special Report 176, National Academy of
Services, National Research Council, Trans~rtation Research

-------
R-2
Streeter, V.L., 1971, Fluid Mechanics, Fifth Edition, The McGraw-
Hill Book Company, New York, New York.

Tchobanoglous, G., H. Theisen, and R. Eliassen, 1977, Solid
Wastes, Engineering Principles and Management Issues, McGraw-Hill
Book Company, New York, New York.
Teng, W.C., 1962, Foundation Design, Prentice-Hall, Inc.
Englewood Cliffs, New Jersey.
Terzaghi, K. and R.B. Peck, 1967, Soil Mechanics in Engineering
Practice, John Wiley & Sons, Inc., New York, New York.
Thibodeaux, L.J., 1981, "Estimating the Air Emissions of
Chemicals from Landfills," Journal of Hazardous Materials, Volume
4. Page 244.
Todd, D.K., 1959, Ground Water Hydrology, John Wiley & Sons,
Inc., New York, New York.
Tschebotarioff, G.B., 1973, Foundations, Retaining and Earth
Structures, The McGraw-Hill Book Company, New York, New York.
u.S. Environmental Protection Agency, June 1988, "EPA Proposes
Cleanup Plan for Old Springfield Landfill Site," EPA Region I
Superfund Program, Boston, Massachusetts.
u.S. Environmental Protection Agency, August 1988, "CERCLA
Compliance with Other Laws Manual - Draft Guidance," Office of
Emergency and Remedial Response, Washington, DC.
u.S. Environmental Protection Agency, September 1988, "Record of
Decision, Old Springfield Landfill, Springfield, Vermont,"
Region I, Boston, Massachusetts.
u.S. Environmental Protection Agency, March 1989, "Risk Assess-
ment Guidance for Superfund, Volume II, Environmental Evaluation
Manual (Interim Final)," EPA/540/l-89/00l, Office of Emergency
and Remedial Response, Washington, DC.
u.S. Environmental Protection Agency, October 1989, "RCRA ARARs:
Focus on Closure Requirements," Directive 9234.2-04FS, Office of
Emergency and Remedial Response, Washington, DC.

U.S. Environmental Protection Agency, December 1989, "Risk
Assessment Guidance for Superfund, Volume I, Human Health
Evaluation Manual (Part A) (Interim Final)," EPA/540/1-89/002,

-------
R-3
u.s. Envi~onmental Protection Agency, January/April 1990, "Health
Effects Assessment Summary Tables, 1st and 2nd Quarters, FY-1990
(Office of Solid Waste and Emergency Response Publication No. OS-
230)," U.S. Environmental Protection Agency, Washington, DC.

U.S. Environmental Protection Agency, July 1990, "EPA Proposes
Source Control Cleanup Plan for the Old Springfield Landfill Site
(Proposed Plan)," Region I Superfund Program, Boston,
Massachusetts.
U.S. Environmental Protection Agency, July and August 1990,
"Seminars - Design and Construction. of RCRA/CERCLA Final Covers,"
(Presentations made between July 17 and August 17, 1990, various
locations), Technology Transfer CERI 90-50, Office Research arid
Development, Washington, D.C.
Versar, Inc., July 1989, "Exposure Factors Handbook (EPA 600/8-
89/043)," prepared for Office of Health and Environmental Assess-

-------
EXHIBIT 1
REsur4ES OF REHCOR PERSONNEL
"REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS.

-------
JOHN P. BLACK, P.E.
MANAGER - ENVIRONMENTAL ENGINEERING AND DESIGN
EDUCATION
M.S., 1979, Civil Engineering, State University of New York
at Buffalo
B.S., 1977, Civil Engineering, State University of New York
at Buffalo
A.A.S., 1975, Engineering Science, "Erie Community College
SPECIAL TRAINING
Environmental Laws and Regulations, Government Institute
Transport of Immiscible Fluids in the Subsurface, by J.W. Mercer,
NWWA, Baltimore, Maryland
Special Topics in Geotechnical Engineering, by D. Sangray,
Carnegie-Mellon University, Pittsburgh, Pennsylvania
Groundwater TIanspott Modeling, by G.F. Pinder, Princeton Univer-
sity, Princeton, New Jersey
Loss Prevention, ASFE, Washington, DC
REGISTRATION
Professional Engineer: Connecticut, New York, Pennsylvania,
Tennessee, Vermont, Virginia
PROFESSIONAL EXPERIENCE
1988 to Present: Mr. Black has been a member of the Environmen-
tal Engineering and Design Group at Remcor since March 1988.
Initially hired as a Project Engineer, Mr. Black has been pro-
moted to his current position as Project Manager in charge of the
Group. In this capacity, Mr. Black manages projects and the ac-
tivities of civil (geotechnical, structural, wastewater treat-
ment), environmental, and chemical engineersi draftspersonsi and
engineering support personnel.

Mr. Black's specific engineering and project discipline expertise
is related to geotechnical engineering, in particular, the behav-
ior of soil, rock, and ground water. His background is especial-
ly suited to the design and evaluation of construction activities
that involve the behavior of these media.
Descriptions of several projects that Mr. Black has played a lead
role in at Remcor are given below:
.
Feasibility study for a National Priority List (NPL) site
~~ western Pennsylvania with solvent, paint waste, and
metals contamination. .
.REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
JOHN p. BLACK
2
.
Supervised the design of the ground water collection sys-
tem for a hillside landfill in western Pennsylvania. The
ground water collection system allowed extraction of poly-
chlorinated biphenyl (PCB) contaminated oil and ground
water while limiting impacts on adjacent wetlands.

Managed environmental site assessments of six steel mills,
automotive plants, and foundries.
.
.
Managed the subsurface investigation and design of the
ground water remediatJ.on sy'stem for' a chemical plant in
the Midwest. The ground water and soil contained elevated
concentrations of cobalt, lead, nickel, potassium, and
uranium.
.
Managed the site investigation of a specialty steel plant
(including the melt shop, pickling lines, three wastewater
treatment plants, rolling mills, and four solid waste dis-
posal areas) in Ontario~ Ganada. Mr. Black directed the
activities of the 10-person field investigation team, co-
ordinated the activities of the asbestos, drilling, and
analytical laboratory subcontractors, and prepared the
site assessment report.
.
Developed closure plans for two biosludge surface impound-
ments in West Virginia. Mr. Black evaluated alternatives,
prepared the final design, and assisted the client in ob-
taining approval for closure from the West Virginia De-
partment of Natural Resources (WVDNR) and the U.S. Envi-
ronmental Protection Agency (EPA).

Provided civil and geotechnical engineering support for
the development of an Operable Unit approach to remedia-
tion of a Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA) site in the Northeast.
The constituents of concern at the site included volatile
organic compounds (VOCs), acids, metals, and PCBs. The
first operable unit designed included ground water collec-
tion and treatment.
.
.
Provided input to the development of realistic solutions
to the closure and/or remediation of PCB, toxic metals,
and VOC-contaminated facilities.
1980 to 1988: Prior to joining Remcor, Mr. Black was employed by
D'Appolonia Consulting Engineers, Inc. (D'Appolonia) and ~ad been
involved in projects ranging from slope stabilization projects to
the design of a SOO,OOO-cubic meter underground storage facility.
The main areas of Mr. Black's expertise have been associated with
the analysis and design of structures that are related to the en-
gineering behavior of soil and rQck., hydrologic and hydraulic
- .
"REALlSnC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
JOHN p. BLACK
3
analysis of civil engineering structure, and the design and uti-
lization of underground space. Projects that Mr. Black had been
involved with, under the following categories, while with D'Appo-
lonia include:
.
Water Resources:

- Planning and development of construction specifications
for the excavation and closure of two mill sludge la-
goons on the Ohio River.

- Ground water modeling fOr paper sludge lagoons near
Green Bay, Wisconsin. These models were used to design
a slurry wall/gradient control system to limit migration
of chlorides.
- Layout and evaluation of conceptual hydroelectric power
facilities on the Betsiboka River in Ambodiroka,
Madagascar.

- Evaluation of the effects of long-term dewatering on ad-
jacent structures, of historical significance, for the
Theater District project in Milwaukee, Wisconsin.
- Evaluation of the consequences of failure of anyone, or
a combination of, three dams in the Hoosier National
Forest, Indiana.
.
Slope Stabilization and Remediation:

- Subsurface exploration, design, and construction docu-
ment preparation for the remediation of a 20-acre land-
slide, which moved 1,300 feet of the Conrail Railroad
tracks into the Ohio River.
- Stabilization of a hillside with approximately 100 pri-
vate residences in Wheeling, West Virginia. This proj-
ect involved stabilizing the hillside, four roadways,
and approximately 100 houses with minimum disruption to
normal activities.
- Design of cut-and-fill slopes for the development of a
mine haul road on an unstable hillside in Greene County,
Pennsylvania and the proposed SRC II Facility in Morgan-
town, West Virginia.

- Evaluation and redesign of a mine spoil disposal facil-
i ty failure in Belcher, West Virginia. the failure of
this facility resulted in spoil materials "flowing" into
homes more than 2,500 feet from the initial disposal
site.
.
"REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
JOHN P. BLACK
4
.
Mine Waste Disposal:

- Development and consultation during implementation of an
alternative coal refuse disposal plan for existing coal
refuse disposal embankments, which were operating inef-
ficiently. The alternative plan, now in use, included
the development of a large dam built of coal refuse to
impound a slurry of fine coal processing waste.

- Evaluation of the mining sequence and resulting spoil
pile stabilization requirements for an oil shale mining
project in Queensland, Australia.
.
- Design of surface drainage and sediment control systems
including dams and drainage channels for several coal
refuse disposal facilities in the Appalachian region.

Underground Space:

- Layout and development of the facility design and exca-
vation method for a SOO,OOO-cubic meter underground
storage facility in the Middle East.
- Development, supervision, and report preparation for a
rock testing program conducted within the outlet tunnel
of the John W. Flannagan Dam near Haysi, Virginia.

- Development of remediation plans for a site on which
leakage from underground storage tanks had created the
potential for off-site ground water contamination.
1979 to 1980: Prior to joining D'Appo10nia, Mr. Black was em-
ployed by Delon Hampton and Associates, Chartered of Silver
Spring, Maryland. De10n Hampton and Associates is a consulting
engineering firm that is involved mainly in transportation-
related projects such as tunnels, airports, bridges, and plan-
ning. Mr. Black was involved in geotechnical research, design,
and recommendations in support of the structural design group.
The scope of this work included:
.
Research into the use of geotechnical instrumentation for
design and construction of both soft ground and rock tun-
nels and on the influence of geotechnical parameters in
tunnel lining design. Various methods of improving tunnel
design and construction through improved preconstruction
geotechnical exploration were developed.

Site investigation, analysis, and design of three projects
at Washington National Airport.
.
.
"REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
JOHN p. BLACK
5
1977 to 1979: Dur ing the completion of his Master of Science
Degree, Mr. Black worked for Faculty Technical Consultants (FTC)
in Buffalo, New York. His responsibilities at FTC included the
calibration, installation, and monitoring of approximately 100
instruments utilized to evaluate the behavior of a long-span cor-
rugated metal culvert in Bucks County, Pennsylvania. The field
testing for this project included plate load tests, deformation,
and stress measurements.
PROFESSIONAL AFFILIATIONS
Chi Epsilon, National Honorary Civil Engineering Fraternity
Tau Beta Pi, National Engineering Honors Association
PUBLICATIONS
Hampton, D., J.S. Jin, and J.P. Black,
Ground Parameters for Analysis of Tunnels:
and Construction," Report FHWA/RD-80/0l4.
1980, "Representative
Vol. 3, Tunnel Design
..
"REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"
E08010

-------
LEO M. BRAUSCB
CHIEF OPERATING OFFICER
EDUCATION
M.S., 1976, Civil and Environmental Engineering,
University of Cincinnati
B.S.C.E., 1975, Civil and Environmental Engineering,
University of Cincinnati
.
REGISTRATION
Professional Engineer:
Pennsylvania
Mississippi, New Mexico, Ohio,
PROFESSIONAL EXPERIENCE
1985 to Present: As Chief Operating Officer, and previously as
Vice President of Engineering and Project Development, Mr.
Brausch provides senior management of Remcor' s technical and
project management staff. In keeping with Remcor' s c1ient-
oriented, hands-on approach to problem solving, Mr. Brausch also
serves as the senior technical director and principal-in-charge
of integrated investigation, engineering, and remediation proj-
ects. In this position, he serves a variety of technical roles,
including the following:
.
Technical consultant in application of remedial
technologies

Evaluator of contaminant fate and transport data
.
.
Client liaison/representation before regulatory agencies.
Mr. Brausch's key technical contributions are focused on the ex-
amination of site contamination data leading to the identifica-
tion, evaluation, and conceptual design of cost-effective reme-
dial measures. These evaluations have been applied to many types
of hazardous waste projects, including the following:
.
Closure of hazardous waste land disposal units (e.g., sur-
face impoundments, landfills) under Resource Conservation
and Recovery Act (RCRA) regulations

Corrective action at solid waste management units (SWMUs)
subject to continuing releases provisions of RCRA, as
amended
.
..
-,rEALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
LEO M. BRAUSCH
2
.
Removal actions and final remediation of waste sites under
the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA)
.
Envi ronmental liability assessments associated wi th the
transfer of contaminated industrial real estate
Industrial facility decontamination, including polychlori-
nated biphenyl (PCB) decontamination under the Toxic Sub-
stances Control Act (TSCA) PCB Spills Cleanup Policy.

This work has been performed for p~ivate-sector clients in steel,
chemical, and manufacturing industries. Technologies applied to
site cleanups generally focus on in-situ or on-site treatment of
wastes and soil and ground water contamination, including biore-
mediation, soil vapor extraction, in-situ chemical fixation, and
waste stabilization.
.
Mr. Brausch has also been the project director and/or manager re-
sponsible for technical quality, budget, and schedule for major
turnkey hazardous waste projects undertaken by Remcor. Descrip-
tions of representative projects follow:
.
Investigation and subsequent cleanup of a gO-acre indus-
trial complex in western Pennsylvania. This project in-
volved the - assessment of contamination and design and
implementation of remedial measures associated with: PCB
decontamination of plant buildings, equipment, and process
sewers; closure of a former PCB waste disposal area; de-
contamination and closure of electroplating facilities;
and plant-wide removal of aSbestos-containing materials
( ACM) .
.
RCRA closure plan development and implementation for fi~e
surface impoundments containing 14,000 cubic yards (yd )
of electroplating sludge at a site in Mississippi. Clo-
sure involved on-site dewatering of the sludge, in-situ
containment of contaminated soils, and ground water recov-
ery/treatment. In addition, potential continuing releases
from on-site SWMUs were investigated, and corrective mea-
sures were designed and implemented.

Under the requirements of a CERCLA Section 106 Order, sam-
pling and analysis of PCB concentrations in plant facili-
ties, surface waters, and sediment associated with leakage
from a heat exchanger that led......t:o contamination of off-
site drainageways, in eastern Pennsylvania. The investi-
gation results were used to develop both on-site decontam-
ination and off-site cleanup plans that were subsequently
implemented under CERCLA Orders. The on-site decontamina-
"tion included cleaning, sc_rifying concrete surfaces, and
encapsulation; the off-site remov'al involved excavation
.
"'REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMSw

-------
LEO M. BRAUSCH
3
and off-site disposal of PCB-contaminated stream sediments
with strict erosion and sedimentation controls.
Performance of the remedial investigation/feasibility
study (RI/FS) and concurrent design/construction of a
ground water treatment system at a site in eastern Penn-
sylvania. Ground water treatment employs two large air
strippers in series to remove trichloroethylene (TCE) and
other chlorinated aliphatics for a pumpage rate of approx-
imately 300 gallons per minute. The treatment system ef-
fluent can either be discharged to the municipal water
supply system or to a small stream when water demand is
low. The pumping and treatment of ground water addresses
the need for adequate local water supply and effectively
controls and recovers the plume of contamination.

In addition to technical contributions and project management,
much of Mr. Brausch's work involves representation of clients in
regulatory agency negotiations and in intercompany negotiations
involving real estate transactions. Mr. Brausch has served as an
expert witness in a major civil action involving PCB contamina-
tion at four facilities in three states. Mr. Brausch served as
the lead technical role for Remcor in the conduct of site stud-
ies, including a comprehensive subsurface evaluation of PCB and
TCE contamination at one of the facility sites in Tennessee. At
trial, Mr. Brausch testified relative to contamination assessment
methods, decontamination procedures and costs, and PCB and TCE
transport mechanisms and pathways.
.
1980 to 1985: Mr. Brausch served as the Manager of Project De-
velopment for International Technology Corporation in Pittsburgh,
Pennsylvania (formerly D' Appolonia Waste Management Services).
His primary role was in the planning and development of remedial
response programs for formerly utilized waste disposal sites.
Representative experiences included the following:
.
Project manager for the investigation of the degree and
extent of PCB contamination at seven manufacturing facili-
ties in five states. This work included development and
execution of investigation programs, evaluation of alter-
native decontamination technologies, and preparation of
detailed decontamination plans and cost estimates.

Project manager for the preparation of a RCRA closure plan
at a formerly used secondary lead smelter site in Florida.
The project involved a comprehensive contamination survey,
subsurface exploration, and ground water monitoring. Mr.
Brausch headed the design team for waste removal, facility
decontamination, and ground water treatment aspects of the
closure.
.
.
"REALISTIC SOLUTIONS FOR HAZAROOUS WASTE PR08LEMS"

-------
LEO M. ~RAUSCH
4
.
Project director for preparation of a RCRA cj-osure plan
for two lagoons (containing nearly 100,000 yd ) of mixed
organic and inorganic sludges) at a plant site in southern
Ohio. The closure plan called for dewatering and physical
stabili~ation of sludges preparatory to on-site
containment.
In addition to such assignments, Mr. Brausch served as in-house
consultant on health and safety programs; air quality monitoring
during waste site cleanup; and waste analysis, manifesting,
transportation, and disposal.

1978 to 1980: Mr. Brausch served as the Lead Engineer, Environ-
mental Issues, for the environmental and safety analysis of the
Waste Isolation Pilot Plant {WIPP} proposed for a site east of
Carlsbad. New Mexico. This position involved coordinating and
leading investigations attendant to all environmental permi ts,
approvals, and compliances required for this radioactive waste
storage/disposal facility. .
1976 to 1978: With D'Appolonia Consulting Engineers, Inc., Mr.
Brausch served as a project leader and technical contributor on
environmental investigations and engineering designs. His prin-
cipal involvement was in environmental permitting and the design
of pollution control facilities. Representative technical tasks
included air quality and meteorological monitoring, preparation
of emission inventories, and evaluations of control technologies
for new-source air quality permitting. Mr. Brausch also prepared
the process, hydraulic, and structural design of industrial
wastewater treatment facilities. Key issues in the treatment
schemes included the design and economic analysis of alternative
treatment schemes (e.g., precipitation/clarification, ion ex-
change, biological); conveyance and disposal of metal hydroxide
and organic sludges: and plant start-up, operation, and
maintenance.
1972 to 1976: Prior to receiving his degrees, Mr. Brausch worked
part time as an engineer ing technician in wastewater treatment
design, highway planning, and surveying.
PUBLICATIONS AND PRESENTATIONS
Nakles, D.V. and L.K. Brausch, 1990, "Bioremediation of Coke By-
Product Plant Sites," Paper No. 90-49.3, 83rd Annual Meeting of
the Air and Waste Management Association, June 25 through 29,
Pittsburgh, Pennsylvania.

Grantz, J.A. and L.M. Brausch, 1988, "Investigation, Remediation
and Sale of Armco's Former Ambridge Seamless Steel Pipemaking Fa-
cility," ~er No. 88-39.4, 8lst Annual Meeting of the Air Pollu-
tion Control Association, June 19.through 24, Dallas, Texas.
'. .
-REALISTIC SOLUTIONS FOR HAZAROOUS WASTE PROBLEMS"

-------
LEO M. BRAUSCH
5
Husak, A:D., L.M. Brausch, and B.P. Bundy, 1985, "Recent Experi-
ences in Waste Si te Remedial Action," Symposium Proceedings,
American Institute of Chemical Engineers 1985 Spring National
Meeting, March 25 through 28, Houston, Texas.

Brausch, L.M. and J.S. Lewis, Jr., 1984, "Case Study: Leachate
Containment System Installation, Lipari Landfill, Pitman, New
Jersey," Super fund Update: Cleanup Lessons Learned, symposium
sponsored by the Center for Energy and Environmental Management,
May 21 and 22, Denver, Colorado.
Brausch, L.M., 1984, "Advances in "Ground Water Treatment Technol-
ogy," General Electric Environmental Protection Seminar, Apr~l 25
through 27, Philadelphia, Pennsylvania.
Brausch, L.M., 1983, "Implementation of Remedial Action
Enterprise Avenue Site," Proceedings, Conference on the
of Solid, Liquid, and Hazardous Wastes, American Society
Engineers, April 28 and 29, Bethlehem, Pennsylvania.

Brausch, L.M., 1982, "Siting and Design of Hazardous Waste Land-
fills," Hazardous Wastes Generation and Management Conference,
June 9 and 10, Pittsburgh, pennsylvania.
Program,
Disposal
of Civil
Brausch, L.M., 1982, "Design and Construction of Landfills for
Hazardous Wastes," International Conference on Technology and
Technology Exchange, May 3 through 6, Pittsburgh, Pennsylvania.

Hohmann, G.L. and L.M. Brausch, 1981, "Environmental Impact and
Protection for the Waste Isolation Pilot plant (WIPP)," Waste
Management '81, American Nuclear Society Topical Meeting, Tucson,
Arizona.
Laushey, L.M. and L.M. Brausch, 1979, "The Geometrics of Rill
Formation on Hillsides," Proceedings of the XVIII Congress of the
IAHR, International Associated for Hydraulic Research, Caligari,
Italy.
Brausch, L.M., 1976, "Observations on Rill Pattern Development,"
Master's Thesis, University of Cincinnati, Cincinnati, Ohio.
.
E09050.

1;1~~. ! ! !

-------
JOHN A. GEORGE
DIRECTOR - SITE CHARACTERIZATION AND ASSESSMENT
EDUCATION
M.S., 1976, Terrestrial Ecology, Clarion University of
Pennsylvania
B.S., 1975, Biology, Clarion University of Pennsylvania
PROFESSIONAL EXPERIENCE
1987 to Present: Mr. George joined Remcor in 1987. He currently
serves as Director of the Site Characterization and Assessment
Section, responsible for project scheduling, budgetary control,
resource allocation, technical direction, review of deliverables,
and client liaison. His Section is responsible for site investi-
gations, definition of the extent of contamination in environmen-
tal media, evaluations of potential risks and remedial actions,
particularly with reference to ground water.

Mr. George recently directed the completion of a focused feasi-
bility study (FFS) of potential source control measures at a for-
mer municipal and industr ial waste landfill in Vermont. This
National Priorities List (NPL) site was the subject of extensive
agency investigation since 1984; Remcor has worked with poten-
tially responsible parties (PRPs) to coordinate the FFS, which
included a major field investigation of the site hydrogeology.
Mr. George also managed a remedial investigation/feasibility
study (RI/FS) focusing on volatile organic ground water contami-
nation at an NPL site. near Allentown, Pennsylvania. Both of
these efforts were conducted by Remcor on behalf of the PRPs and
are currently in the remedial design/remedial action (RD/RA)
phase, again led by Remcor. This work has involved extensive
efforts on Remcor's part to work with the PRPs to negotiate the
respective Consent Agreements for RD/RA.
Mr. George has participated in numerous site characterization
efforts. Included among these are studies of waste management
units at electronics components manufacturing facilities and
abandoned steelmaking facilities, and wastewater settling lagoons
at a primary aluminum reduction facility. He was also one of the
principal authors of a Remcor study of potential effects of the
U.8. Environmental Protection Agency (EPA) Resource Conservation
and Recovery Act (RCRA) Corrective Action Program (CAP) on the
domestic steel industry. Mr. George continues to lead Remcor's
efforts to provide support to the American Iron and Steel Insti-
tute (AISI) in review of the potential cost impacts of the RCRA
CAP.
.
-REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS.

-------
JOHN A. GEORGE
2
1982 to 1981: Mr. George served as a Project Manager in the
Waste Management Services Division of NUS Corporation (NUS) in
Pittsburgh, Pennsylvania. During much of this period NUS was the
prime contractor to the EPA for Remedial Planning and Field In-
vestigation Team (FIT) support for the Superfund Program. Mr.
George participated in several RI/FSs at Comprehensive Environ-
mental Response, Compensation, and Liability Act (CERCLA) sites,
both technically and in a managerial role. The following pro-
vides a representative listing of project experience:
.
Grove1and Wells Site, Groveland, Massachusetts - Pro 'ect
Manager - RI FS for a 820-acre mun1.cipal wellf1.eld 1.n
northeastern Massachusetts contaminated with volatile
organics, principally trichloroethylene (TCE).

Charles Geor e Land Reclamation Trust Landfill Site,
Tyngsboro, Massachusetts - ProJect Manager - RI FS for a
70-acre municipal and industrial waste landfill in north-
eastern Massachusetts overlying contaminated fractured
bedrock aquifer tapped by domestic wells: total landfill
volume approximately four million cubic yards.
.
.
Cannon Engineering/Plymouth Site, Plymouth, Massachusetts
- Technical Lead - Wetlands and floodplain assessment in
support of the FS.
.
Drake Chemical Site, Lock Haven, Pennsylvania - Technical
Lead - Assessment of vegetative stress due to discharge of
herbicides from a former manufacturing facility.

Sullivan's Led e Site, New Bedford, Massachusetts- Pro'ect
Manager - RI FS for volatile organ1.c polychlor inate bi-
phenyl/metals disposal in abandoned quarry pits.
.
.
Leetown Pesticide Site, Leetown, West Virginia - Project
Manager:

- RI/FS for evaluation of a 2.S-square mile watershed con-
taminated through indiscriminant disposal of pesticides
and the use of agrichemicals.

- Bench-scale treatability study of microbial degradation
of pesticides by indigenous soil microbes.
1980 to 1982: Mr. George served as Director of Mining Services
with Penn Environmental Consultants (acquired by NUS in 1981),
supervising a staff that provided complete engineering and per-
mitting services to several moderate-sized Appalachian surface
mining interests.
"
-REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"

-------
JOHN A. GEORGE
3
.
1979 to 1980: Mr. George served as a principal investigator with
Michael Baker Corporation, Beaver, Pennsylvania. His responsi-
bilities involved environmental assessments for utility line con-
struction and development of environmental baseline data for sur-
face affects on underground mining operations.
1977 to 1979: Mr. George served as Supervisor of the Land Sta-
bilization and Reclamation Program (Surface Mining Reclamation)
at Belmont Technical College, St. Clairsville, Ohio.
PREVIOUS PROFESSIONAL AFFILIATIONS
American Chemistry Society
American Institute of Biological Sciences
Pennsylvania Mining Professionals (Vice President,
Soil Conservation Society of America
1981/1982)
PUBLICATIONS
George, J .A. and L.A. Szuhay, 1988, "Implications of the RCRA
Continuing Releases/Corrective Action Program Regulations for the
Iron and Steel Industry," presented at the 8lst Annual Meeting of
the Air Pollution Control Association, Dallas, Texas.
Hubbard, A.E., J.A. George, R. Hubbard, and W. Hagel, 1986,
"Quantitative Risk Assessment as the Basis for Definition of Ex-
tent of Remedial Action at the Leetown Pesticide Superfund Site,"
Presented at the HMCRI Superfund '86 Conference, Washington, DC.

George, J.A., 1982, "Erosion and Sedimentation Control Alterna-
tives - Surface Mining in Northern Appalachia," presented at the
Fifth Annual Meeting of the Water Pollution Control Association
of Pennsylvania, Pittsburgh, Pennsylvania.
George, J.A., 1976, Seasonal Weight and Activity Relationships in
a Free-Rangin~ Population of .the Eastern Chipmunk (Tamias stri-
atus) Rodentla: Sciuridae, Master's Thesis, Clarion State
College.
..
-REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS"
E090S0

-------
PETER V. SWALLOW
PROJECT BYDROGEOLOGIST
EDUCATION
B.S., 1984, Geology, George Mason University
SPECIAL TRAINING
Annual Health and Safety Refresher"Course, 1990
Waste Site Supervisor/Manager Training Course, 1987 ,
Waste Site Worker Protection Course by Hygiene, Safety and
Training Company, 1987
Safety at Hazardous Waste Sites by National Water Well
Association (NWWA), 1985
24-Hour Course on Ground Water Geochemistry, NWWA, 1989
40-Hour Course on Analytical Aquifer Analysis Techniques, NWWA,
1987
Rutgers University Course on Soils and Site Evaluation, 1986
U.S. Environmental Protection Agency (EPA) Site Evaluation
Seminar, 1986
PROFESSIONAL EXPERIENCE
1987 to Present: Mr. Swallow joined Remcor as a staff Geologist
in 1987 and has served as a Project Geologist for Remcor since
1989. In this position, Mr. Swallow is responsible for develop-
ing and implementing ground water monitoring and extraction pro-
grams as well as a variety of contamination investigations re-
sulting from hazardous waste disposal practices. Among these
investigations are remedial investigations/feasibility studies
(RI/FS) and remedial design and monitoring studies under the Com-
prehensive Environmental Response, Compensation, and Liability
Act (CERCLA) and preliminary assessments/site investigations for
continuing releases under the Resource Conservation and Recovery
Act (RCRA). Recent tasks include:
.
Site coordinator and project hydrogeologist for a 10-man,
5-month field investigation for an RI/FS under CERCLA in
southern Vermont, which included monitoring wells, extrac-
tion wells, borings, test pits, multi-well pumping tests
and injection tests, single well tests, temporary treat-
ment system construction, and operation.
.
Seismic
Carolina.
and
electromagnetic
investigation
in
South
.
Environmental oversight for 5-month decommissioning and
demolition of a coking facility and 10-mile gas line in
southwestern Ohio.
.. .
-REALlsnc SOLUTIONS FOR HAZAROOUS WASTE PROBLEMS.

-------
PETER V. SWALLOW"
2
.
Project hydrogeologist for an
extraction monitoring program
Pennsylvania.
RI/FS and ground water
under CERCLA in eastern
.
Assisted in the conduct and evaluation of
pumping tests in Charles town, West Virginia.

Assisted in several multi-site environmental audits in-
cluding performing test pit, boring, and monitoring well
programs.
multi-well
.
.
Assisted in the Superfund Amendments and Reauthorization
Act (SARA) Title III audit and consultation for an e~plo-
sives manufacturer in West Virginia.
.
Contaminated soil/ground water investigation for construc-
tion projects in Ohio and West Virginia.
.
Assisting in reduction and evaluation of pump test data
for a RI of pickling wastes in Mississippi.

Supervision of the drilling of test borings and installa-
tion of many monitoring wells for an RI/FS under CERCLA in
eastern Pennsylvania.
.
1985 to 1987: Mr. Swallow was employed as a Geologist and Micro-
computer Specialist for Geonics, Inc. in Clinton, New Jersey. In
this role he was responsible for or aided in a diversity of geo-
logic, hydrogeologic, and geophysical investigations. Projects
included: Environmental Cleanup Responsibility Act (ECRA) re-
views: ground water contamination studies: environmental liabil-
ity assessments: waste treatment and disposal studies: and water
supply investigations. In the process, Mr. Swallow designed and
supervised the construction of various ground water monitoring
programs, logged test borings and test pits: directed water and
soil sampling programs, and performed electromagnetic, magnetic,
and seismic geophysical surveys. Mr. Swallow also initiated and
directed. a restructuring of the firms' microcomputer system.

1985: Mr. Swallow served as an underground utili ty locating
technician for So-Deep, Inc. in Manassis, Virginia. This posi-
tion required the use and interpretation of electromagnetic and
sonic detection equipment. Logging and surveying test pits were
also performed.
PROFESSIONAL AFFILIATION
Association of Ground Water Scientists and Engineers (Division of
the NWWA)
.
"REALISTIC SOLUTIONS FOR HAZARDOUS WASTE PROBLEMS.
E08010

-------
EXHIBIT II
DESCRIPTION OF CONTAMINANT DESORPTION MODEL
WASTE AREA 2
OLD SPRINGFIELD LANDFILL SITE

-------
EXHIBIT II

DESCRIPTION OF CONTAMINANT DESORPTION MODEL
WASTE AREA 2
OLD SPRINGFIELD LANDFILL SITE
SPRINGFIELD, VERMONT
In the focused feasibility study (FFS) for the Old Springfield
Site (Remcor, June 1990), analytica~ data from the sampling of
Seep LSE-04 were presented.
These data evidence a marked de-
crease in concentrations of volatile organic compounds (VOCs) in
this seep since the time of its initial sampling in January 1985
(FFS, Section 2.2.3.2, page 2-18).
The six sets of sampling data
available for Seep LSE-04 were subjected to nonlinear regression
analysis to develop a m~thematical relationship reflecting the
depletion of the sources of VOC contamination to ground water in
Waste Area 2 (FFS, Section 2.5.1.5, page 2-85).
The attached
Figure 1 is a graph (on semi-logarithmic scale) showing total
VOCs for the various sampling events and the regression analysis
relationship of total VOC concentration versus time.
Figure 1 also presents the results of modeling desorption of VOCs
from the solid waste in Waste Area 2 and into the water reflected
by Seep LSE-04.
This desorption modeling was performed by Remcor
as a means to confirm the reasonableness of the source depletion
model (i.e., regression analysis equation) presented in the FFS.
As indicated in the attached Figure 1, there is good agreement
between the results of the regression analysis and the desorption

-------
2
in VOC concentrations observed over the past five years and
predict very low total VOC levels (i.e., total VOCs less than
5 micrograms per liter [~g/l]) in the next few years.
It is
significant to note that the most recent sampling of Seep LSE-04,
by the Vermont Agency for Natural Resources in May 1990, showed
compliance with current and propos~d maximum contaminant levels
(MCLs) for VOCs, except for perchloroethylene (PCE).
The re-
ported PCE concentration from this sampling was 6 ~g/l versus the
MCL of 5 ~g/l.
This exhibit describes the desorption model used by Remcor in the
evaluation.
In this description, frequent reference is made to a
recent technical article by Olsen and Davis (1990) that summa-
rizes much of the current literature on the factors affecting the
migration rates and concentrations of contaminants in ground
water.
Overview
The desorption model used by Remcor in this evaluation describes
the "flushing" of the waste in Waste Area 2.
This flushing oc-
curs as rainwater (and, to a very limited extent, lateral ground
water flow) infiltrates the waste.
As this flushing occurs, con-
taminants present in the solid waste leach into the uncontami-
nated rainwater or upgradient ground water.
The resulting leach-
ate subsequently travels to Seep LSE-04 where it is discharged as
contaminated seep flow.
The quantity of contaminants present in
.

-------
3
the solid waste is correspondingly decreased by the amount dis-
solved into the water.
The rate at which desorption occurs de-
pends on a number of variables, including the physicochemical
properties of the waste matrix, the specific chemical partition-
ing characteristics of the contaminant(s) of concern, and the
rate of water infiltration.
The desorption modeling for Waste Area 2 involves the following
initial steps:
1.
Describing the physical and chemical characteristics of
Waste Area 2
2.
Defining the water flow rate through Waste Area 2 and the
initial VOC concentration in the leachate from this area
3.
Selecting a representative VOC to simplify calculations
and defining the chemical adsorption and biodegradation
characteristics of this compound.
Based on these input a series of sequential calculations are made
for each time step:
1.
Total accumulated time
2.
Contaminant mass in solid waste at the beginning of the
time step

Contaminant mass removed from the solid waste during the
time step by flushing with water
3.
4.
Contaminant mass remaining after flushing during the time
step
5.
Contaminant mass removed from the solid waste during the
time step by biodegradation
6.
Resultant contaminant concentration in solid media
7. ..Resultant contaminant conce_ntration in leachate.

-------
4
These sequential calculations are repeated, by incremental time
step, until the VOCs initially present in the solid media are
"exhausted."
Physical and Chemical Characteristics of Waste Area 2
In modeling contaminant desorption,. the following physicochemical
properties of the waste matrix must be determined or estimated
(Olsen and Davis, 1990):
.
.
Fraction of organic carbon in the
Bulk unit weight (bulk density)
Porosity of the waste formation
Gross volume of waste.
waste
.
.
Table 11-1 summarizes these data for Waste Area 2 at the Old
Springfield site.
As indicated in Table II-I, the values as-
signed to these input variables were determined primarily from
data developed during the FFS.
Water Flow Conditions
The rate at which water enters Waste Area 2 is estimated from the
site hydrologic model developed in the FFS (Section 2.5, page
2-77).
On an annual average basis, the total water inflow to the
waste is estimated as follows (FFS, Section 2.5.2.3, page 2-95):
.
.
Rainwater infiltration - 1,200 gallons per day (gpd)
Lateral ground water flow - 630 gpd
Total - 1,830 gpd.
.

-------
5
The "initial" total VOC concentration at Seep LSE-04 corresponds
to the measurements made by NUS Corporation in January 1985 in
which 37,946 ~g/t total VOCs were reported (ICF, 1988c, Figure
4-14).
Contaminant Properties
The rates of flushing of contaminants from solid media into water
are compound-specific and are dependent on the molecular weight,
solubility, and other intrinsic properties of each compound.
For
ease in modeling, a single, representative contaminant is typi-
cally selected.
In modeling Waste Area 2 at the Old Springfield
Site, trichloroethylene (TCE) was selected as the representative
VOC.
TCE and its degradation by-products (e.g., dichloroethyl-
ene, vinyl chloride) constitute the chlorinated ethenes that are
the principal threat to ground water at the Old Springfield Site
and represented more than 50 percent of the total VOCs in the
initial sampling of Seep LSE-04.
In a two-phased system of water and solid media, TCE will both
dissolve in the water and be adsorbed into the solid media.
The
overall distribution of contaminant concentrations between that
dissolved in water and that adsorbed into solids can be described
in terms of a retardation coefficient (Kd) as described in Olsen
and Davis (1990).
The retardation coefficient used in the de-
sorption modeling at Waste Area 2 was calculated for adsorption
of the TCE onto the organic carbon pre~ent.in the waste.

-------
6
adsorption is quantified by the organic carbon partitioning coef-
ficient (Koc), which defines the milligrams (mg) of adsorbed TCE
per kilogram (kg) of organic carbon present in the waste divided
by the concentrations of TCE in the waste (milligrams per liter
[mg/l]).
Koc is a compound-specific property and is equal to
138 liters/kilogram (l/kg) for TCE jTable II-I).
In modeling
Waste Area 2, adsorption of TCE into mineral surfaces was not
considered; this adsorption accounts for a very minor portion of
the total adsorption of the TCE onto solid media (Olsen and
Davis, 1990).
The retardation coefficient calculated in the desorption model
for Waste Area 2 at the Old Springfield Site is 0.77 l/kg.
This
value-is calculated by multiplying the fraction of organic carbon
(foe) by the organic carbon adsorption coefficient (Koc).
The
initial TCE concentration in the solid waste is calculated by
multiplying the initial waterborne concentration (37,946 ~g/l)
by the retardation coefficient (i.e., 37,946 ~g/l x 0.77 l/kg =
29,233 ~g/kg).
The initial mass of TCE in the solid waste is
calculated by multiplying this concentration by the gross mass
of the solid waste (i.e., 29,233 ~g/kg x 4.36 x 106 kg =
1.28 x 1011 ~g).
In addition to water-solids partitioning, the biodegradation
properties of the contaminant of concern must also be defined.

-------
7
terms of the biodegradation half life (th)'
This half-life de-
fines the time frame over which 50 percent of the mass of contam-
inant in the solid medium could be expected to be biodegraded.
Biodegradation of the TCE can lead to the formation of dichloro-
ethylene compounds, which, in turn, degrade to vinyl chloride.
The overall length of this process is highly variable and depends
on the nature of the waste matrix, the nature of indigenous
microorganisms that could use these chlorinated ethenes as a food
source, and the relative availability of other nutrients.
Biode-
gradation half-lives for TCE and dichloroethylene compounds have
been reported to be less than one year (in parallel, not series);
biodegradation rates for vinyl chloride have been quantified but
are believed to be significantly longer.
These data have been
summarized in Olsen and Davis (1990).
For desorption modeling
for Waste Area 2, a biodegradation half-life of 25 years was as-
sumed.
This value is sufficiently long so as to make biodegrada-
tion only a minor contributor to the overall depletion of TCE
from the solid waste.
Desorption Calculations by Time Steps
With these described input data, TCE desorption from Waste Area 2
was calculated in a series of time steps (Table II-2).
Each time
step corresponded to one "pore volume", i.e., the time required
for the inflowing water to displace a volume equal to the volume
of the pore space in the waste (Table II-I).
A pore volume is

-------
8
calculated by multiplying the gross volume of the waste times the
.
porosity of the waste.
In each time step, the TCE mass in the solid medium is reduced by
the mass transferred to one pore volume of water.
Mathematical-
ly, che quantity of TCE transferred to the water is calculated in
three steps:
2.
Multiplying the retardation coefficient times the concen-
tration of TCE in the solid at the beginning of the time
step to determine the TCE concentration in the water
serving as the flushing fluid.

Converting the quantity calculated in Step 1 to mass
(i.e., multiplying concentration times volume of pore
water).
1.
3.
Subtracting the mass calculated in Step 2 from the mass
of TCE in the solid medium at the beginning of the time
step.
The remaining TCE in the solid medium is then further reduced in
the time step by calculating the reduction due to biodegradation.
As described in Olsen and Davis (1990), this biodegradation is
calculated as a "first-order" exponential depletion.
After subtracting out the TCE in the solid medium lost to biode-
gradation, the remaining concentration of TCE in the solid medium
is calculated by dividing the remaining mass of the TCE by the
total mass of the waste.
The resultant waterborne TCE concentra-
tion at the end of the time step is then calculated by dividing
the concentration in the solid by the retardation coefficient.
..

-------
9
Further reductions by time step are then calculated using this
same procedure.
The data points shown in the attached Figure 1
show the total VOC concentration in water calculated (as TCE) at
various times after the initial (January 1985) sampling.

-------
TABLE 1
SUMMARY OF INPUT DATA
STABILITY ANALYSIS
WASTE AREA 3 OUTSLOPES(l)
    SATURATED ANGLE OF
  TOTAL UNIT  UNIT INTERNAr
  WEIGHT(3)  WEIGHT FRICTION 4)
M..~TERIAL(2) (pcf)  (pcf) (degrees)
Fill (existing)  106  115 35
Till (sand and silt) 106 .. 115 35
Waste area  75  105 35
(waste and sand)     
Weathered bedrock  150  162 40
Alluvial sand and gravel 112  130 34
Gravel Seepage     
Collection Zone  120  140 45
(l)Values are estimated from physical descTiptions of materials
and published information on typical values, for example,
see Teng (1962).

(2)Cap placement simulated by adding a vertical loading of 770
pounds per square foot (psf) to the plateau.
(3)"pcf" - pounds per cubic foot.

-------
::"':::J:',::':''''
. . ... . ... ." . . . . . . . ...
. ."'. '. "."'...".". ". .." ',',"'.., ..",',..',,"
. . . "'.." ',."',".. ,"..".. ...".'. . ',',",' ". .
.',,'p ARAME'l'~it?}::::::i:~{::\/)::::::?)({(
TABLE 11-1
SUMMARY OF INPUT DATA
CONTAMINANT DESORPTION MODEL
WASTE AREA 2
, ,
, ,
(UNITS
. . . ,
".,,' DESCRIPTION/BASis:::::
, ,
'VALUE ":
Contaminant Descriotion (Trichloroethylene)
octanol-water partion coefficient (Kow) l/kg
Organic carbon partition coefficient (Koc) l/kg
Geomedia Descriotion
Fraction organic carbon (foe)
Bulk unit weight (p)
poro8ity (n)
Surface are, coefficient (SA)
Retardation.coefficient (Kd)
Biodeqradation Constant
Biodegredation half-life (th)
Fir8t order k for biodegradation
Physical Descriotion/Source Size
Volume of 801id material (V8)
Ma88 of 801id material (M8)
Volume of pore liquid (Pore volume, pv)
Initial
Initial
Ini tial
Ini tial
water concentration
contaminant ma88 in water
801id8 concentration
contaminant ma88 in 801id
material
Clean water flow rate through geomedia
Time associated with one pv
195
138
Compound-8pecific property
Compound-8pecific property
gIg 0.0056 E8timated from 8ite data for 
  indu8trial waste/MSW/80il mix 
g/ml 0.89 Equivalent to 1500 Ib8/cy for 
  indu8trial wa8te/MSW/8oil mix 
ml/ml 0.41 Calculated from p value with 
  particle den8ity of 2 g/ml 
m~2/g 0 Not included in calculation due .
  to high foc and wa8te/8oil mix 
l/kg 0.77 Calculated value 
year8
1/yr
25
0.028
E8timate for TCE - DCE - VC
Calculated value
yd~3 6,400 FFS data  
kg 4.36E+06 V8 x p (convert unit8) 
liter8 2.01E+06 V8 x n (convert unit8) 
ug/l 37,946 RI data  
ug 7.61E+10 pv x Water Concentration
ug/kg 29,333 Water concentration x Kd
ug 1. 28E+11 Solid8 Concentration x Ma88
gpd 1,830 FFS Hydrologic Model 
years 0.8 Pv/Flow Rate (convert units)
..'
.. '
... . . .
. .....".'" ,", ,"" .,",.
i:::Ih:FtRENC1E..:,
P"
..
, '
.- ...
.::.',".:.:..;.:,",..:'.
, ..
..,
.... .
018en and Davi8 (1990)
018en and Davi8 (1990)
.
FFS, Table8 9 through 11
Tchobanoglou8, et al. (1977)
Olsen and Davi8 (1990)
018en and Davi8 (1990)
018en and Davi8 (1990)
FFS, section 2.2.3.2, page 2-14
ICF (1988c), Figure 4-14

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TABLE II-2
DESORPTION CALCULATION
WASTE AREA 2
Number of Dore volumes   1 2 3 4 5
Total accumulated time  years 0.8 1.6 2.4 3.2 4.0
Initial contaminant mass in solid material ug 1.28E+ll 5.05E+10 1. 96E+10 7.40E+09 2. 14E+09
Contaminant mass removed by water  ug 7.61E+10 J. 01E+10 1.16E+10 4.41E+09 1.63E+09
Remaining contaminant mass in solid material ug 5.17E+10 2.04E+10 7.90E+09 2.99E+09 1. 11E+09 
Contaminants biodegraded  ug 1.12E+09 8.79E+08 5.05E+08 2.52E+08 1.15E+08
Remaining contaminant mass in solid material ug 5.05E+10 1. 96E+10 7.40E+09 2.74E+09 9.92E+08
Resultant concentration in soil  ug/kg 11,600 4,488 1,698 629 228
Resultant concentration in water  ug/l 15,006 5,805 2,197 813 295
Reduction in water concentration  percent 60.5\ 84.7\ 94.2\ 97.9\ 99.2\
Number of Dore volumes   6 7 8 9 10
Total accumulated time  years 4.8 5.6 . 6.3 7.1 7.9
Initial contaminant mass in solid material ug 9.92E+08 3.51E+08 1.22E+08 4.13E+07 1. 37E+07
Contaminant mass removed by water  ug 5.91E+08 2.09E+08 7.26E+07 2.46E+07 8.16E+06
Remaining contaminant mass in solid material ug 4.01E+08 1. 42E+08 4.92E+07 1. 67E+07 5.54E+06
Contaminants biodegraded  ug 4.96E+07 2.0JE+07 7.95E+06 3.00E+06 1. 09E+06
Remain\ng contaminant mass in solid material ug 3.51E+08 1. 22E+08 4.13E+07 1. 37E+07 4. 44E+06
Resultant concentration in soil  ug/kg 81 28 9 3 1
Resultant concentration in water  ug/l 104 36 12 4 1

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e = BASE OF NATURAL
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. ACTUAL DATA
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ATTACHMENT C
~RANSCRIPT OF ~HE AUGUST 2, 1990

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IN RE:
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
OLD SPRINGFIELD LANDFILL SUPERFUND SITE
PUBLIC HEARING TO RECEIVE COMMENT ON PROPOSED
PLAN FOR SECOND RECORD OF DECISION
August 2, 1990
CYNTHIA FOSTER BENSON, RPR, Court Reporter.
North Country Court Reporters
West Lebanon, New Hampshire 03784

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DAVID WEBSTER:
We can get started.
Good
evening.
Thank you for coming tonight.
I'd like to
welcome you here tonight to a public hearing for the Old
Springfield Landfill Superfund Site here in Springfield,
Vermont.
My name is David Webster.
I'm the Chair of
the Maine and Vermont Superfund section at Region I EPA
whicb is in Boston.
My)osition with EPA as Section
8
Chief of the Maine and Vermont section includes
9
responsibilities in overseeing the implementations of
Superfund remedial programs in the State of Vermont.
I'd like to start off by introduclng the people here at
the. head table.
Actually the other person at the head
table.
To my left, is Tom Moye, the State Regional
Project Chairman of the Department of Environmental
Conservation, the Court stenographer.
Other
representatives from the State and Federal government,
Jim Sebastian is here whose hand's raised in the back
from EPA's Office of Public Affairs.
And Bill Ahearn
from the, who is the director of the Division of
Hazardous Materials ManageDent with Vermont
Developmental Environmental Conservation.
Ed Hathaway,
Remedial Project Manager for the Springfield site is in
the hospital and couldn't be here tonight.
I will serve
as Chairman for the hearing tonight and want again to
welcome you all here.
North Country Court Reporters
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The purpose of tonight's hearing is to
.formally accept your comments on the 1988 feasibility
'\
~
study, the 1990 focused feasibility study, 1990
supplemental feasibility study and the other documents
which are in the administrative record and on EPA's
proposed plan for the source control remedial action at
the Old Springfield Landfill here in Springfield,
Vermont.
Copies of the proposed plan are available.
If
9
you didn't get one as you came in the door or in the
mail, see Jim Sebastian in the back and he can help you
out.
Before I begin the formal part of this
evening's proceedings, I would like to describe to you
the format of the hearing.
Essentially the evening will
be structured into several parts.
First, I'll give you
a brief overview of the site contamination and EPA's
proposed plan for source control remedy at the Old
Springfield Superfund Site.
As many of you know, EPA
representatives made a presentation to the public
outlining the site contamination and proposed plan at a
public informational meeting which was held here on July
12th.
Following this overview, we will open it for
other, for oral comments from anybody that's present
tonight.
That will be opened to anyone that wants to
make a comment for the record.
Those of you who wish to
North Country Court Reporters
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comment tonight should indicate your desire to do so by
filling out on an index card if you haven't already that
Jim Sebastian has in the back.
Or at a later time I'll
ask if there's any other comments and you can indicating
by raising your hand.
At that time I'll ask any of you
6
who wish to comment to identify yourself and your
association with the Gld Springfield Landfill Superfund
7
8
site.
As I call upon you to make a statement or comment
9
for the record I'd kindly ask you to come up to the
~ront.
We have a table over here or stand, whatever you
feel more comfortable so that you can be here and so our
court reporter can also hear you.
I reserve the right
to limit each oral comment to ten minutes.
Although we
don't expect this to be a problem in terms of time, I
may have to impose this restriction.
If I have to
impose that restriction I will ask you to summarize your
most important points and then ask you to provide EPA
with a full copy of your comments either at the end of
tonight's meeting hearing or prior to the close of the
public comment period.
Please note that the entire
contents of the hearing is being transcribed and will
become part of the administrative record for the site.
After you've made your comments; I or a member of the
State of Vermont DEC, Tom Moya, may ask you some
clarifying questions to assist you in more fully
North Country Court Reporters
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addressing your statements or concerns.
After all the ~
.comments have been heard, I will close the formal part;
of this hearing.
Just to remind you, the purpose of tonight's
hearing is to receive your comments for the
administrative record.
During the formal part of this
8
evening's hearing, EPA and DEC personnel here tonight
will not be able to respond to your comments or
9
questions when they are asked.
However, after the close
of the formal part of the hearing, we will remain
available informally to answer your questions on any of
the issues raised during the evening's hearing or any
other aspect of the proposed plan.
As many of you
already know the public comment period for the proposed
plan began on July 13th and was scheduled to conclude on
August 11th.
However, tonight EPA is extending the
public comment period for an additional 30 days to
September lOth, 1990, based on requests made on behalf
of Emhart Industries and Textron, Inc., asked for more
time to review the proposed plan and all other
documents.
Therefore, if you wish to submit written
comments and I would encourage you to do so, they must
be postmarked no later than September lOth.
All wri ttel1
comments should be mailed to Ed Hathaway at EPA's office
in Boston.
The address of our office can be found on
North Country Court Reporters
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Page 3 of the proposed plan.
Finally, at the conclusion of this evening's
public hearing, please see one of us from EPA if you
have further questions on the process for making written
comments.
Any written, any oral comments we receive
tonight during the formal part of this hearing and those
we receive in writing:during the comment period will be
responded to in a document we call the responsiveness
summary.
Therefore, I urge you to comment during the
formal part of tonight's hearing.
This responsiveness
summary will be included in a decision document that we
call a Record of Decision or ROD that EPA prepares at
the conclusion of the comment period.
In the record of
decision, EPA will explain which cleanup alternative or
alternatives has been selected by EPA for the source
control remedy at the Old Springfield Landfill site.
I realize I presented a lot of information
to you in this opening statement.
Are there any
questions on how we're going to proceed tonight?
Okay.
Again I want to thank you for coming.
And encourage you
to express any comments or concerns you have this
evening after a presentation summarizing the proposed
plan.     
 At this point, I'd like to switch hats for a
minute to fill in for Ed Hathaway providing you with a
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........
brief overview of the site and the proposed plan which
~s open for public comment.
I'll try and make this
brief, too, since I see a lot of familiar faces and what
I want to do is give you an overview of the source
control proposed plan that we're seeking comment on and
I'll try to work quickly through that overview, how
these actions fill into other site work going on, what
9
site conditions and risks we are addressing in the
proposed source control remedy, what remedies were
evaluated, and very importantly, what are EPA's criteria
!
that we use in coming up with this preferred alternative
and those criteria which we'll be using in selecting the
final alternative.
I emphasize again, this is a
preferred alternative, it's not fixed at this point.
wel
do seek your comment on it.
And give you every
opportunity to be part of this process here.
I used the word source control in the opening
presentation and let me make sure that I'm clear what's
going on here.
Back in 1988, we were here about two
years ago today and we had a proposed plan that dealt
with two aspects of the site.
One was what I'll call
Operable unit 1 or the management of migration.
That
has to do with leachate and the groundwater.
What to do
with the seeps coming out from beneath the landfill.
We
also at that time proposed a plan for Operable Unit 2,
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.-~~
8
that included a capping the site.
This is what I'm
calling the source control and the landfill itself.
What happened at that point moving along here
after reinvestigation, feasibility study, after that
proposed planned we had comment on it, based in large
part on comments received from the public and from the
state, we decided to ~o forward with the first operable
unit which had to do with the leachate and the
groundwater.
And we've gone on from that, parties have
com forth much to their credit to come into an agreement
with EPA and the state to perform that work.
However,
based on concerns, a lot having to do with understanding
how the groundwater was interacting with the waste, was
groundwater moving through the waste or not and a
preference on the part of the state to try to get some
way of getting the waste out of the groundwater and the
groundwater out of waste decided to go forth with more
study on the second operable unit.
Or the source
control.
What should we do at the landfill itself so we
find ourselves here two years later with proposing an
alternative for the source control for the landfill.
I'm not going to talk much about the first operable
unit, this is where we are now.
We have had a focused
feasibility study.
The proposed plan is available and
we're in an important public comment period right now to
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consider your comments before a Record of Decision.
Remaining situation to be addressed in a
proposed alternative and a Record of Decision has to do
!
with three waste areas up on top of the landfill.
Waste
areas 2, 3 and 4.
Two and 3 are areas that were ravines
on the steep eastern slope of the landfill that were
filled with waste.
Area four is a little bit different.
8
It's trenches, now, on the flat plateau part of the site
9
they were filled with waste.
Some other differences,
groundwater wise almost all of Waste area 4 is
underground water.
So it's saturated.
Waste areas 2
and 3 are, small part of it, portion of it is within the
groundwater flow.
These are important and we think we
have a better handle on that thanks to some of the
studies that have gone on particularly in a remedy which
is trying to prevent more of the groundwater coming in
contact with the waste and leaching it out into the
groundwater and into the environment.
other information
that's come to light in recent studies was a, what we

call a water balance, where the water is coming from.
Again, important if you want to try to cut the water off
to know where it's coming from.
About 60 percent of the
water entering the waste and percolating through the,
leach out of contaminants is coming from the surface.
Rainfall, snow melt.
About 40 percent is coming
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literally, either from this direction, I'm sorry, either
coming off the hill from this direction or coming on the
plateau.
In the case of the Waste area 3, which is
probably the most contaminated area, a lot of it comes
from Waste area 4 so this is filled up like a bathtub
generating water bere and coming in infiltrating,
important to realize that in the context of what we
should do at the site.
The contaminants, we have PCBs
9
or polychorinated biphenyls; PARs, or polycyclic
aromatic hydrocarbons, these tend to be less volatile
and persistant in the environment; and volatile organic
compounds which tend to migrate faster than the other
ones and are of primary concern in the groundwater.
So
you have a situation if I can draw a crude analogy to
your drip coffee maker where you have the waste, you
have wastewater going through that leaching that out.
Where does it go, goes in the aquifers beneath it.
Further down there is a sand and gravel unit which goes
from someplace in this area over to the western sites
seep.
carries water rather rapidly.
Moves from here
from Waste area 4 and part of Waste area 3 over to the
western seeps by Seavers Road.
Beneath the sand and
gravel aquifer which doesn't extend all the way here
there is a fractured bedrock.
It appears that waste
primarily from Waste area 3 is getting down into that
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l
~
bedrock aquifer and seeping down in the direction of the
Black River.
Of course some of the groundwater is
migrating in an easterly direction and coming out at the
leachate seeps along the eastern side as well.
So the
problems that we have, that we're trying to address and
remedy here are the groundwater infiltrating the waste
and contaminating the;groundwater.
There bas been a lot of talk about risk, w~at
are the risks associated with the site.
They are, while
there is no individual out there that we feel is faced
with an unacceptable risk as we are now, there are
several what-if situations that we are concerned with
and has triggered in our mind a need to take actions to
be protective of public health and the environment.
One
of those is I just mentioned the groundwater which is
contaminated and in a residential, if it were to be used
in a residential drinking water for prolonged period of
time we feel it would be an unacceptable risk.
Another
is gases emanating from the landfill and from the seeps.
Someone over a long period of time exposed to that would
be exposed to an unacceptable risk.
And the third is
contact with the soils themselves over a prolonged
period of time, future, nobody at this point.
But if
that was to become residential and people were exposed
to that for a long, throughout their lifetime, that
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buildup of exposure on the skin and incidental ingestion
would be unacceptable based on the criteria EPA uses as
to what kind of cancer risk they'd be exposed to.
Next step in the process after trying to
understand the problem is to look at different possible
solutions.
We looked at in the course of these three
feasibility studies that I mentioned before, some 11
alternatives.
They ranged, that's in your proposed plan
and I'd refer you to that for more of a breakdown.
They
range from a no-action alternative which we used for a
baseline comparison to one that involves excavating all
the waste and treating it with incineration.
That by
law is the preferable treatment.
That in the statute
says EPA is to treat the waste wherever it's practical
to do so.
In coming with the alternative we have we'd
have to make a finding that it is not practical to do
that at this site.
But that's clearly the mandate from
Congress on this.
A number of those 11 alternatives
deal with some kind of capping or containment to try to
contain the waste with various add-on engineering
features, some of which I'll describe because they're in
the preferred alternative.
Given these alternatives,
what criteria does EPA use to make its first, it's
preferred alternative and later our decision in the
Record of Decision.
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There are nine criteria in our regulation that I
we use in evaluating the alternatives.
They're in the
proposed plan with a little explanation of each one of
them.
Let me just hit on a couple.
The first two are
threshold criteria, they're pretty much directly from
the statute, the law passed by Congress.
And we
consider the most impertant.
If you don't meet these,
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then it's not an alternative that we can select.
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OVerall protection of human health and the environment.
I go back to those risks, if we don't feel that the
alternative is addressing those risks that I indicated,
ve don't feel that it is prospective so in looking at
the alternatives we're looking at the ones that
addressed the risk I mentioned.
Again the what-if risk
of the inhalation of volatiles from the landfill, the
dermal contact, coming in contact with a toxic or
ingestion, or the potential future use of groundwater
and ingesting chemicals that way.
Second one,
compliance with, there's a lot of words, applicable or
relevant and appropriate requirements.
Basically
complying with the law.
You can think of this as the
let's not reinvent the wheel criteria.
If you have a
law that tells you how, what's protective or what should
be done in a situation, the Superfund law says you've
got to follow that law.
For example, if you have
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drinking water, if there's a law that says how, to what

level you're supposed to clean up groundwater we are
bound to follow that law.
There's a certain amount of
logic to that.
Another example relevant to this site if
you have a law, a Federal law or a state law that tells
you how to deal with a hazardous waste landfill, you are
bound to follow that law if you find that that law is
relevant and appropriate to the site.
There are some
exceptions where waivers can apply to this but basically
these are the ones to bear in mind and I think hopefully
we'll present a little bit of our thought process in
coming up with our proposed remedy.
have to do with effectiveness, cost.
Additional criteria
Let me point out
the next two, state acceptance is one of the factors
that we look into, we may be hearing more about that
tonight.
Community acceptance.
That's what's this
public comment period is all about.
We do listen to it.
This site, this one included were based on input from
the state and community.
If we have a deviation from
the proposed plan.
50 this is an opportunity right now
for the input on that.
I think it will bear well if you
consider these criteria that we are going to make the
decision based on.
Okay.
What then briefly is the preferred
alternative, well, there are seven steps here.
They're
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up here on the board here that I can refer to later on.t
The first one deals with capping areas one, three,
excuse me, two, three and four.
The basic overall
strategy here was after some thought and looking at the
water balance, is let's try to contain it as best we
can.
Let's try to keep the water from entering the
waste to contain it aftd keep the contamination from
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flushing out and we'll take what measures seem to be
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practical to do that.
And most of those fall in that
category of trying to contain the waste to keep it from
spreading out.
First is capping the areas, Waste areas
2, 3 and 4 with an impermeable cap made of a combination
of clay and synthetic materials.
That's how it was
seoped out.
The area on the cap you recall, this is
areas 2, 3 and 4, Will Dean Road, Route 11.
Down over
here.
The area in the preferred alternative is that
area with the crosshatch marks in here which extends
over the areas of 2, 3 and 4.
I'll get to these in just
a second.
Again, to prevent direct contacts and to try
to decrease the infiltration of water into the waste to
try to reduce the amount percolating out.
The second is
an active or passive gas collection system.
The gas is
built up on and I already mentioned that that's a
potential risk that we have.
It's in Area 3 where most
heavily contaminated with volatiles we have an active
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system to purge those contaminants out and the other
areas it will be by diffusion to build up of gases of
either volatile organic compounds or landfill from the
owner.
The next item, French drains, deals with
another approach to try to catch the water from
infiltrating into the~landfill to try to cut down the
amount of contaminants that are leaving and escaping
down into the groundwater.
The areas of what a French
drain is basically is a trench that we backfill with, go
down, this one is scoped out at 15 to 25 feet, goes
down, backfilled with gravel, have a perforated pipe
down at the bottom.
A lot of you have around your house
maybe for water protection so the water that's moving
here will make its way down to the pipe.
Basically if
you have the water coming this way and you have the
waste here what we're trying to do is avoid having the
lateral flow go through the waste, we're trying to
basically isolate the waste from the water by
intercepting it in a trench like this going out around
Waste area 4 and this was indicated as another flow of
source of water infiltrating through Area 3 and down in
Area 3, 2, 2.
That's what we're thinking in terms of a
French drain. Next item is a side slope stabilization.
While we found that the, we do have a law for hazardous
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waste landfills which says one of the appropriate things,
you can do is either pick it up and treat it or put a
cap of this type on it, we didn't think that that was
appropriate for the steep slopes.
Doesn't take much
imagination if you try to put something that's six or
seven feet of compacted soil on a slope it's going to
fall down on Route 17:
So what we try to do there is
stabilize that slope so that it will support the cap
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that's on top of it.
So basically in these areas here
and here, we feel that to insure that the cap stays
there, doesn't shift, doesn't slide, doesn't crack,
doesn't fall down and here we have more weight up here
and already that's a pretty unstable situation is to
stabilize this slope here along the sides and support
that cap.
The next component is source control wells.
By source control wells we do have beneath the waste
areas themselves contamination in the sand and gravel
aquifer which then logically could be moving east, could
be moving east and west from particularly Waste area 3,
let's try to capture and keep it from spreading.
Therefore we're proposing two wells that goes down into
the sand and gravel aquifer loam indicated here within
Waste area 3 to pump this contaminated water and that
would be treated, plan there from the first operable
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unit as well.
Try to hold back some of that
contamination.
six is institution of controls to restrict
future use.
Because this isn't what might be called a
permanent remedy out at the site, it's not, you will be
left with a landfill cover on the site.
There are
certain controls that"we'd want to insure that it
doesn't get used in a way that destroys the caps or
counteracts all these things that we're doing.
What I
mean by institutional control rather than engineering,
we're talking about fence, maintaining no trespassing,
maintaining town ordinance in effect as far as uses that
would compromise these other engineering features.
Finally, according to the law, we can't walk
away from it.
So you'll be seeing me or someone for a
long time.
If you're leaving the waste in place you
have a mandatory five-year review process where you come
back at tbe remedy, see how it's holding up.
At this
point we'll be looking at the cap and concentrations and
see if we're still on track and see if there's a need
for corrections along the line.
That's basically the
preferred alternative.
The cost of that comes down to $8.6 million is
what we estimate with some degree of uncertainty.
Some
of the heavy features in there are the cap itself which
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is in the order of two and a half million dollars.
The
side slope stabilization which is in the order of about
a million dollars.
The French drain about a million
dollars.
And other components as well as engineering
contingencies and such.
Looking at that cost, one thing
6
came to mind and we'd put as an option in the proposed
plan that you can make comments on tonight if you wish,
7
8
is well, of the cost of the side stabilization over here
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which is estimated to be about a million dollars.
Maybe
it would make more sense not to stabilize this cap with
the side slopes stabilized side slope here and maybe you
could save some money just excavate that soil there, I
think it's around 6,000 cubic yards and if appropriate
take it off-site.
Which we would estimate to be a very
small volume and otherwise put it underneath the cap
that's in this area.
That way no need to cap over here
and put that expensive slope stabilization.
That's kind
of in there as an option that we're still considering
and any comments that you have on that would be
appropriate, too.
So we looked at the alternatives, we looked at
our criteria, remember those two first threshold
criteria, of the ones that meet those first criteria,
public health and meeting the State and Federal laws, we
felt that this one was the most cost effective.
And the
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best balance of the remaining criteria.
And that's what
we're seeking your comment on.
And I will invite you to
give that comment and I hope this was helpful in
preparing you for that.
Okay.
We will now take your comments for the
record regarding the proposed plan.
And all the other
studies conducted at the Old Springfield Landfill site.
I'm going to st~rt with the people that they had a card
here and I'll start with Tom Moye from the Department of
Environmental Conservation.
TOM MOYE:
Again, my name is Tom Moye and I'm
with the Vermont Depa%tment of Environmental
Conservation.
Very briefJl.y, the state's position is
that we support EPA's pr~osed plan as the best balance
between protection of public h~th and the environment.
And cost.
We are currently considering the option to
consolidate Waste area 2 under the cap for Waste area 3.
And as more information become~ available we will
finalize our position on that option.
The State's final
concurrence on the proposed p~.m wi1l take place after
we have carefully considered all comments received
during the public comment period.
DAVID WEBSTER:
Thank you, Tom.
Wayne Golec?
If you wouldn't mind coming up here to make sure we'd
get it on the record, I'd appreciate it.
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WAYNE GOLEC:
I have four or five comments I'd~
~ike in the public record.
What will be done with the
town water line on that, that is on the site presently
running through it.
And when will it be done.
Is
Remcor going to relocate the Command Post
decontamination facility, if so when.
I understand
8
there's some holdup iR that it might possibly be out of
that but EPA is waiting to and they're waiting for EPA
9
to give them som& okay on any source control wells.
If
they cannot come to agreement with EPA, how about
relocating the Command Post decontamination facility,
would EPA step in and take over the site.
And that
might allow them to move it.
If Article 88-2 for the
Town of Springfield is not enforced, which I understand
it isn't, what is protecting the site from somebody
doing digging on the site. And when EPA comes to a
site, while it may not be a requirement, concern should
go given to the aesthetic values of the property around
and on the site.
In other words, if it doesn't cost
anything, why not be a little aesthetic about it and
possibly more considerate.
With EPA and the people they
have do the work for them.
And will there be, nothing's
going to be done with Waste area 1.
Will it be safe to
dig in that area and whatnot in the future.
And has the
State approved the sewer plant use for the site.
Thank
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you.
DAVID WEBSTER:
Thank you very much.
Again,
after the formal part we can talk a bit more.
call on Ed Battles.
Next I
ED BATTLES:
No comment at this time.
DAVID WEBSTER: John Tuttle.  
JOHN TUTTLE I I have no comment at this time.
DAVID WEBSTER: Okay, I'll give you another
chance in a Dinute if you want.
Bill Newman..
BILL NEWMAN:
No comment.
DAVID WEBSTER:
John George.
JOHN GEORGE:
My name is John George.
I'm the
Director of site Charaterization and Assessment with
Remcor, Incorporated.
I'm here this evening on behalf
of Emhart Industries and Textron, Incorporated.
I have
a statement I'd like to read into the record at this
time.
Emhart Industries, Incorporated, and Textron,
Inc., are currently in the process of reviewing EPA's
preferred alternative for Operable Unit #2.
We have not
yet completed our review and on July 26th made a formal
request for extension of the comment period for a
minimum of 30 days which I understand today was granted.
Despite the fact that-we're not yet prepared
to provide complete comments, we would like to state the
following points for the record at this public hearing.
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It i~ our position that there is no current unacceptablJ
fisk posed by the site and that the June 1988
endangerment assessment prepared by the EPA and used as
a basis for conducting remedial action at the Old
Springfield site does not adequately characterize
potential future risks to public health.
In particular,
we believe that the medel used to determine risks
through future inhalation of landfill gases and
ingestion of groundwater lacks technical justification
and significantly overstates the potential risks.
Comments made by Emhart and Textron in August, 1988,
during the public comment period on the preferred
alternative for Operable Unit #1, relative to the
endangerment assessment were never responded to by the
EPA.
We would respectfully reiterate our request for a
formal response to those comments.
The initial draft of the focused feasibility
study report prepared by Remcor on behalf of Emhart and
Textron had indicated that EPA alternative seven which
was our alternative Number 3 was the recommended
alternative, providing for protection of public health
from all potential risks in combination with the
management of migration controls provided by Operable
Unit #1.
This alternative included fencing the site,
installation of a source control well and covering of
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~ ':ff':-- -~--
24
surface soils that may pose a dermal contact risk.
The
capital cost of this alternative was estimated by Remcor
at $495,000 with an annual operating and maintenance
cost of approximately $18,000.
A net present value
ranging from $692,000 to $821,000.
This is in
comparison to the EPA's preferred alternative under
consideration this evening with a base capital cost of
seven and a half million dollars, and annual 0 and M of
~30,000 and a range in net present value of 8.8 to 9.6
million dollars.
In the absence of a groundwater threat, an
impermeable cap is not required at Waste area 2.
To the
extent that the EPA insists on construction of a low
permeability cap over the former landfill areas, the EPA
should permit alternate cap designs compliant with RCRA.
Several points under there.
There is no need for a
twelve-inch gas vent layer at the base of the cap.
Alternative materials such as soil admixtures or
Bentonite panels should be permitted to substitute for
the two feet of compacted clay incorporated in the
typical cap cross sections provided in EPA's proposed
plan.
There is no need for two feet of clean fill
over the sand drainage layer when one foot of fill would
be adequate.
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stabilization of the outs lopes of Waste area 3
is not necessary from an engineering perspective to
insure the stability of a RCRA-Compliant cap placed on
the plateau portion of Waste area 3.
Such stabilization
will result in an unnecessary expense of approximately
$300,000 in accordance with EPA's estimate.
If the EPA ~ontinues to maintain the covering
of the outs lopes of Waste area 3 is appropriate,
9
provision of cover material could best be achieved by
filling to a stable grade over the waste, rather than by
excavating or regrading the waste materials.
As set
forth above, we do not accept that there is a risk-based
justification for placing a cap on Waste area 2.
To the
extent that the EPA believes that this is necessary,
there's no need for an elaborate stabilization scheme.
The one million dollar cost estimate for stabilization
of the outslopes of Waste area 2 is grossly inflated
leading to the errant conclusion that excavation of
Waste area 2 may be a more cost-effective solution.

Excavation of the waste materials is unnecessary and
would result in the potential for significant releases
of contaminants within the municipal solid waste to air
and water as well as exposing remediation workers to
unnecessary risks.
If a French drain is to be installed on the
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upgradient side of Waste area 4 it should be dedicated
to interception of shallow groundwater flow only and a
surface water collection ditch should be placed
upgradient of the French drain to reduce the volume of
6
water that will have to be conveyed by the French drain
system.
7
Dewatering ef Waste area 4 could be more cost
effectively achieved by installation of the French drain
8
9
upslope of the waste area as proposed, but by
eliminating the flexible membrane on the downslope face
of the drain.
Dewatering Waste area 4 through
extraction wells as proposed by EPA and the proposed
alternative was proven ineffective in the groundwater
isolation study performed by Remcor.
And finally, Emhart and Textron and the Town
of Springfield are among Respondents who under an
administrative order by consent with the EPA are
responsible for design of the leachate collection and
groundwater extraction system as Operable Unit #1.
Certain aspects of EPA's preferred alternative under
discussion today such as the stabilization of outslope
areas of Waste areas 2 and 3 are likely to adversely
impact the current design of Operable unit #1.
Unless
the EPA integrates the design of both operable units,
significant cost and schedule inefficiencies are likely
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~
to occur to be paid for by both the town and Emhart and~
.Textron.
Thank you.
DAVID WEBSTER:
One question, John, did I
understand on the source control wells that that was not
something you'd recommend at this point or did I miss
that?
JOHN GEORGE:
We have a question as to why two
source wells.
I have several questions that I'd like to
ask later but we have a question as to whether two
source control wells is exactly actually the best
design.
DAVID WEBSTER:
Okay.
Thank you, I'll now
take your comments for the record regarding the proposed
plan or anything else if there's anybody else that would
like to make a comment for the record tonight.
ROBERT YODER:
Yes.
Could I make a statement?
DAVID WEBSTER:
Sure.
ROBERT YODER:
I'm Robert Yoder, resident of
Springfield and I'm a representative in the Vermont
Legislature in the Vermont House for the District in
which this landfill is located.
We've heard, I've heard
comments on the engineering and economic levels.
And
we've been informed about engineering considerations,
what is the safest and best way to go, the perhaps least
expensive way to achieve the end goal that you have.
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But I wonder to what extent EPA has considered some of
the pOlitical elements that, that is the feasibility of
this town which has suffered a lot of economic reverses
undertaking another, yet another expensive project.
Ten
years ago and for quite some time I guess we began it
longer ago than that, we considered the possibility of
developing a hydroeleetric system and that's cost us
some $3,000,000 which the taxpayers are paying off
without having produced very much in revenue, we've had
some.
This has been a machine tool town which has seen
reverses and loss of jobs in a very significant way over
the past several years.
And I wonder what will happen
if we are after the discussion with Emhart and Textron,
the town is faced with the prospect of having to cough
up a significant portion of this 8.6 million.
I would
imagine that we would have to, this would have to be an
article in the town warrants that the town voters would
vote on.
And bas any consideration been given to the
possibility that there could be a taxpayer revolt.
And
in that event, what do we do then.
You mentioned the
possibility of excavating one site and placing the
contents thereof in another site.
And this would reduce
the the engineering costs by some $700,000.
Why isn't
that just automatically recommended.
Why even consider
spending more money when this would seem to be a sounder
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solution.
I must confess that I'm not an engineer, but
it seems to me that sometimes a common sense approach
has some merit.
And I toss out these ideas for what I
understand their purpose is for EPA's consideration.
And I hope that you will take this into consideration.
Sometimes desperate problems need extraordinary and
imaginative solutions'and I'd like to throw one out that
8
just occurs to me for your consideration.
And I don't
9
know how well this will fit in with existing law,
bureaucratic requlations, labor union rules and labor
laws, but it strikes me that it's possible that some of
the labor might be done by volunteers.
When a community
had a problem in the past, quite frequently people would
get together and volunteer their labor and their help.
That may be that much of this has to be done by skilled
engineers using heavy equipment.
But we do have skilled
people in this community and there may very well be some
people who would volunteer some time to help keep costs
down, to help keep the tax rate reasonable.
And I
wonder if that couldn't be explored, a volunteer team.
Thank you very much.
DAVID WEBSTER:
Thank you.
Is there anybody
else that would like to make a comment for the record at
this time?
Seeing no other comments for the record this
evening, this concludes the formal portion of this
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evening's hearing.
There will be no more oral comments
for EPA's response and responsiveness summary of the
Record of Decision~
Now, I'd like to entertain any comments
questions or comments and maybe it would be appropriate
to speak on some of the things I heard coming up here.
Thank you very much again.
I think that there is a lot
to think about that's been presented here.
Some of
which we considered and some of which we haven't.
Where
should I start?
On the facility that you may be aware,
Wayne, we are trying to work with that.
Our laws, as we
indicated last time, deal with the release of hazardous
materials, we're seeing if that poses something under
the law and maybe we will in future agreements with Mr.
curtin in access if necessary by an EPA or by the PRPs
will take those kind of things into consideration but
unfortunately some of the considerations that are
brought up, mainly aesthetic, is not specifically
mentioned in the Act and it precludes us from taking
that in a manner that's making something be more costly
if it's to meet aesthetic criteria.
However certainly
if it was the same one, I think it would be a reasonable
thing to do.
Either trying kind of through those
channels also perhaps the agreement regarding the access
to the property and the location of those facilities as
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you are well aware is between the property owner John ~
eurtin and it's either Remcor or Emhart and Textron, I'm
not sure which.
I don't know, do you have anything to
say on that, John?
JOHN GEORGE:
I know that we're beyond the
part of the meeting here where we're being transcribed,
right?
DAVID WEBSTER:
You've being transcribed.
But
it's not, the distinction is that these are not ones
where we're trying to consider these ones anything
that's being said now in trying to address the community
concerns under the statute.
It's not a specific
requirement that in responsiveness summary that
everything that gets said here will necessarily be
responsed to in the official responsiveness summary.
But yes, John, you're being recorded.
JOHN GEORGE:
I don't have any specific
knowledge of what the current status of that agreement
is with John curtin aside from the fact that it hasn't
been concluded.
DAVID WEBSTER:
I don't have much else to add,
Wayne.
I don't know if you want to follow that up.
We
have made a request although we have not seen that as a
threat, release or threat of release of hazardous
materials at this point which is our statutory
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authority.
WAYNE GOLEC:
It is a decontamination center?
DAVID WEBSTER:
As I understand it.
Yes.
That's the pool that they use to wash some of the
equipment in.
JOHN GEORGE:
Just to clarify, that pool was
more or less an equalization basin to hold water so that
it could be run throuqh the treatment system before it
was dischar.ged to the municipal sewer.,
There was no, I
mean there were some decon fluids that were placed into
the basin but there wasn't any direct decontamination
into the basin itself or into the pool.
DAVID WEBSTER:
So if it's water in it now,
it's rain water?
JOHN GEORGE:
I don't know if there's water in
it right now or not.
There there might be a little bit
of rain water, it's covered.
So there really shouldn't
be any rain water in it.
WAYNE GOLEC:
The whole problem, the owner
evidently has an ego problem and it should never have
come about.
From what I understand Remcor didn't want
it there in the first place.
They wanted it elsewhere.
It was more convenient for them, maybe less costly for
them, I don't know, but they were forced to put it there
and from what EPA says, that it's going to be there
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another, I think it was maybe another two to four years.
To me that's a problem.
I don't like it at all.
Md
there's no reason for it to be there other than the
guy's got a problem.
DAVID WEBSTER:
It kind of relates to your
other question about, well, when will EPA step in and
move that and aqain, ve are bound by the authorities
that have to do with we can take a lot of different
9
actions dealing with their release or threat of release
of hazardous substances, if it's not tied to that, we're
looking into what authority we have that way and working
hopefully in a way to resolve it but there's some
limitations on it.
WAYNE GOLEC:
Then I'm told that EPA is
holding up Remcor as far as source control wells?
They
could drill those wells and probably be right out of
there.
But what's the holdup there.
DAVID WEBSTER:
I'm afraid I'm going to have
to get back on you about that one.
I don't know.
SPEAKER:
What's in the blue barrels behind
the fence?
JOHN GEORGE:
Those are drums of activated
carbons that were used in the treatment system.
Groundwater treatment system.
All of what is up there
as far as waste is concerned, the two red boxes, they're
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termed roll-off boxes, there are twelve drums of spent
carbon from the groundwater treatment system.
And one
drum of decontamination fluids, mostly acetone, just
common decontamination fluids.
We anticipate with EPA's
approval having those off-site by the middle of August.
That's our current target and we're pretty close to
realizing that.
'.
DAVID WEBSTER:
If that's the holdup you're
talking about, EPA is involved with that and we go
through a process of checking the facility that it's
going to to make sure it's in compliance with the
environmental laws in whatever states that it's going to
and that is tied up in paperwork as Ed indicated but I
think you're referring to something else.
WAYNE GOLEC:
Except, source control wells
which would be over in two or three.
DAVID WEBSTER:
I'd have to get back to you.
WAYNE GOLEC:
Why would it take so long to
allow Remcor to move these red containers?
DAVID WEBSTER:
What that process entails is
whenever we're taking something off a Superfund site we
have early in the problem basically gotten into trouble
taking things from one site and taking it to another one
which ended up making a Superfund site so we go through
a lot of checks of if it's going someplace contacting
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~
the other regions, seeing what the compliance record is
with that facility in Alabama or New York or Illinois,
whatever it is and it's going through that process now.
WAYNE GOLEC:
How long does that take
typically?
DAVID WEBSTER:
I think it's been between two
and six months has been my experience.
Depending on
different waste, different facilities are licensed to do
different wastes and when it got to be facilities
whether there were fewer facilities handle those, a
contaminant that fewer facilities were handling it's
been very heavy.
WAYNE GOLEC:
So it's not really Remcor's
fault or EPA's fault?
DAVID WEBSTER:
To tell you, I don't know
enough of where the paperwork is.
I can assume it is, I
know that that takes a long time for EPA so it is
plausible to me.
I don't know whether you want to take
credit for it or not.
JOHN GEORGE:
You can take that one.
WAYNE GOLEC:
If it was a site out in the back
woods somewhere I guess there's no problem but when it's

right across from houses, residents, it poses a problem.
DAVID WEBSTER:
It is a problem.
WAYNE GOLEC:
It does not look good.
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DAVID WEBSTER:
It's a problem here and
nationally and there are very few facilities that are
meeting the regulations for handle and treating
hazardous wastes and to get those approvals is not
necessarily an easy thing.
WAYNE GOLEC:
Are they going to move area two
to three, why can't t'at all be put under the cap,
that's where it comes from, isn't it?
DAVID WEBSTER:
In that option, all but I
think i.t's in the option, it says assumes couple hundred
cubic yards would be.
There's one boring in that area
that we felt was contaminated such that it should
trigger taking it to an off-site facility.
WAYNE GOLEC:
But you only got part of it
then?
The part you bored down?
DAVID WEBSTER:
So in the area, that boring is
our assumption we're going to have some that we should

take off site but it's very small, it's a few
percentages of the total ones.
The rest of it we're
doing in that option.
We're doing exactly what you
said.
Which is excavating basically all of that filled
ravine in Waste area 2 and placing it on Waste area 3
before putting a cap on it.
To respond to one of the
things that you mentioned, it was a bit of a timing
situation.
We were evaluating that at the last minute,
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I
one of the things that frankly was hard to get a handle
on was the cost for the slope stabilization.
And as
tho~e numbers came in, and this was a significant cost,
that sent up the red flag of should we look at it.
you heard from John George, there are trade-offs
As
involved with that.
You have, you do have possibly more
emissions or possibly;more exposures to the workers any
time you're excavating waste and there's a factor any
time you're deciding to excavate but it's a trade-off
and on the other hand it saves some money.
There's
another whole portion of the site which does not have to
be behind a fence in perpetuity.
JOHN THURBER:
John, isn't there going to a
similar deal to what we have had with asbestos removal?
~
Where they figured today it might be better if we left
asbestos where it was because there was a greater danger
to the environment with the removal as it would be when
they left it?
DAVID WEBSTER:
You mean whether you take the
pipe and encapsulate it rather than removing it?
I
think from what I know about asbestos treatment there's
a lot of people that recommend leaving it in place and
maybe --
JOHN THURBER:
Seems to be the consensus now.
After they got everybody in the schools to remove it and
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I didn't know whether this might be a --
DAVID WEBSTER:
Anyone of these remedies
there's a trade-off and I think what's been pointed out
is a good one.
That on one hand it's tempting to say
excavate it and get rid of it but that's the beginning
of the problem.
If it's hard getting approval to ship
off the, to find a place to take the few drums that
we're talking about, wait until we get into the hundred
thousand cubic yards of waste and it is questionable
whether it's better to take the risk of excavating it as
opposed to trying to contain it and it's one that we
face at a lot of sites and this one we felt that it
would have been practicable.
JOHN THURBER:
What is the risk if we leave it
as it is?
We haven't heard any risk that there was any
great --
DAVID WEBSTER:
If it's, when we look at the
no action alternative we looked at what's the risk right
We feel that currently there is nobody, no
now.
individual that's at risk.
If there was somebody that
was living on the site, current risk we feel would be
the exposure to gases coming from the landfill over a
prolonged period of time.
And to get them to years and
years of exposure.
Then we get into what we call future
risk or what-if risk, what if somebody built a house and
~ .
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started drinking the groundwater.
That we think would
be a risk, okay?
You can debate on the policy of wait a
minute, should EPA protect against those kinds of
what-if risks, what if somebody puts a house on the site
and plays on it.
You can debate both sides, the way we
do is we consider the what-if risks.
JOHN THURBER:
There's been a good many years
just as it is.
Even an open pit at one time.
DAVID WEBSTER:
That's a fair comment.
If on
the other hand I come up and say we're proposing to you
walking away because it doesn't look very likely that
anybody will ever expose it, forever, and besides we
have ordinances or whatever to protect against it, I
think we're up for, that's up for debate whether it's
protective, too, in leaving it for the remainder of the
time and none of those what-if's.
PRESTON CHILDS:
I haven't heard a definition
of the area under your code 6 institutional control, how
much will that encompass, the whole site boundary?
Last
meeting we had I believe the answer was given that you
would not allow any people to use the land above the
caps because it might dislodge or affect the longevity
of the cap.
Seems to me that we're talking of a no
man's land here that will not be able to be used,
so-called, forever.
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1
DAVID WEBSTER:
PRESTON CHILDS:
The cap within the fence?
I'm asking you how large an
Are we talking about the
area are we talking about.
whole site boundary including Waste area 1 2, 3 and 4?
Under this institutional control, are we taking that
whole site boundary and putting that under institutional
control?
If we are, A, we've 10ss tax revenue on that
land forever; B, nobody with live on it so you can't
have your people in residence on it getting gas
problems.
Toxicity from the soil, or from the water.
Because nobody will be able to be on that piece of land.
If indeed, if your reference 6, institutional controls,
locks off that whole site boundary you've got a no man's
land that can't be touched.
Therefore, and you say that
at present there's not a problem.
Down the road, if
somebody tills the ground, opens the ground up, goes in
for a well, well, if that's a no man's land nobody is
going to be in there.
DAVID WEBSTER:
There are several
institutional controls which are envisioned and some of
them were in the first ROD and there's additional ones
in this proposed plan.
I think to get to your immediate
question, it's not on this map but I seem to recall some
of the engineering maps indicating that basically it's
the capped area and then whatever buffer zone is needed
. .
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to protect the cap is what we're talking about.
tI

That is
as you call it no man's land.
That is, yes, in
.

perpetuity, not going to be developed as far as I can
see.
Maybe they'll come up with something that's a
compatible technology or recreational area or something
like that where they, but yes, and it's, there are other
institutional controls that have to do with until we
achieve the groundwater cleanup standards in all the
areas, institutional control or town ordinance to be
enforced to prohibit use of the groundwater.
Hopefully,
by the combination of Operable Unit 1 and 2 we will
reach a day when that won't be necessary anymore because
we will achieve those clean-up goals, that it would be,
meet any Federal or state standard for drinking waters,
that's what we're trying to do.
But yes, we're talking
about institutional controls that would prevent damage
to the cap.
PRESTON CHILDS:
Your goal is that this will
clean up back to the point that this can be put into
residences.
DAVID WEBSTER:
No.
Not the cap itself.
You're taking it off the rolls.
PRESTON CHILDS:
The toxicity is forever under
the ground so that is a no man's land forever.
DAVID WEBSTER:
Right.
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PRESTON CHILDS:
Then I don't see where we
need to go to all this expense.
DAVID WEBSTER:
What we're trying to achieve
with that is not only in this area where the cap is but
also trying to get to the point where the contaminants
in the groundwater is cleaned up.
So that maybe the no
man's land is just the landfill itself and not the area
where the groundwater is contaminated beyond the
landfill towards Seavers Brook and the Black River.
You
see what I'm saying?
PRESTON CHILDS:
If that area in the water
you've got contamination from the water in Seavers Brook
now, why isn't that shown on that map as part of your
contaminant site?
DAVID WEBSTER:
This is the source area is
where the waste was.
This is contaminated all the way
along here in the sand and gravel unit beneath the
ground all the way to Seavers Brook.
What are we doing
about it?
In the first Operable unit there's a blank
plan to collect at the seep here the water that's
emanated and to treat it.
Also to accelerate it in the
first operable unit, there are proposed wells in this
area to go down into that sand and gravel aquifer which
is where you can get at the best to pull it up to
shorten the amount of time it takes to clean up the
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1
contamination in this area.
Thirdly, in the source
2
control, we're trying to cut off the source of that
contamination migrating to more so that will clean up
3
4
faster.
By cutting off the source, by a combination of
5
things, keeping the water from infiltrating through it
and also trying to hold it back with these source
6
7
control wells bere to=pull it back into this area.
80
8
we've got a little built of distinction between the area
9
that we're, basically what you're calling no man's land
that will be a cap.
In perpetuity on a landfill.
This
is not one where what you here, well, clean closure, go
away, that's our goal, our goal is to leave the site so
you can have a residential development and we can do it
on some site but that's not what we're proposing on this
one.
ED BATTLES:
Following up on Preston's
question, are you saying that the capped area, I
understand, is up when it's forever fenced in and so on
the other area of that is going to be able to be, to
have homes or trailer park back on it?
DAVID WEBSTER:
That's my understanding.
Md
I'd rather get back to you with a definitive one but
when we looked at Waste area 1 that it did not pose an
unacceptable risk on it.
ED BATTLES:
How long a period of time will it
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be before there can be something back on that property?
DAVID WEBSTER:
I don't know.
From a
technical point it's very short.
I don't know what the
ownership and legal considerations are with that.
But
we feel that we have, there was an extensive boring
program up here to look on a grid 70 feet apart of it
and we feel pretty comfortable that we have delineated
the source of where the waste was disposed of up at the
landfill.
And had one pocket here on closer inspection
during Remcor's evaluation that did not appear to be as
widespread.
I don't know if Tom or John can comment a
little built, I'm not real familiar with the details of
what they found there and how that changed his thinking.
TOM MOYE:
I think that's accurate.
The work
that Remcor did suggested that the waste that was at
location one was a much smaller volume and maybe was
related to some kind of incidental dumping, very small
volume.
DAVID WEBSTER:
I'm sorry.
I'll try to
recollect but feel free if you brought something up
earlier and you want to see what my thoughts are on it.
ED BATTLES:
You're saying now that once the
cap is in place, and the wells are in place and so on
that if they complete what you expect them to do, that
people can inhabit the rest of the part?
. .
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DAVID WEBSTER:
I think that's the goal and I
think that's what we're trying to achieve and we're
saying this is the area.
There may be some area around
here that it's getting into the integrity of the cap.
TOM MOYE:
And there may be additional
restrictions such as, you can't have a private well at
that location, you might have to be hooked up to the
municipal water supplies.
ED BATTLES:
The water supply is already
there.
TOM MOYE:
Right, but I'm pointing out --
DAVID WEBSTER:
If we achieve the objective
which is the goal but it may take 10, 30, I don't know
what the estimate is of years of pumping it to contain
it and cut it off from the source of the contamination.
WAYNE GOLEC:
At what point do you say that
you put the cap on it, the fence around it, at what
point do you say that these people are no longer
responsible?
DAVID WEBSTER:
Not responsible?
WAYNE GOLEC:
Let's say John CUrtin sells that
land and they come up and build on it.
Are these people
going to be, oh, geez, more chemicals here, you people
are responsible.
How do you determine?
DAVID WEBSTER:
As far as new owners up
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there --
WAYNE GOLEC:
Let's say the old owners, after
it's cleaned up everything is clear and clean, Remcor
and Emhart --
DAVID WEBSTER:
If we have outstanding money
6
on the site as far as free and clear is concerned.
And
one of the things that people settled in this case in
that deal were that there were certain things that we
9
would not press as far as future liabilities.
JOhn, I
can, maybe you can help me but I think past costs that
were involved previously was protection.
JOHN PARKER:
Part of the partial consent
decree, there is some statements and agreements there as
far as the pro rata share of costs that might be
recovered at a later date, that those were waived as
part of this agreement.
Among those parties only.
DAVID WEBSTER:
Which is Emhart, Textron, the
Town and BFI.
That doesn't apply to John Curtin, he
He has liabilities and we did not
didn't settle.
collect a hundred percent of what we spent on the site
during that version and as you can see no matter what we
pick here we're going to have more liability.
So one is
the previous one, they're liable until they either get a
release of the liability which the town has on that
previous work or there is no more outstanding Federal
. .
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cost.
WAYNE GOLEC:
area,
though.
DAVID WEBSTER:
~hat's not for everybody in the
You're talking about legal
liability, potential of ingesting contaminants?
WAYNE GOLEC:
Liability.
I mean I'd hate to
think I'm going to li~e the next 30 years with that
8
hanging over my bead.
9
property or whatnot.
See what I'm saying?
DAVID WEBSTER:
saying.
WAYNE GOLEC:
whatnot but that's --
DAVID WEBSTER:
WAYNE GOLEC:
DAVID WEBSTER:
Or the person that might buy my
Wha~ do I tell them?
Good luck.
I understand what you're
I'm glad the Town's off it and
That's not you.
Right.
To tell you the truth we
haven't gotten far enough in the Superfund process of
dealing with --
WAYNE GOLEC:
they brought it up.
DAVID WEBSTER:
I hadn't thought about it until
afterwards.
We try to settle up liabilities with the
Recovery and what happens
point.
people that we feel are responsible parties at some
I'D involved in another site where we're doing
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that now after the clean up and trying to settle up the
past costs but there are, as of right now, you're not
one of the 14 parties who received the notice letter on
it.
ROBERT YODER:
When you say that the capped
area are going to remain hazardous and toxic in
perpetuity, do you mean forever?
Is that an assumption
or is there a study that points to that conclusion?
thinking that technology in that area seems to be
I'm
evolving very, very rapidly-
And you have bacteria
which will help control oil spills.
Is it possible that
studies are ongoing that which might suggest that
chemical changes, chemical processes, bacteriological,
biological processes, may not over a long period of time
render it nontoxic?
DAVID WEBSTER:
Excellent point.
Not only
could there be biological action happening in there but
also it is possible that as time goes on, we do a five
year look at the site, new technologies will have
progressed so that maybe injecting something in there to
stimulate microbes could be something that's possible to
do.
Whatever.
I am taking the pessimistic attitude but
I think realistic that, hey, it's going to be there for
a long time if not forever.
ROBERT YODER:
When you say forever, that is
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1
an assumption.
DAVID WEBSTER:
Also I'm on a little thin
3
ground technically and I don't know, Bill or John,
someone wants to help me out here, but I think that very
5
slowly, any cap is going to be some continual leaching
6
there.
What we're hoping is that that's so
8
"
insignificant that we " achieve the groundwater cleanup
levels and maybe that very small flow eventually will
9
drain out.
But that's definitely, that's not the
strategy fOllowing, we're not following the flush
strategy of trying to contain it and based on that
strategy, you have to be ready to live with it that it's
going to be a long time and it's not a piece of land
that is prime for development or developmental forever.
ROBERT YODER:
In a thousand years, the
Listers can take another look at it.  
 DAVID WEBSTER: Every five years the Listers
can look at it. Maybe there'll be a techology for doing
it.
Maybe.
I don't know.
PRESTON CHILDS:
I believe at the last meeting
that it was stated that if the town, if this is the step
that we're going to follow, and if it goes through,
we're looking at four years before it's instituted.
By
your timetable.
And instead of 8.6 million we're
looking at probably four years down the road at twelve
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million dollars, in those, what is that, 1994 dollars.
Then five years later you will do a test, how many times
will you continue to do five-year tests and at what
point do you say it's cleaned up?
Do you say three good
five-year tests, do you say four or what do you say?
DAVID WEBSTER:
The law says any remedy where
you leave waste in place, EPA shall conduct a review
every five years of the site.
That's the law.
ED BATTLES:
Forever?
DAVID WEBSTER:
That's as far as the law went.
So I guess I can assume it's every or until that law is
changed.
JOHN GEORGE:
I wanted to clear up one thing
that Mr. Yoder had said earlier and that was with
respect to the excavation cost for Waste area 2 if it
were to be removed and placed under the cap in Waste
area 3.
There was a comment that that would result in a
savings of $700,000.
Actually, the estimate for slope
stabilization on Waste area 2 is a million.
Which is a
very rough number.
The estimate for the net present
value for excavation of Waste area 2 is in excess of
800,000.
There's actually not a real significant
difference between the two.
There's certainly not
$700,000 difference between the two in net present value
and the point that I was trying to make earlier was that
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. ~
Remcor believes anyway that the million dollar number 1S
grossly overstated which we believe that the site, the
stabilization if it's to occur on the outs lopes the area
two could be done for much less in the area than the
cost of excavating and placing it on Waste area 3.
DAVID WEBSTER:
We're very interested in
seeing your opinions on that and looking at it.
Right
9
now that's what we came up with is there would be a --
there's a lot of engineering assumptions that could go
into that.
JOHN GEORGE:
When you're looking at the two
different passive soil gas collection system and the
three active systems, what combination of the five did
you select for incorporation into in the preferred
alternative?
DAVID WEBSTER:
Passive systems in areas two
and four and active ones in Waste area 3.
Are you
asking about how many vents and how much?
JOHN GEORGE:
Which of the two passive systems
did you choose and which of the three active systems did
you choose that are identified in Appendix C of the
supplemental feasibility study?
capital costs to work out.
I couldn't get the base
DAVID WEBSTER:
Okay.
I'm not sure of that
one.
And I'll get back to you on it.
I'm not sure if
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one of them was picked and if so --
JOHN GEORGE:
There's a significant value.
That present value in the order of a million dollars
difference between one end of the spectrum and the
other.
DAVID WEBSTER:
Okay.
Got that one, John?
.
JOHN SEBASTIAN:
Yes.
WAYNE GOLEC:
I'm going to ask you the
question.
Does Mr~ George or Remcor, they're
disagreeing with you, with his comments there, I assume
he was disagreeable with the preferred alternative.
DAVID WEBSTER:
He's disagreeable on what the
amount of cost savings if any there is with the movement
of that I presented in the option of moving Waste area 2
under the cap here.
Saying that by the time you
excavated and put it under here, you have spent as much
as you would have been saving by doing the slope.
Our
estimate of that says you save more money in not putting
the cap in the side slope stabilization here than you do
in the movement and it means that basically we've got to
look at the assumption.
WAYNE GOLEC:
You've already extended the
comment period another month.
I guess for Remcor or for
whatever, is this disagreement or discussion going to
hold it up, the cleanup any longer?
.. .
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DAVID WEBSTER:
What will happen to the
comments such as the one made in the normal period and
to the extent we can't, anything else is said tonight,
is consider it and then explain how it was considered.
So what you can expect on a comment like that one is
okay, here's our assumption, we considered it and this
"
is what we think now." And we may be in accordance with
8
what he's saying and may be --
9
But you don't see it as being a
WAYNE GOLEC:
barrier of any kind or a stumbling block maybe that
would --
DAVID WEBSTER:
I don't see it as one right
now.
To begin with that was an option that was kind of
vague.
Additional option out there is and one default
is to reject the option if the comments given --
WAYNE GOLEC:
I guess I didn't understand
everything he said.
But it sounds --
DAVID WEBSTER:
Basically he's saying it's not
a good idea.
He says engineer wise it doesn't save
money-
JOHN GEORGE:
He was right.
We were in
disagreement with the preferred alternative more or less
in total.
And I was also trying to clarify that there
really isn't any cost savings associated, in fact there
may be much greater cost associated with moving Waste
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area 2 under a cap in Waste area 3.
So it was yes and
yes.
ROBERT YODER:
My comment about the savings of
700,000 is based on your paper of July this past month
that states clearly estimated total construction
operation and maintenance cost $8,600,000.
If the
excavation option is ased $7,900,000.
So if Mr. George
is correct, then this statement is incorrect?
DAVID WEBSTER:
That's right.
That's based
on, everything in there is based on certain engineering
assumptions on how things are constructed.
So you can
come up with a cost.
And engineers as you've heard will
disagree on what the cost of something is on things.
ROBERT YODER:
That leaves us with less
confidence than before.
Are there any other --
I think anyone of the cost
DAVID WEBSTER:
estimates in there, we estimate the cost at this point

because one of the criteria that we use is cost to
assess it.
We estimate it, we give instructions to the
estimators that we're looking for something in the range
of plus 30 percent or minus 30 percent so right there in
a million dollars cost you're talking about anywhere
between 700,000 and a million and a half dollars.
okay?
Why that big a range?
Well, it costs money to bring
down the range.
We're considering costs so that we pick
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the cost effective solution.
I make no guess that we've
got in it down to the penny and some of the other
comments that Mr. George said is high, here's some other
things to consider in the cap that may save the cost.
And we'll consider those.
You'll get another cost
estimate when you design the cap.
And even that may be
.
different than what you get when you actually build it.
8
ROBERT YODER:
That underscores my expressed
9
concern about the burden to the taxpayer because there
is kind of a rule of thumb that everything always costs
twice as much.
DAVID WEBSTER:
Well, there are certainly
uncertainties in anyone of them and when we try to
estimate it.
We do think that we were more realistic in
our estimates of a cap on the site and the necessary
components than what was done in some of the estimates
in the focused feasibility study and John might take
issue with that but in looking at things with the soil
stabilization, you've heard a different opinion for
that, too.
JEAN WILLARD:
I'm not an engineer so I
probably am missing something but in the reading that
I've done, and what I hear you say, I hear a lot of
contradictions.
And between the first Record of
Decision and this one, I wonder if some of the EPA
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officials shouldn't read their own material and resolve
some of these contradictions.
DAVID WEBSTER:
What are you referring to?
JEAN WILLARD:
I just feel that there are
areas that as I said, I'm not an engineer so maybe I'm
missing something, but some of the decisions are not
making sense to me.
DAVID WEBSTER:
Okay.
Let me know if this
jogs any of the inconsistencies and I'll go through what
I think as being some of the differences between the
proposed plan of '88 and what's now.
a lot of similarities.
Because there are
JEAN WILLARD:
There are some but there's some
inconsistencies, too, and I just wanted to know when you
were working on this decision if you took a good look at
your first plan to meld it in with this one.
DAVID WEBSTER:
I think --
JEAN WILLARD:
You think you did in fact?
I think this preferred
DAVID WEBSTER:
alternative was done by a contractor of EBASCO which was
our pri~e contractor before and they added it on.
There
are some different details.
I think we had additional
technical input on the slope stabilization in the
interim there.
I've been at one landfill where the cap
was not stable and cracked on a slope for somewhat
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different reasons but it was next to a wet area because
it wasn't anchored and it slipped and I think that's
general engineering in the community that perhaps more
awareness of that.
Our first proposed plan didn't have
that in that.
Who knows but down
Are we better now?
the road we may be better off if this prevents it from
sliding.
Other differences we have thanks to work in
the focused feasibility study we have a better area, in
the area of extended contamination.
There's a lot more
tests done up there so the print of the cap has changed
a little bit from one to the other one.
The nature of
materials, maybe you can help me out.
But I don't think
it's changed a whole lot because basically we're looking
towards the law which governs hazardous waste sites and
the regulations EPA has developed, the guidances EPA has
developed under that to look at what's necessary- I
think another change is looking at the active gas 
emission system and a big change is the French drain.
It was not in the proposed plan two years ago and that
comes in a lot of the raised concern of wait a minute,
you don't understand the interaction between the water
and the waste.
I'm looking at that and we hope we're
making a better decision saying there's something that

we can enhance, we can add to effectiveness of isolating
the waste from the groundwater by putting this
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interceptor French drain above it.
I hope, you know, I
would believe that it would work better because of that
because there is less water that's going to be flushing
through the waste.
There are differences and they have
to do with more, I think, study.
I think that more
study produces better solutions, probably so, and you
reach at some point whereby if I rattle off a couple
more feasibility studies, you reach diminishing returns
at some point on it.
But I can never say that we
wouldn't learn more if we studied it more.
WAYNE GOLEC:
If Remcor was doing the testing
at the site with the PRPs and EPA was taking their
material, why does there seem to be a disagreement now?
Why didn't you and Remcor get together or EPA and Remcor
get together and say this is what we found, okay, we see
that's what you found, but we're going to do -- it would
be better if you did that and come here with a plan that
you both agreed on.
DAVID WEBSTER:
That would be optimal.
~y
didn't it happen?
My perception and John George can
give his if he wishes but we got in the focused
feasibility study one alternative that we didn't think
we are meeting the nine criteria fully.
Based on
different interpretations of what risks were, what
relevant and appropriate laws were, and at that point,
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we said well, that if that's not going to be evaluated
we better evaluate what we think does meet those
criteria.
WAYNE GOLEC:
They were looking at money, you
were looking at --
DAVID WEBSTER:
We were looking at the same
criteria, they evaluated those criteria but I think
there were different interpretations if you want to
elaborate on that.
JOHN GEORGE:
I think we were working off of
some fundamental disagreements with respect to the
endangerment assessment that was done in June ~ '88,
that established the basis in risk for performance of
remedial action at the site.
And we were also looking
at integration of the source control remedy with
management of migration which EPA was also looking at it
but we were looking at it from a little different
perspective.
We didn't necessarily see and some of the
objectives that are established in the supplemental
feasibility study for management of migration seemed to
be in excess of what were actually established in the
Record of Decision.
with respect to prevention of
groundwater contamination off-site, to us that's more of
a management and migration issue.
I guess we, bottom
line, we have some fundamental differences in terms of
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the approach to remediation of the site.
Partly in risk
assessment, and partly in the engineering.
We have a
difference of opinion, for instance, with respect to
Waste area 2, the waste is currently unsaturated,
monitoring wells in the waste actually monitoring
groundwater immediately below the waste are clean.
Wells that are just d0wnqradient of the waste area.
The
leachate seep which is seep four on the eastern side of
the slope is progressively been getting cleaner over
time to the point where the only contaminant that
exceeds the safe drinking water standard MCL exceeds it
by one part per billion in the most recent sample.
don't really feel that that waste area merits an
We
impermeable cap.
We don't see any real benefit to an
impermeable cap on the waste area here and there's a
mechanism, Resource Conservation and Recovery Act, RCRA,
that allows for what's called a hybrid closure which is
a closure of a landfill where there's no ground water
threat with a, with no requirement for low permeability

No requirement for a cap as such and these are
cover.
some of the disagreements that we've had kind of on an
ongoing basis.
DAVID YESMAN:
Would it be possible, based on
what Mr. George is saying tonight that there appears to
be some changes in the way things are at the site, would
I
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it be possible to go back and reevaluate the
endengerment assessment made for ROD 1.
And if in fact
that the assessment would change now because things are
changed, that it may be possible to change the focus of
what is proposed now to more closely parallel to what
Remcor is suggesting?
DAVID WEBSTER:
We did look at risk assessment
although it wasn't required of Remcor and based on that
consideration we thought that that was the best
assessment to do with the site right now was that that
implication of the risk in the air, direct contact and
groundwater.
Certainly they have analyzed this and put
it in their feasibility study, we looked at it back and
forth and put some things in the administrative record
saying how and looking at these alternatives and our
alternative, where the criteria, where we come up with
on making that.
A lot of it has been done.
This is
somewhat of a second chance because it's also an
opportunity along with the folks in town also
responsible parties making their engineer decisions on,
wait a minute, you want two feet, how about one foot and
these are also comments that we take a look at.
So we
look at the value particularly at those instructions,

some of them that sound new, other ones are ones that
Remcor put forth in the focussed feasibility study.
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DAVID YESMAN:
I have one other question, that
deals with the comments that were made about the
residual moneys that have been spent. But yet not
reimbursed by, to EPA by PRPs that were not part of the
consent decree.
What kind of dollars are you talking
about that this has to be paid off by the other PRPs.
Ball park.
BILL STEELE:
Three million estimated on the
special notices, at the time of special notice, and past
cost of 1.75 million was collected.
Estimated three
million.
DAVID WEBSTER:
Part of the settlement, doing
that.
As well as reimbursing.
It had a date of
expenses to occur.
DAVID YESMAN:
So that leaves a balance of
1.25 to be absorbed by the other PRPs?
DAVID WEBSTER:
In past costs.
Before that
date.
Then there have been expenses since that time, a
lot of them because Remcor had been doing the
investigation, not paying, but for example, our
analysis, being here tonight, our evaluation of the
supplementary feasibility study, enforcement actions and
such, there are continuing EPA's expenses.
What will
happen, enforcement wise, is a couple things.
First,
once a Record of Decision is signed on this one, we will
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be contacting parties as far as trying to come to an
agreement on this.
As a separate issue, that I'm not
going to comment exactly on what EPA's long-term
strategy is, is to try to collect those past costs of
1.25 from the non-settlers, the people that did not
6
participate in that first agreement.
DAVID YESMAN:
What's the bill so far on this
8
go around?
9
since that last date up until
DAVID WEBSTER:
now?
DAVID YESMAN:
Got a rough idea?
Yes.
DAVID WEBSTER:
I really don't know what it
has been.
I'm going to have to defer because I'm not
4
project manager on this one.
The cost, one of the
expenses has been the oversight of the activities that
we are going on with Remcor, another one has been a
contractor hired to evaluate and come up with some of
the cost estimates that we've heard tonight.
DAVID YESMAN:
You think it's over a million
dollars?
DAVID WEBSTER:
What I'm not sure on is in
that agreement what the structure was for reimbursement
of EPA oversight costs, anybody want to help me with
that one?
BILL STEELE:
Estimated at 750,000 at one
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juncture.
DAVID WEBSTER:
Typically I think we're going
on a bill as you go basis.
In other words, Emhart and
Textron have, let me, typically PRP signing on an order
like that, there's a provision that every year EPA will
calculate what it's spent on oversight and send a bill
to the PRPs for recovery and I think that's the way that
that order is structured.
I can't be positive without
lookinq back on it.
In those which the oversight cases
aren't part of that bill, they have been settled up by
one of those two responsible parties.
JOHN THURBER:
I don't want to monopolize this
hearing but there's one thing that's bothering me a
little.
That No.7.
Five year reviews.
As I
understood you to say last July, no guarantees when
there is all done that there is going to operate it as
you intend it, am I right?
DAVID WEBSTER:
There's no guarantee.
JOHN THURBER:
Now five years from now we've
got a review, find things aren't working as you
anticipated.
Then what happens?
DAVID WEBSTER:
We haven't gotten that far in
the process but what I would anticipate if I was doing
it today, you would look at it and see if there is,
should be an amendment to what the decision was made.
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Maybe it's the new technology that's come across.
Maybe
it's a finding out that there was, this was not the best
material.
Maybe there's a better material and it's so
much better that we should be putting that as a cover
over it instead.
Maybe it's a look and seeing that the
slope stabilization could be reinforced and we're
getting some slipping: in the cap.
It may be looking at
8
the institutional controls and saying gee, they're not
9
being enforced, something that's going to change.
If
there is a need for a change, we look at the Record of
Decision.
And we have kind of policies on three
different levels of changes.
One that we consider
rather minor, we'll make the change and announce the
change.
If it gets into the higher categories then it
requires going out, a proposed change, going out for
public comment and getting basically a Record of
Decision.
JOHN THURBER:
And that could mean another 8.6
million down the road.
DAVID WEBSTER:
There are a lot of
uncertainties.
BILL NEWMAN:
If something is going, I'm using
just plain language, going to hell, why do you have to
wait five years?
In other words, after two years
there's things that have to be remedied, it's going to
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be much worse at the end of five years, why not do it at
two years?
DAVID WEBSTER:
I hope we're thinking as
logically as that and I had would like to think we are.
We're not that far away from it.
If, for example, the
cap started sliding down the hill, and there were fumes
being detected coming:out from the landfill, I don't
think we would wait for the end of five years.
In the
operation and maintenance portion here, we'd be looking
to do that and whether it means that EPA doing that or
responsible parties doing that, we consider that
operation and maintenance to look for things that need
to be corrected.
Maybe it's the fence gets knocked
down, we're not going to wait five years to fix the
fence.
We have an operation and maintenance plan
associated with the work.
JOHN GEORGE:
With Emhart, Textron and the
town under a consent order for design of Operable Unit
#1, issues like the side slope stabilization being
potentially affecting a portion of that design, how does
EPA intend on integrating the final Record of Decision
for ROD 2 with what we're currently attempting design
for ROD 1?
DAVID WEBSTER:
I think -- I don't know.
There's been some talk of that and I think that if it
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looks like before we move forward on something in the
imp~ementation schedule that it might be a bona fide
reason for holding back on that.
For example, if we're
putting in something that has to be covered over later
on with a slope stabilization, I think we're aware of
that possibility-
But I think considering things
speculative enough now and not at that critical juncture
to act directly on that right now.
Do you think I'm
mistaken from your perspective on that?
I mean we're
going to use common sense as far as if you're worried
that we're going to enforce, put this in this month and
now dig it up and put this cover over and then put it in
again underneath it.
JOHN GEORGE:
I think though that if that's a
real possibility that we probably ought to hold now on
what we're doing until we get the thing worked out.
DAVID WEBSTER:
Well, I hope we're proceeding
reasonably so far on the design and that could be
discussed.
JOHN GEORGE:
Okay.
TOM MOYE:
And there are certain things that
could be done that are unrelated to eastern side slope
stabilization like the west side.
DAVID WEBSTER:
I think that the conversations
we've had that the western slopes aren't affected by
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Seavers Brook.
So there are things to go and then as
2
we're still in the P 0, permit application and
everything else.
3
PRESTON CHILDS:
I don't know if this is an
appropriate question but it's one on my mind.
I think
you've done a commendable job.
I think you're very
.
sincere about your job.
I think both of you men are
highly qualified but you have differences of opinion.
This is understandable.
What I want to know is what
government agency came up with the brainstorm of saying
we're going to have a Superfund and what knowledge do
they have.
If you engineers who are working with this
on a day to day basis, you're trying to adhere to a
Congressional law.
But who designed that law?
Do they
know what they're talking about?
If you two gentlemen
who are highly qualified in your field have a difference
of opinion you're still free to adhere under a law that
we don't know they knew what they were talking about.
DAVID WEBSTER:
I'm not sure I can respond to
that.
PRESTON CHILDS:
We operated at the time we
had this springfield landfill, we operated under the
guidelines that the State had at that time.
Now the
State is out of it free and clear.
It's our ball park.
Who's to say that we are operating under your, the law
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we have today to the best of the knowledge that you have
but ~t still isn't going to work?
We're going to pay
3
and pay and pay, build, rebuild, until this sort of
thing is going to have anything.
I'm concerned, as I
said, probably my question can't be answered but it is a
6
question I have in my mind.
We try to do right.
We
went under the existing guidelines for the state at that
8
time.
They didn't know
And I'm not faulting the state.
9
the ramifications of the toxicity but it wasn't that we
were a problem child and rebelling against their
guidelines.
But we have to pay and they don't.
Okay?
state's out of it.
It's our ball park.
Now again we're
trying to comply with laws and in all intent we think
we're doing, we're being compelled to do, go by the
laws, when they may not be right either.
DAVID WEBSTER:
Don't have a whole lot of
response.
There's a lot of things.
Do we know how
Congress developed laws?
I'm sure there's a lot of
people having input on how that's done including EPA and
EPA is certainly in there opposing, proposing, this is a
good idea.
Certainly lot of people in public and
companies were thinking it was a good idea, too.
I
don't know how to respond on that one.
I can go through
liabilities and what it is.
I think basically Congress,
I'll get a little philosophical, faced with a problem of
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who is going to pay for these waste sites and says is
there anything that's equitable and they probably
scratched their head and said no.
Is it right to make
it the general tax revenues and make everyone pay for
everyone else's hazardous waste sites, no.
And probably
came up with a scheme that says well, here's a group of
parties Which ~ think:may have had the best intentions
in the world but we're going to name them liable.
Owners, operators, parties.
I don't think anybody's
going to make a contention that there's in most of the
cases that I see there's maliciousness or intent or
certainly not some kind of adherence to what was going
on all around the country-
I think, you say you had
good intentions, I think Congress did, to.
When they
saw the outcry, pass the bill.
And I think there's some
really hard questions.
And they're hard engineering
questions, they're hard assumption ones, how clean is
clean, should it be permanent, should you dig it up, who
should be liable.
If anybody tries to tell you these
are easy ones, don't believe them.
ED BATTLES:
Mr. curtin did not participate as
a PRP in the first ROD, right?
DAVID WEBSTER:
In the first consent decree,
correct.
ED BATTLES:
If Mr. curtin decides to, you
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have a three to five year plan here to get whatever that
you ~ecide to do into operation, if Mr. curtin decides
that he's not going to participate in the second step
and all of a sudden Mr. curtin decides that he doesn't
want anybody else on his property, does the EPA have the
authority to go in and do this work whether Mr. curtin
wants you there or not or does it have to go through the
Court system?
DAVID WEBSTER:
We have authority to go get
access to properties for the purposes of investigating
or responding to release or potential release of
hazardous substances.
Exactly the legal mechanisms, I'm
not sure.
I know in some cases we go to a judge to get
a court order to get on property-
Whether that's the
case here, I'm not sure.
But we have authority whether
that's through the Court or administratively to get on
the property for the purpose of doing the action.
ED BATTLES:
The question I'm asking is how
long could this be tied up in the courts beyond the
three to five years?
DAVID WEBSTER:
Oh.
Is there a lawyer in the
crowd that wants to speculate on that one?
I think a
long time.
And you just hit, access is one potential
issue.
We have other ones.
Let me not be pessimistic
on it.
The way that the Act is structured, if there's
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1
not a settlement, EPA has a couple of options.
One, it
2
can order administratively one or more responsible
parties to take any or all the actions that have been
3
4
involved.
5
ED BATTLES:
We understand that one.
6
DAVID WEBSTER:
Now, if they say no, then my
7
understanding it goes:to court pretty fast at that
8
point.
Another option is that we have is to use the
9
Federal Superfund money which is used to get industries
to do that work and try to get that money later on.
That is a way that might not add, doesn't hold up the
act but will that end up in court, probably, because we
will take action to recover that money-
ED BATTLES:
That wasn't my question.
My
question is do you have the authority to go on that
property?
DAVID WEBSTER:
Right now?
ED BATTLES:
To do this work?
DAVID WEBSTER:
We have the authority in
No.
the statute to take the steps to get on the property.
Do we have an access agreement or court order in hand

for John Curtin's property, I don't believe so, but I
don't believe so but I'm not the one day-to-day.
JOHN PARKER:
We have the mechanisms to do
that.
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DAVID WEBSTER:
We have the mechanisms because
clearly we have made decisions so it has to have been
possible for us to go on that site.
So the law has the
authority to go on there.
Whether we take the steps and
go to the right administrative person or judge, I don't
think we have.
But I could be wrong on that.
JOHN PARKER:
It could happen very quickly,
too.
ED BATTLES:
What I'm asking is could it be
held up for several years in court?
DAVID WEBSTER:
It could be held up in court.
Several years.
Depending on the issue.
Once it's in a
judge's hands, what control we or the parties that were
in litigation would have very little to do with.
JOHN PARKER:
Depends on the nature of the
remedy that you sought.
DAVID WEBSTER:
You're hitting on the access
one because that's a very good point because there's a
lot of other ways that --
ED BATTLES:
I'm not talking about the access,
I'm talking about the physical work, do you have the
authority to do the physical work on his property?
DAVID WEBSTER:
In the statute.
Yes.
Specifically to this site it hasn't been pursued.
ED BATTLES:
Without his permission?
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DAVID WEBSTER:
In the statute, yes.
In a
specific court order or agreement for this site, no.
think, there's some access agreements but I think it
I
pertains to Emhart and Textron getting on to --
WAYNE GOLEC:
If he says no, you go on and do
the work anyway and then you go to court afterwards?
.
DAVID WEBSTER:
As I understand access law,
and I'm on my fringe here, there's a step of us getting
a court order by the authorities in the statute to get
on the property.
ED BATTLES:
Is that like eminent domain,
John, simi1ar?
JOHN PARKER:
Not really, philosophically it's
different.
You have a very specific, very narrow issue
here, but the EPA has some mechanisms to move ahead if
necessary.
ED BATTLES:
What I'm getting at is they're
talking about three to five years before this but what
happens if he decides, is it going to drag, can he drag
it through the courts for another five years before
anything is done?
JOHN PARKER:
Depends on the nature of the
remedy that the moving party would seek.
you can get very quick answers now.
Some things
ED BATTLES:
But it would be possible for him
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to drag it through the courts for a long period of time.
JOHN PARKER:
Depends on the procedures,
what's initiated and what the remedy is that's sought
and so forth.
There's no black and white answer to
that.
DAVID WEBSTER:
We've taken those steps on
other sites to get access and it's happened in the time
frame of months rather than years.
JOHN GEORGE:
You brought up the issue before
about the source control wells.
I was wondering two
questions.
Why two source control wells and second one
is there's a diseussion in I believe it's Appendix D of
the supplemental feasibility study that the intent was
i
to reduce the eastward limit of the capture zone for the
wells to the extent possible.
I'm wondering why two and
then the second question, why would you want to reduce
the easternmost extent of the capture zone of the wells.
DAVID WEBSTER:
Extend the easternmost extent
of the capture zone?
JOHN GEORGE:
Why would you want to reduce the
capture of the wells by moving towards the east?
DAVID WEBSTER:
Basically did the analysis on
.
what would be optimal as far as the source control wells
for cutting down the contamination, that's what caught
me a little off guard in your statement.
Because in
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SODe o£ your alternatives, I don't know in your
pre£erred alternatives offhand you had one source
control well i~ there.
JOHN GEORGE:
Well --
DAVID WEBSTER:
Basically looking at that
saying one's good, two's better in analyzing it.
JOHN GEORGE:
Two costs twice as much.
DAVID W!$S'I'ER:
There are certainly
trade-offs.
And part of the thought was I believe the
sand and gravel aquifer that these are tapping into,
you're in this area someplace in bere you're on the
divide in the sand and gravel aquifer where with the
sand and gr.a~l aquifer-s going towards Seavers Brook or
contributing tQ1be bedrock aquifer that in part is
going to the Black River.
And while you have further
down here in the first operable unit wells that are
extracting water from the sand and gravel aquifer, this
is kind of your last chance on anything that's getting
down into the bedrock.
So let's design that to try to
pull and keep things from going into the fractured
bedrock in this direction.
So I think there was an
effort to do it close enough to a££ect out towards, as
far as possible towards the east.
JOHN GEORGE:
There's a statement though in
the appendix that: says that you want to limit the
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t
eastern extent of the capture zone of those wells.
Tha~'s why it's in conflict with what you're saying now.
I'm not sure why you want to limit that. 
 DAVID WEBSTER: I'm going to have to get back
to you. Unless, Tom, you have any idea on that one.
TOM MOYE:
No, I don't.
I can
I'm not sure.
.
look at the intent was and maybe, in response to that
comment relook at the analysis that was done as far as
the number of wells at the site.
ED BATTLES:
I'd like to ask Mr. George a
question.
You I believe read in your statement
something to the effect that the French drain that is up
there on the picture, that your French drain, you still!
had a French drain in but it wouldn't be as deep, right?
JOHN GEORGE:
No, it wasn't so much that.
That French drain detail doesn't really show --
DAVID WEBSTER:
There's a plastic on one side.
JOHN GEORGE:
I'm showing you what I was
talking about.
If there is what we're looking at here
as far as Waste area 4, this is the northern side and
this is the southern side.
Of that French drain.
See
if you're looking at this, if this is the northern side
of the French drain next to Waste area 4 and this is the
southern side with the hillside coming up over here,
what the EPA French drain system contains is a flexible
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membrane down the side adjacent to Waste area 4, about
25 feet deep with a twelve-inch corrugated pipe,
perforated pipe at the base.
What we're saying is the
intent of that as I understand it was to prevent
contaminated groundwater from migrating from Waste area
4 into the drain.
What we were saying is that if
.
instead of allowing the drain to collect both surface
water and shallow groundwater flow, if you put up here a
collection ditch and pick up the surface water and move
it off which would be clean, and you use the French
drain to collect only the groundwater then you're going
to have a relatively low flow.
You can allow that drain
not to have an impermeable barrier on the side adjacent
to Waste area 4, let the water from Waste area 4 come
into the drain and treat it because you'll have 
treatment capability available through the management of
migration treatment system.
That would be a more
effective way, more cost effective way of drawing the
water table down in Waste area 4 which you need to do in
order to cap Waste area 4 than to install the dewatering
wells in which one of the four waste wells but we
attempted to pump a well in one of the waste wells in
Waste area 4 during one of the study and finally divided
organic material came out of the waste drain and we just
couldn't pump it.
. .
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ED BATTLES:
Isn't there a large amount of
wa~er coming off the southern slope?
JOHN GEORGE:
Surface water?
ED BATTLES:
No.
Underground water.
No.
Isn't most of the water feeding into area four actually
coming off of the uphill side, southern side?
.
JOHN GEORGE:
There's a lot of surface
drainage area onto Waste area 4.
You could pick up a
lot of surface area runoff with a collection ditch.
ED BATTLES:
Let me ask you this question,
then.
Do you know where the water is coming from that's
cominq out down on Seavers Braok?
JOHN GEORGE:
We believe we do.
ED BATTLES:
Is that water coming from the
southern side of Waste area 4?
JOHN GEORGE:
To an extent it is.
ED BATTLES:
Southern sides up the hill,
right?
JOHN GEORGE:
There's a certain water
Yes.
that enters Waste area 4 and moves down through about 60
feet of till.
Glacial till and enters the sand and
gravel drain.
That sand and gravel unit that kind of
cuts across the site from the southeast to the northwest
and we believe empties into the seeps that are on the
Seavers Brook Road.
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ED BATTLES:
Now, the seeps, are you referring
to the seeps on Seavers Brook Road as the springs?
the springs on Seavers Brook Road the same as what
Are
you're referring to as seeps?
JOHN GEORGE:
The ones that I'm referring to
are the ones that are inside the fenced area.
ED BATTLES:: That's the springs, okay.
WAYNE GOLEC:
Are you putting French drains
down there?
DAVID WEBSTER:
Down by Seavers Brook Road?
WAYNE GOLEC:
Yes.
DAVID WEBSTER:
It was called for in the ROD,
you guys can help me, too, that the collection would be
subsurface or so there won't be volatilization.
And we
had one scheme for that in the proposed plan of ROD and
I'm not up to speed who what may have proposed something
different but achieve the same directive on design.
WAYNE GOLEC:
One there and would the other
side, they are not in --
DAVID WEBSTER:
That's first operable unit
stuff.
That's in the leachate seep collection.
WAYNE GOLEC:
I thought they were supposed to
be already started then.
DAVID WEBSTER:
First operable unit which is
what the '88 ROD was went out and signed an agreement
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this past May by the judge to effect that one.
And we
are in, they are designing that one now.
That would
include the mechanisms at down by Seavers Brook Road and
along the eastern seeps to collect those seeps without
allowing the volatiles contact with the area.
in the design phase, they're not in there.
So that's
.
WAYNE GOLEC:
They will collect the seeps?
I
thought they were in or supposed to go in shortly,
though.
DAVID WEBSTER:
They are being designed.
WAYNE GOLEC:
What's shortly?
Couple years?
DAv:ID WEBSTER:
I think you're realistic
talking that way.
The one that seems tc be on the
critical path right now is not the design of that system
by Seavers Brook Road, it's what to do with the
collected water.
WAYNE GOLEC:
If you stop the water that's
coming down the hill in the four isn't that the water
that goes across the gravel and that goes up to in
Seavers Brook?
JOHN GEORGE:
That's why it was a little bit
difficult to answer that question.
That's not just that
water, there's other water coming from a lot of
different sources.
ED BATTLES:
With all the wells that you have
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put up there, have you been able to locate or have you
been able to determine how much say gallons a minute of
water is coming down off of that hill in the four and
going down into Seavers Brook area?
JOHN GEORGE:
within the limits of, within
fairly close limits Z think we have been able to do
that.
Short of beinq:able to measure every input to the
system and knowing exactly where all the water goes
through to, you can measure exactly what flow is ending
up in a particular place.
You can't get that 100
percent but we did develop in the feasibility, focused
feasibility study a water balance for the site that I
think hangs together pretty well.
In other words, it is
really a balance.
You take the information that you
have on rainfall and snow melt, entering in certain
areas as you portion that across the site and you
measure the flow say to leachate seeps and you go back
and check and does it make sense that with bedrock
groundwater entering sand and gravel with a certain
amount of flow with certain sand and gravel been with a
certain amount of infiltration can I come up with the
flow that I'm seeing over western seeps and the model I
think, I think that the model that we presented in the
focused feasibility study hangs together fairly well.
So that we, within a certain amount of error, I
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l
1
wouldn't, we could do it definitely without any error at
alJ but I think within an acceptable area, we can do
2
3
that.
4
HAROLD MILLAY:
Do you know how many gallons a
5
minute is going out there now?
6
JOHN GEORGE:
out the western seeps?
7
HAROLD MILLAY:
Yes.
8
That flow is fairly constant'.
JOHN GEORGE:
I
9
think it's about 35 gallons per minute.
ED BATTLES:
I think it's probably a little
more.
HAROLD MILLAY:
55.
JOHN GEORGE: When I say 35 gallons per minute~1
I'm saying an average basis over the year which is the
way we did the water balance.
There may be certain
times when there's going to be contributions from snow
melt or rainfall.
ED BATTLES:
Those springs never change.
They
run the same yearround.
They ran the same in the middle
of the winter as they did in the spring and in the
middle of the summer when it was the driest summer
around.
HAROLD MILLAY:
That's one culvert that takes
care of the whole thing.
~ake a bucket and watch it and
it comes up around 55 gallons.
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JOHN GEORGE:
If we projected 35 on the water
balance and it was a hundred and 35, that would be
close.
If it was 55, that would be great.
ED BATTLES:
Now let me go back to the French
drain.
Is the French drain going to collect most of
that water?
JOHN GEORGE:
It wouldn't collect most of it.
It will collect a portion of that water.
DAVID WEBSTER:
I think one thing, correct me
if I'm on a different track here, but in putting the
French drain in the proposed plan it was to dewater the
water that was going through the waste.
That's not
going to get rid of water that's coming down the hill
beneath the waste and ending up in that sand and gravel
unit and coming back out.
We're not concerned about
that.
ED BATTLES:
How deep is that water coming
down off of the hill going through Waste area 4?
DAVID WEBSTER:
There's no sand and gravel
here so it's basically till overlying bedrock, right?
I
mean up this in this area?
JOHN GEORGE:
Right.
DAVID WEBSTER:
So you're not talking about a
unit which has a lot of permeability which is why I
would agree with what John said, major factor is how
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much is coming on the surface.
ED BATTLES:
You're saying now the water is
running through bedrock before it enters four?
DAVID WEBSTER:
What I'm saying is the
bedrock, the fractured bedrock may be the most permeable
strata that you have in generally coming down here.
Is
.
that true or will they take sands in there?
TOM MOYE:
It's more permeable than the till.
DAVID WEBSTER:
We're not putting the French
drain down to fractured bedrock.
One because what with
the stuff that's going down for the fractured bedrock in
there isn't intercepting the waste.
It's getting away
from our purpose of the French drain which was to lower I
the water table and keep the water from going through
the waste.
ED BATTLES:
I'm -- just one more question.
DAVID WEBSTER:
I'm sorry this is frustrating
for you.
ED BATTLES:
That's all right.
No problem.
with all the drilling and everything that you've done up
there to locate the water and so on have you had anybody
walk from Seavers Brook Road up from Will Dean Road to
the main road across the southern side of that which
would be above the French drain and dowse it and tell
you how much water is coming off that hill?
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DAVID WEBSTER:
Not to my knowledge.
2
ED BATTLES:
I suggest you do it.
There's
3
some pretty good dowsers around.
There's some that can
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5
tell you, the old-timers can tell you where it is and
tell you how deep it is and how much is there and
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th~Y're awful close.
I know it's not very scientific
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nowadays.
~ut it bas~turned up a lot of good wells.
8
Preston's got an awful good spring that I dug with a,
9
bulldozer.
You couldn't see a drop of water but the
do'Wser found it.
WA YNE GOLEC:
It was mentioned tonight that
Waste area No.4 is running cleaner than it was before.
DAVID WEBSTER:
I think he was talking about
Waste area 2.
JOHN GEORGE:
I was talking about leachate
seep four.
DAVID WEBSTER:
Down in this area.
WAYNE GOLEC:
If it's been 20 years since
water's been run through these chemicals, why aren't the
chemicals all gone?
It's coming cleaner, that's a good
sign.
Why are we bothering --
DAVID WEBSTER:
First, I may be on shaky
ground but there's inconsistency with the data coming
in.
There was one hit which hasn't been replicated in a
couple of sampling rounds, is that the leachate sample?
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JOHN GEORGE:
Actually we sampled in August
and the state sampled in May.
And leachate seep four
our results for chlorinated ethanes (phonetic) which are
the volatile contaminants of concern were remarkably
similar.
That's a sample there back in 1985 and then
subsequent years I believe there were two or three
samples that showed considerably higher levels but it
would appear as if leachate seep four is on a downward
trend as far as contamination is concerned.
And as I
said, the only, there is one parameter, one contaminant
that exceeds it's MCL by one part per billion which is
almost beyond the limits of being able to make a
distinction in the most recent analysis in leachate seep
~
four.
WAYNE GOLEC:
But there's Ostill concern that
it should be cleaned up.
DAVID WEBSTER:
We look at it as that that is
an area of hazardous waste disposal that hasn't been
cleaned up and the risk associated with that is part of
the plans to cap that to cut off the contamination.
WAYNE GOLEC:
Is it possible what they're
seeing is that maybe it's just cleaning a certain area
and everything else is just waiting to move in on it?
DAVID WEBSTER:
It's possible.
I'm not sure
if that's the only place that the water is going from
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that one, from the waste area and maybe that's like a
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record to walk away from at this point.
Obviously we
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don't in our analysis.
We feel that that should be
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contained in that, either contained or excavated.
But I
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think those results were in our mind when we said also
look at maybe this is one that we can get by with
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something less costly=and I think in excavating it
because it doesn't seem to be as concentrated a source
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as area 3.
WA Y1m GOLEC:
Has the state approved the use
of the sewer plant yet?
TOM MOYE:
No.
WAYNE GOLEC:
Is there a reason for that?
will they?
TOM MOYE:
The consent decree that was entered
into by the three or four responsible parties required
that they submit an application to the state.
WAYNE GOLEC:
Who are they?
TOM MOYE:
The respondents, Emhart and
Textron, BFI and the town of Springfield.
They have
done that and the town, the State is reviewing that
application now.
But whether the state approves of that
with pretreatment or without pretreatment, the Town of
Springfield will decide whether they will allow the
leachate to go there or being pretreated or not.
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WAYNE GOLEC:
What are you looking for, how
will you decide?
TOM MOYE:
Well, actually, I'm not involved in
that process.
I'm trying to speak for another branch of
state government.
WAYNE GOLEC:
Any idea how it will be decided?
The industrial pretreatment,
BILL AHEARN~
there's a program called Industrial Pretreatment Group.
It's operated out of the Permits and Protection Division
and what they do is they look at the ability of the
treatment plant to assimilate, to take those substances
that are coming into the wastewater and to treat them,
successfully remove them and they look at the impact of
those substances on the sludge quality as well.
50
they'll be looking to see if the wastewater can come
into the plant and be successfully treated by it so it
doesn't just run through the plant and they'll be
looking to make sure that it doesn't change the quality
of your sludge in any way that will prevent it from say
a land application program or the composting program.
WAYNE GOLEC:
Will you be using Remcor's
results from the test to determine?
BILL AHEARN:
They'll-be using the results
that are submitted in the application.
50 in an
application the Applicant has to tell you what it is
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that they want to discharge so I'm not familiar with
this application.
But the standard practice is to look
at what the Applicant tells you is there.
it's consistent with the general practice.
To see if
For if
they're looking at leachate then they would like to see
what the leachate did and all the books showed this and
if you have something:that's in range, there isn't a
reason to --
WAYNE GOLEC:
You will look at just what the
PRP sends you?
You won't come down here to Springfield
and look through all the books?
BILL AHEARN:
You would look at what any
Applicant sent you and typically you set up a monitoring
program on that.
TOM MOYE:
I can tell you that the people that
are reviewing that application have looked, have come to
us for any other sources of information that we have
about the types of chemicals and the concentrations.
So
they're looking at EPA's reports, any sampling results
we have, as well as the information that was submitted
with the application.
BILL NEWMAN:
Aren't you having, you're having
a leachate coming from Newport, too, right, New
Hampshire?
And as well as this?
My question is,
another thing, I was wondering about:the capacity of the
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treatment plant to be able to take this as long as any
projected growth, you know, wondering about the
capacities and reserve of the sewage treatment plant?
TOM MOYE:
I believe those factors are
considered in the review of that application.
What are
all the sources of leachate to the treatment plant and
8
.
what would this proposed additional discharge, what
impact might that have.
9
BILL STEELE:
That's part of the 172 or
consideration, both the quantity and quality of the
leachate.
HAROLD MILLAY:
Any figure on the quantity?
BILL STEELE:
I don't have the figure in my
head.
HAROLD MILLAY:
55 gallons coming out Seavers
Brook, a minute, and I don't know how much on the west
side, you're talking maybe a hundred excess gallons a
minute, that's quite a bit, isn't it?
BILL STEELE:
The plant just for background,
the plant is rated at a hundred gallons a day.
Capacity.
A million gallons a day, two million gallons
a day.
We're climbing but we got there.
Right now
we're at approximately a million gallons a day.
It's a
lot of work.
Basically half hydraulic capacity.
JOHN GEORGE:
Question on the need for
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stabilization of the outs lopes , what are the different
points that provide justification for covering and/or
stabilization of the outs lopes of the two waste areas?
DAVID WEBSTER:
Covering we looked at the
relevant and appropriate standard and we thought and
concluded that that was not appropriate for the
stabilization for covering, putting a RCRA cap on the
side slopes.
What was in our thinking was that one, to
try to meet the, it was in our thinking was the
protection of the cap on top of it.
We had experts
saying that if you put that load on top on the plateau
area, and that's your slope after visiting the slope and
seeing the slope, they said that will fail.
That the
cap will crack, it wouldn't be able to support that
weight and you need to stabilize it in some way, look at
some ways and chemicals and cost, so it was basically to
protect the remedy on top of it.
JOHN GEORGE:
So if it could be demonstrated
through engineering calculations and in particular in
Waste area 3 that the outslopes would be stable with an
adequate factor of safety without any additional
stabilization to protect the cap that that would be
acceptable proof to justify any outslope covering or
stabilization?
DAVID WEBSTER:
I think you might follow that
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one up.
I think we would be receptive to any comment
made like that as far as the justification because it
was in our thinking that that was to protect the slopes
and to protect the integrity of the cap against possible
releases in capped areas in the future.
TOM MOYE:
John, I believe another reason was
8
.
to stabilize the side. slopes in such a way that promotes
runoff from the side slopes rather than and discourages
9
infiltration into that part of the waste area that's on I
the slope.
DAVID WEBSTER:
As far as meeting the
regulatory aspect of RCRA, of crea(ing a reducing runoff
and making a cover more impermeable than what you
needed, I think another factor that was involved was
thinking about the gas generation under the landfill.
And if you had an impermeable cap on the plateau and
something of much lesser permeability here, you better
be careful that you're not making a conduit to
concentrate the gas coming out in that conduit out the
side slope more concentrated than it was so there was
thinking back and forth between interaction between the
permeability on the side slope and the gas collection
system.
with that factored into the design of a side
slope is something that I'll respond to your office but
it would be something that was raised in the kind of
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evaluation that doesn't have an impermeable cover on the
site.
ED BATTLES:
You extended this period for an
extra 30 days, right?
DAVID WEBSTER:
Right.
ED BATTLES:
will there be another
informational hearing~at the end of that 30-day period?
DAVID WEBSTER:
We're not planning one at this
point.
ED BA'rI'LES:
Then as far as the public is
concerned, the plan that you proposed is the one that
you're going to go ahead with?
DAVID WEBSTER:
No.
We are still receiving
public comments.
Once the public comment period is
over, we have some things to start thinking about
tonight.
We anticipate that there will be probably some
Eore people that write in.
still looking at it, too.
John, I heard John George is
We consider the comment.
Consider the analysis that we did prior to the comment
and then try to make the best decision concerning both
of those factors.
ED BATTLES:
Then will there be a public
hearing as to what your final analysis is or are you
just going to go ahead and say this is what we're doing.
DAVID WEBSTER:
The latter.
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You're going to go ahead and say
ED BATTLES:
2
this is what we're doing.
3
After consideration of the
DAVID WEBSTER:
4
public comments, we will develop a Record of Decision
and sign that and that will be what we're doing on the
5
6
site.
7
The weight of the cap, you've
WAYNE GOLEC~
8
been discussing the weight of the cap, with heavy
equipment up there, I don't know what you're going to be
9
using, I don't know what the dump site was, is it
possible that the equipment or the weight of the cap
could cause a cave-in type thing with maybe something
rotting underneath or maybe a pothole or something
didn't fill in?
DAVID WEBSTER:
Are you thinking now or here
in construction or after it's finished?
WAYNE GOLEC:
Both.
DAVID WEBSTER:
Yes.
That's why we try to do
a plan that minimizes the chance of that.
That's what
we're trying to address.
People looking at it were
fairly concerned about the slope looking like it would
not support much weight.
WAYNE GOLEC:
What about in the center of the
landfill or could that be an area that would sink after
it was all done and rupture the cap or something?
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Because of the weight of it.
drag a big square thing --
I mean they
Do they know?
2
3
DAVID WEBSTER:
I've heard some discussions in
4
considering it particularly in Waste area 4 where you

have a subsidance from the waste and I don't know, I
5
6
can't say it was considered and this is what we did
7
about it but I think this is something that we should
8
consider if it hasn't been.
You get in a particular
9
municipal landfill it's more like a mountain, you get
kind a bit of sides down there and you contend with that
in your design plan for the cap.
It's a little bit
different situation on those filled ravines and you
expect, it may be more catastrophic nature of all of a
sudden sliding as opposed to --
WAYNE GOLEC:
I understand it does settle
under there under the trailers or it did.
 DAVID WEBSTER: The trailers down towards the
waste area?     
 WAYNE GOLEC: I don't know. I really don't.
 DAVID WEBSTER: Because of the trailers aren't
on top of waste.
As you can see from that but there are
some down in here that are or were pretty close, right?
JOHN GEORGE:
Waste area 2.
PRESTON CHILDS:
In today's mode of business,
have to be responsible for their actions and area
people
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of responsibility, somebody has to answer if they design
something and it failed like we had a school that burned
2
3
up and passed engineering studies and the whole thing
4
status and the whole thing bit.
In answer to Ed's
5
question you're going to take the input of the meeting
tonight and the subsequent written comments, evaluate it
6
7
and come out and say,-okay, this is the system we're
8
going to put in.
Okay.
If it doesn't work, you're
9
responsible?
I'm saying in private enterprise, this is
the way it is.
And you're the one that's going to
finally come to the town and say this is what, is the
system that's going to be instituted correctly to
correct it.
What is it, is it an experiment?
Is it an
$8.6 million experiment or is somebody accountable for
it?
DAVID WEBSTER:
Kind of uncertainty.
We try
to factor in a decision to try to make the best decision
possible.
I don't think as far as if it required to
amend it 20 years down the road, come up with something
else, because of something that was not taken into
account --
PRESTON CHILDS:
If the first five-year
inspection doesn't hold up?
DAVID WEBSTER:
Then my first concern is to
modify the remedy so it's protected.
Who's liable from
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~
that, I don't believe under the statute EPA or me
personally are liable for that.
And I think if you had
it you wouldn't find too many people going into
government service.
PRESTON CHILDS:
Am I from a reasonable
assumption then, this is an $8.6 million experiment?
DAVID WEBSTER:
Depends on your definition of
experiment.
If you're saying experiment with anything
without a guarantee on it, if you're saying that we use
the best judgment that we have available to come up with
it, if you consider given that that it's still an
experiment, yes.
I think in some respects, what we've
proposed is not from a financial viewpoint but from a
technology viewpoint might be looked at as the
conservative approach of this is more the traditional
approach to take care of the landfill.
Cap it, try to
control the contamination whereas something along the
lines of vitrification and fire remediation or
incineration or some on other kind of stabilization or
going with a flushing scenario might be considered more
experimental if you will.
I don't know if that, you
take any heart in that one.
As people start to drift
out, written comments are accepted and you're encouraged
and to do that.
WAYNE GOLEC:
Would you look into the Remcor
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co~and post decontamination center, see what you can dol
on your end to move things a little faster so that they
can do what they have to do to leave sooner?
2
3
4
We are and I'm not aware of
DAVID WEBSTER:
5
I'm not involved in that.
that.
6
I am looking at the process for
WAYNE GOLEC:
7
moving the dumpsters."
8
I know, you're getting that
DAVID WEBSTER:
9
inferred that there was something that Remcor was
waiting for an EPA approval in order to do that.
I
don't know what that is.
WAYNE GOLEC:
Something you could say hey --
DAVID WEBSTER:
Do you know what it is as far
as taking the drums off-site?
I don't know what it is
as far as the Command Post.
I know they spend a lot of
time in it.
And I'll check up on that.
WAYNE GOLEC:
Okay-
DAVID WEBSTER:
Okay.
Thank you very much for
coming out.
HEARING ENDED AT 10:10 P.M.
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1
2
C E R T I F I CAT E
3
4
I, Cynthia Foster Benson, RPR, Notary Public and
5
6
Court Reporter for North Country Court Reporters, West

Lebanon, New Hampshire, on August 2, 1990, do hereby certify
8
that the foregoing pages 2-through 101, inclusive, comprise a
full, true and correct transcript to the best of my ability
7
9
of the Public Hearing to Receive Comment on Proposed Plan for
10
Second Record of Decision in re:
Old Springfield Landfill
11
Superfund Site, as to which a transcript was duly ordered;
12
Dated at West Lebanon, New Hampshire, this 15th day
13
of August, 1990-
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ATTACHMENT D
EPA RESPONSE TO CONTAMINANT

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ATTACHMENT D
EPA COMMENT ON THE PRPs' CONTAMINANT DESORPTION MODEL FOR WASTE AREA 2
EPA concurs with the observation by the PRPs' consultant that
examination of available groundwater sampling results for Waste
Area 2 collected from 1985-1990 indicate evidence of a decrease
in total VOC concentrations as measured at leachate seep LSE-04.
EPA does not, however, concur with certain conclusions of the
desorption model presented by the PRPs' consultant with respect
to projected timeframes for natural remediation of volatile
organic contaminants in groundwater at LSE-04. In particular,
EPA does not concur with the desorption model prediction that the
total volatile organic (VOC) concentration in groundwater at LSE-
04 will necessarily decrease to less than 5 ug/l total VOCs by
1991.
First, as is clearly demonstrated in Figure 1 which accompanies
the PRPs' desorption model discussion, the actual field data from
LSE-04 do not closely coincide with model predictions. In
particular, the most recent total VOC concentrations measured at
LSE-04 are well in excess of 100 ug/l as compared to a model
prediction of approximately 30 ug/l. Also important is the
observation that the rate of yearly reduction of VOC
concentrations at LSE-04 shows distinct evidence of slowing down.
This "tailing effect" has been observed in VOC groundwater
monitoring programs at other hazardous waste sites. It generally
indicates a slowdown in the rate that groundwater contaminants
are being flushed or removed from the wastewater system. At the
Springfield site, this type of tailing effect will potentially
have the effect of significantly prolonging (by years) the time
required for total VOC concentrations at LSE-04 to decrease
permanently to less than 5 ug/l.
EPA also wishes to point certain additional weaknesses in the
PRPs' application of the desorption model to Waste Area 2 at the
Springfield site.
First, the PRPs' model relies heavily on the results of one
January 1985 sampling event at LSE-04 to calculate initial waste
area solid phase VOC concentrations and subsequent model-
predicted changes in groundwater VOC concentrations. A review
of available data indicates total VOC concentrations measured at
LSE-04 in December 1985 were almost an order of magnitude lower
than the values measured in the January 1985 event. These
results and the subsequent 1986-1990 leachate data strongly
suggest that the January 1985 total VOC concentration value may
have been anomalously high. As indicated in the Supplemental RI
(Ebasco, 1988), this value might have resulted from a singular
(one time) event, such as the rupture ,of a drum within the waste
area and"'the release of a pulse of contamil18ted groundwater or

-------
The inclusion of this potentially anomalous ~ampling.po~nt in the
PRPs' desorption model has the effect of mak~ng p:ed~ct~ons of
the times required to reduce total VOC concentrat~ons at LSE-04
to less than 5 ug/l appear to be considerably more rapid than
would otherwise be projected.

An examination of the accompanying Table A demonstrates recent
trends in the measured concentrations of some of the contaminants
which have been detected at LSE-04. This table includes results
from the sampling rounds conducted since January 1985. The data
presented in Table A demonstrate both the yearly variability in
measured concentrations of many of the contaminants detected at
LSE-04 and the slow rate at which contaminant reductions may be
occurring. For both trichloroethene and tetrachloroethene values
measured in 1990 are similar to values measured in 1985 with
concentrations measured during intervening years being generally
higher. Concentrations of xylene (a monocyclic aromatic
compound) demonstrate the extent of variability that may be
encountered in contaminant concentrations at landfill leachate
seeps. A concentration of 400 ug/l was detected in 1985. Xylene
was not detected in 1987 or 1989, but was again detected at 89
ug/l in 1990. It should be noted that these variations in
measured xylene concentrations are a significant contributing
factor to the decrease in total measured VOC concentrations
presented in the PRPs' data.
Finally, with respect to LSE-04, EPA does believe that the high
total VOC concentrations observed in January 1985 demonstrate the
potential variability in groundwater contaminant concentrations
which may be measured in landfill leachate seeps. The Agency.
also believes that similar, although perhaps not as dramatic,
abrupt fluctuations in groundwater contaminant concentrations may
occur in the future at LSE-04. Also, with respect to the PRPs'
desorption model, EPA wishes to point out that the use of
trichloroethene (TCE) as a representative "chlorinated ethene"
contaminant is not necessarily conservative with respect to
desorption model time predictions for LSE-04. Tetrachloroethene
(PCE) also present in groundwater at LSE-04 (in consistently
higher concentrations than TCE) is much less water soluble
(solubility -200 mg/l) and has a significantly higher K value
(364 ml/g) than does trichloroethene (water solubility ~ 1100
mg/l and K~ - 126 ml/g (EPA, 1986». This decreased water
solubility and increased Koc value indicates that PCE will be
more strongly adsorbed (retarded) by soils and more slowly
flushed out of Waste Area 2 than TCE. Therefore the
incorporation of tetrachloroethene in the desorption model would
likely result in significantly increased time projections for
total VOC contaminant reductions through flushing to 5 ug/l.

EPA also wishes to acknowledge that, as assumed in the PRPs'
model, biodegradation of "chlorinctt~ a.then~s" can occur,
a~though ~h7 rate~ of suc~ degrad~t7on.are highly uncertain on a

-------
is lackin9. However, it should be emphasized that one of the
potential degradation products of the more chlorinated ethenes is
vinyl chloride which is considered one of the more toxic of the
chlorinated ethenes and which possesses a relatively low MCL (2
ug/l). Therefore, even desorption model predictions of
reductions in total VOC concentrations to 5 ug/l do not insure

-------
   TABLE A  
  VOC CONCENTRATIONS AT LSE-04 (ug/l)
PARAMETERS  12/85 10/86 9/87 9/87
VINYL,CHLORIDE 2 8 10 
DICHLOROETHENE 4 5 5 2
TRICHLOROETHENE 4 7 8 7
TETRACHLOROETHENE   * 
6 17  27
1,1,1-TRICHLOROETHANE 78 64 16 15
TOTAL XYLENES 400 24  
TOTAL VOCs (APPROXIMATE) 617 179  54
8/89
4/90
19
3
6
22
89
140
12
7
*
ONLY SELECTED CONTAMINANTS ARE LISTED, THEREFORE TOTAL VOC CONCENTRATIONS MAY
EXCEED THE SUM OF THE LISTED PARAMETERS.
NOT DETECTED.
HIGH LABORATORY DETECTION LIMIT -- COMPOUND PROBABLY PRESENT.

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APPENDIX F
ADMINISTRATIVE RECORD INDEX
FOR

-------
Old Springfield Landfill
NPL Site Administrative Record
(Operable Unit II - Source Control)
Index
Compiled: July 12, 1990
ROD Signed: September 28,1990
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
,. ,One Kendall Square, Suite 2200. Cambrid~e, Mas~chusetts 02139. (617) 577-9915

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This document was prepared under EPA's TES 6 prime contract (#68-W9-0003)for EPA
Region I. American Management Systems, Inc. prepared the document under a subcontract

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Introduction
This document is the Index to the Administrative Record for the Old Springfield Landfill
National Priorities List (NPL) site (Operable Unit II - Source Control). Section I of the Index cites
site-specific documents, and Section II cites guidance documents used by EP A staff in selecting a
response action at the site.
The Administrative Record is available for public review at EP A Region I's Office in Boston,
Massachusetts, and at Springfield Town Library, 43 Main Street, Springfield, Vermont 05156.
This Administrative Record includes, by reference only, all documents included in tlu!
September 22,1988 Administrative Record/or this NPL site. Questions concerning the
Administrative Record should be addressed to the EP A Region I site manager.

The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and

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Section I

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4.0
ADMINISTRATIVE RECORD INDEX
for the
Old Springfield Landfill NPL Site
(Operable Unit II - Source Control)
Feasibility Study (FS)
4.1
Correspondence

1. Letter from Frank J. Ciavattieri, EPA Region I to John A. George, REMCOR,
Inc. for Emhart Industries, Inc. and Textron Inc. (March 16, 1989).
Concerning designation of Project Coordinators.
2. Letter from Scott J. McDougall, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. to Paula Lia Fitzsimmons, EPA Region I (April 7, 1989).
Concerning transmittal of Draft Focused Feasibility Study Work Plan.
3. Memorandum from Peter R. Kahn, EPA Region I to Paula Lia Fitzsimmons,
EP A Region I (August 17, 1989). Concerning review of attached "Revised Air
Monitoring and Sampling Plan," REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. (August 14, 1989).
4. Letter from Robert S. Markwell for John A. George, REMCOR, Inc. for Emhart
Industries, Inc. and Textron Inc. to Edward M. Hathaway, EPA Region I
(October 19, 1989). Concerning transmittal of validated organic analytical
results for residential wells/surface sediment.
5. Letter from Scott J. McDougall and John A. George, REMCOR, Inc. for Emhart
Industries, Inc. and Textron Inc. to Barry L. Malter, Swidler & Berlin (Attorney
for Emhart Industries, Inc.) and Daniel H. Squire, Skadden, Arps, Slate,
Meagher & Flom (Attorney for Textron Inc.) (October 27, 1989). Concerning
summary of schedule delays relating to Focused Feasibility Study.
6. Letter from Robert S. Markwell, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. to Edward M. Hathaway, EP A Region I (November 7, 1989).
Concerning transmittal of validated metals results for surface water
sediments/residential wells.
7. Letter from John A. George, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. to Edward M. Hathaway, EPA Region I (April 13, 1990).
Concerning transmittal of analytical data reports of residential wells and
streambed sediment analyses.
8. Letter from John A. George, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. to Edward M. Hathaway, EPA Region I (May 25, 1990).
Concerning notification that roll-off boxes are pending waste acceptance.
9. Letter from John A. George, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. to Edward M. Hathaway, EPA Region I (June 7,1990).
Concerning transmittal of the June 7, 1990 "Draft Final Focused Feasibility
Study Report," REMCOR, Inc. for Emhart Industries, Inc. and Textron Inc.
10. Letter from Daniel H. Squire, Skadden, Arps, Slate, Meagher & Flom (Attorney
for Textron Inc.) to Timothy M. Conway, EPA Region I (June 8, 1990).
Concerning transmittal of the June 7, 1990 "Draft Final Focused Feasibility
Study Report," REMCOR, Inc. for Emhart Industries, Inc. and Textron Inc.
11. Letter from Edward M. Hathaway, EPA Region I to John A. George,
REMCOR, Inc. for Emhart Industries, Inc. and Textron Inc. (July 19, 1990).
Concerning request by local residents to relocate command post/decontamination

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4.2
4.4
4.5
Page 2
. Sampling and Analysis Data
1.
Residential Sampling Results - Round I, REMCOR, Inc. for Emhan Industries,
Inc. and Textron Inc. (August 22, 1989 through September 1, 1989) including:
A. Case Narrative
B. Summary of Metals Analyses Results
C. Inorganics Analyses
D. MetalsAnalyses
Residential Sampling Results - Round n, REMCOR, Inc. for Emhan Industries,
Inc. and Textron Inc. (February 15, 1990 through February 22, 1990)
including:
A. Metals Analyses
B. Volatile Organics Analyses
Well Sampling Data, REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (May 1, 1990).
Letter Repon from Lewis M. Horzempa, EBASCO Services Incorporated to
Edward M. Hathaway, EPA Region I (May 2, 1990). Concerning draft split
sample data comparison.
2.
3.
4.
The remaining Sampling and Ana/ysis Data/or the Feasibility Study (FS) may be
reviewed, by appointment only, at EPA Region I, Boston, Massachusetts.

Interim Deliverables
Repons
1.
"Proposed Scope of Work for Aquifer Pumping Tests," REMCOR, Inc. for
Emhan Industries, Inc. and Textron Inc. (December 13, 1989).
Comments
2.
Comments Dated January 2,1990 from Edward M. Hathaway, EPA Region I
on the December 13, 1989 "Proposed Scope of Work for Aquifer Pumping
Tests," REM COR, Inc. for Emhan Industries, Inc. and Textron Inc.
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
Letter from John A. George, REMCOR, Inc. for Emhan Industries, Inc. and
Textron Inc. to Thomas C. Moye, State of Vennont Agency of Natural
Resources Department of Environmental Conservation (February 13, 1990).
Concerning request for definition of potential state applicable or relevant and
appropriate requirements for the Focused Feasibility Study.
Letter from Thomas C. Moye, State of Vennont Agency of Natural Resources
Department of Environmental Conservation to John A. George, REMCOR, Inc.
for Emhan Industries, Inc. and Textron Inc. (February 15, 1990). Concerning
potential state applicable or relevant and appropriate requirements for the
Focused Feasibility Study.

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4.6
4.7
Page 3
Feasibility Study (FS) Repons
.
Repons
Letter from Lewis M. Horzempa, EBASCO Services Incorporated to Edward M.
Hathaway, EPA Region I (May 23, 1990). Concerning content and transmittal
of attached "Technical Oversight Memorandum - Old Springfield Landfill Site -
Evaluation of Soil Vapor Extraction Technology," EBASCO Services
Incorporated (May 23, 1990).
'Draft Final Supplemental Feasibility Study Evaluation," EBASCO Services
Incorporated (July 1990).
Memorandum from Edward M. Hathaway, EPA Region I to File (July 1990).
Concerning detailed evaluation and comparative analysis of alternatives.

The records cited in entries number 4 through 6 are drafts which have not received
final acceptance from the U.s. Environmental Protection Agency or the State of
Vermont Agency of Natural Resources Department of Environmental Conservation.
The opinions,jindings, and conclusions expressed are those of the authors and not
those of the U.S. Environmental Protection Agency or the State of Vermont Agency of
Natural Resources Department of Environmental Conservation.
1.
2.
3.
4.
5.
"Draft Focused Feasibility Study Report - Volume I - Text," REMCOR, Inc. for
Emhan Industries, Inc. and Textron Inc. (April 1990).
"Draft Focused Feasibility Study Report - Volume II - Appendices," REMCOR,
Inc. for Emhart Industries, Inc. and Textron Inc. (April 1990).
"Draft Final Focused Feasibility Study Report - Volume I - Text," REMCOR,
Inc. for Emhart Industries, Inc. and Textron Inc. (June 7, 1990).
6.
Comments
7.
Comments Dated May 10, 1990 from Michael Jasinski for David M. Webster,
EPA Region Ion the Apri11990 "Draft Focused Feasibility Study Report,"
REMCOR, Inc. for Emhan Industries, Inc. and Textron Inc.
Responses to Comments
Response Dated May 18, 1990 from Barry L. Malter, Swidler & Berlin
(Attorney for Emhan Industries, Inc.) to the May 10, 1990 Comments from
Michael Jasinski for David M. Webster, EPA Region I.
Response Dated May 30, 1990 from Michael Jasinski for David M. Webster,
EPA Region I to the May 18, 1990 Response from Barry L. Malter, Swidler &
Berlin (Attorney for Emhan Industries, Inc.).

Work Plans and Progress Reports
8.
9.
Work Plans
1.
2.
"Draft Focused Feasibility Study Work Plan," REMCOR, Inc. for Emhart
Industries, Inc. and Textron Inc. (July 1989).
"Summary of Recent Modifications to Focused Feasibility Field Studies,"
REMCOR, Inc. for Emhan Industries, Inc. and Textron Inc.
(September 7, 1989).
"Formal Notification of Accepted Modifications in Field Activities - Focused
Feasibility Study," REMCOR, 'nc: fot Emhart Industries, Inc~ and Textron Inc.
(September 22, 1989).

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Page 4
4.7
Work Plans and Progress Repons (cont'd.)
Work Plans
4.
"Summary of Recent Modifications to Focused Feasibility Study." REMCOR,
Inc. for Emhan Industries. Inc. and Textron Inc. (October 6. 1989).

Comments
5.
Comments Dated August 3. 1989 from David M. Webster. EPA Region I on the
July 1989 "Draft Focused Feasibility Study Site Worlc Plan." REMCOR. Inc.
for Emhan Industries. Inc. and Textron Inc.
Comments Dated August 18,1989 from David M. Webster. EPA Region I on
the July 1989 "Draft Focused Feasibility Study Site Work Plan. If REMCOR,
Inc. for Emhan Industries. Inc. and Textron Inc.

Responses to Comments
6.
Response Dated August 16. 1989 from John A. George for Scott J. McDougall,
REM COR, Inc. for Emhan Industries, Inc. and Textron Inc. to the
August 3, 1989 Comments from David M. Webster, EPA Region 1.

Progress Reports
7.
8. Progress Report No.1, REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (March 30. 1989).
9. Progress Report No.2, REMCOR. Inc. for Emhan Industries, Inc. and Textron
Inc. (May 1, 1989).
10. Progress Report No.3. REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (May 30. 1989).
11. Progress Report No.4. REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (July 10, 1989).
12. Progress Report No.6, REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (September 6, 1989).
13. Progress Report No.7. REMCOR, Inc. for Emhan Industries, Inc. and Textron
Inc. (October 5. 1989).
14. Progress Report No.8, REMCOR, Inc. for Emhan Industries. Inc. and Textron
Inc. (November 2, 1989).
15. Progress Report No.9, REMCOR. Inc. for Emhart Industries. Inc. and Textron
Inc. (December 6. 1989).
16. Progress Report No. 10, REMCOR, Inc. for Emhart Industries. Inc. and
Textron Inc. (January 15, 1990).
17. Progress Report No. 11. REMCOR. Inc. for Emhart Industries, Inc. and
Textron Inc. (January 31, 1990).
18. Progress Report No. 12, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. (March 2, 1990).
19. Progress Report No. 13, REMCOR, Inc. for Emhart Industries, Inc. and
Textron Inc. (April 4, 1990).
20. Progress Report No. 14, REMCOR, Inc. for Emhart Industries. Inc. and
Textron Inc. (May 10. 1990).
21. Progress Report No. 15. REMCOR, Inc. for Emhart Industries. Inc. and
Textron Inc. (June 4. 1990).
.

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4.9
Page 5
Proposed Plans for Selected Remedial Action
Repons
1.
"EP A Proposes Source Control Cleanup Plan for the Old Springfield Landf1l1
Site," EPA Region I (July 1990).
Comments
Comments on the Proposed Plan received by EP A Region I during the formal public
comment period are filed and cited in 5.3 Responsiveness Swnmaries.

Record of Decision
5.0
5.1
5.3
5.4
Correspondence
1.
Memorandum from Don R. Clay, EPA Headquarters to Regional
Administrators, Regions I-X (January 29, 1990). Concerning the delegation of
remedy authority to Regional Administrators for Superfund Records of Decision
for the attached list of NPL sites.
Responsiveness Summaries
1.
Cross-Reference: Responsiveness Summary, EPA Region I
(September 28, 1990) [Filed and included as Appendix E in entry number 1 in
5.4 Record of Decision (ROD)].
The following citations indicate docwnents received by EP A Region I dwing the
formal public comment period.
Cross-Reference: Transcript, EPA Region I Public Hearing to Receive
Comment on Proposed Plan for Second Record of Decision for the Old
Springfield Landfill Site (August 2,1990) [Filed and included as Attachment C
to Appendix E in entry number 1 in 5.4 Record of Decision (ROD)].
Comments Dated August 25, 1990 from David J. Wills on the
July 1990 "EPA Proposes Source Control Cleanup Plan for the Old Springfield
Landf1l1 Site," EPA Region L
Comments Dated September 7, 1990 from Everett T. Hammond on the
July 1990 "EPA Proposes Source Control Cleanup Plan for the Old Springfield
Landf1l1 Site," EP A Region I.
Comments Dated September 10, 1990 from Bany L. Malter, Swidler & Berlin
(Attorney for Emhart Industries, Inc.) and Daniel H. Squire, Skadden, Arps,
Slate, Meagher & Flom (Attorney for Textron Inc.) on the July 1990 "EP A
Proposes Source Control Cleanup Plan for the Old Springfield Landf1l1 Site,"
EP A Region I.
Comments Dated September 10, 1990 from William Steele, Town of Springfield
on the July 1990 "EPA Proposes Source Control Cleanup Plan for the Old
Springfield Landfill Site," EPA Region I.

Record of Decision
2.
3.
4.
5.
6.
1.
Record of Decision, EPA Region I (September 28, 1990).
.

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9.0
Page 6
State Coordination
Letter from Gerald M. Levy, EPA Region 1 to Patrick A. Parenteau, State of
Vennont Agency of Natural Resources Department of Environmental
Conservation (June 15, 1988). Concerning response to proposed remedial plan.
Letter from Merrill S. Hohman, EPA Region 1 to Patrick A. Parenteau, State of
Vennont Agency of Natural Resources Department of Environmental
Conservation (July 19, 1988). Concerning letter of conculTence with the
proposed plan.
Letter from Sam Silvennan for Merrill S. Hohman, EPA Region 1 to Patrick A.
Parc:nteau. State of Vermont Agency of Natural Resources Department of
EnvIronmental Conservation (August 12, 1988). Concerning attached briefmg
document outlining recent events regarding the remedy selection process.
Letter from Patrick A. Parenteau, State of Vermont Agency of Natural Resources
Department of Environmental Conservation to Merrill S. Hohman, EP A
Region 1 (August 26, 1988). Concerning state concurrence with the proposed
plan.
Letter from Patrick A. Parenteau, State of Vermont Agency of Natural Resources
Department of Environmental Conservation to Merrill S. Hohman, EPA
Region 1 (September 2, 1988). Concerning response to issues relating to
proposed remedy.
Letter from Paula Lia Fitzsimmons, EPA Region 1 to Thomas C. Moye, State of
Vermont Agency of Natural Resources Department of Environmental
Conservation (September 27, 1988). Concerning transmittal of the
September 22, 1988 Record of Decision for the site.
Letter from Tunothy J. Burke, State of Vermont Agency of Natural Resources
Department of Environmental Conservation to Merrill S. Hohman, EPA
Region 1 (June 29, 1990). Concerning review of proposed remedial plan.

10.0 Enforcement
9.1
Correspondence
1.
2.
3.
4.
5.
6.
7.
10.7 EPA Administrative Orders
1.
Administrative Order by Consent, In the Matter of The Old Springfield Landfill,
Springfield, Vermont. Emhart Industries, Inc. and Textron Inc., Respondents,
Docket No. 1-89-1019 (March iO, 1989).
Letter from Jerome C. Muys Jr., Swidler & Berlin (Attorney for Emhart
Industries. Inc.) to Paula Lia Fitzsimmons, EPA Region 1 (March 21, 1989).
Concerning receipt of the March 10, 1989 Administrative Order by Consent

11.0 Potentially Responsible Party (PRP)
2.
11.9 PRP-Specific Correspondence
2.
".3.
1.
Letter from Paula Lia Fitzsimmons, EP A Region I to Daniel R Squire,
Skadden, Arps. Slate, Meagher & Flom (Attorney for Textron Inc.)
(September 23, 1988). Concerning transmittal of the September 22, 1988
Record of Decision for the site.
Letter from MeITill S. Hohman, EP A Region 1 to Mr. and Mrs. Harold Millay
(November 7, 1988). Concerning notice of potential liability .
Letter from Merrill S. Hohrruui, EPA Region.l to President or General Manager,

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Page 7
,.
11.9 PRP-Specific Correspondence (cont'd.)
. .
4. Letter from Merrill S. Hohman, EPA Region I to Robert L. Gulley,
Browning-Ferris Industries, Inc. (January 17, 1989). Concerning notice of
potential liability.
5. Letter from William Walsh-Rogalski, EPA Region I to John Parker, Parker,
Lamb & Ankuda (Attorney for Town of Springfield) (February 13, 1989).
Concerning environmental and public health threat remaining at the site after
implementation of the September 22, 1988 Record of Decision with attached:
A. Letter from John Parker, Parker, Lamb & Ankuda (Attorney for Town of
Springfield) to William Walsh-Rogalski, EPA Region I (February 6,1989).
Concerning transmittal of attached letters (B, C, and D) with the suggestion
that they be included in the Administrative Record.
B. Letter from John Parker, Parker, Lamb & Ankuda (Attorney for Town of
Springfield) to Conrad Smith, State of Vermont (January 24, 1989).
Concerning possible solutions to the public health threat from contaminated
ground water at the site.
C. Letter from Richard A. Valentinetti, State of Vermont Agency of
Environmental Conservation Department of Water Resources and
Environmental Engineering to Edgar May, Member of the State ofVe~ont
Senate (April 26, 1983). Concerning implementation of remedial action to
clean up drinking water supplies at the site.
D. Letter from Edgar May, Member of the State of Vermont Senate to Nancy
Z. Piligian, EPA Region I (August 29,1983). Concerning comments on
the July 1983 "Remedial Action Master Plan," NUS Corporation.
6. Letter from William Walsh-Rogalski, EPA Region I to Bany Malter, Swidler &
Berlin (Attorney for Emhart Industries, Inc.) (March 10, 1989). Concerning
response to arguments that EPA failed to respond adequately to PRP comments
on the September 22,1988 Record of Decision for the site.
7. Letter from Merrill S. Hohman, EP A Region I to John Adams, Vermont
Research (May 17, 1989). Concerning special notice of potential liability. for
first operable unit remedial designlremedial action.
8. Letter from Merrill S. Hohman, EPA Region I to Linda Biagioni, Emhart
Industries, Inc. (May 17, 1989). Concerning special notice of potential liability
for first operable unit remedial design/remedial action.
9. Letter from Merrill S. Hohman, EPA Region I to John Curtin (May 17, 1989).
Concerning special notice of potential liability for first operable unit remedial
designlremedial action.
10. Letter from Merrill S. Hohman, EPA Region I to Paul Duff, Textron Inc.
(May 17, 1989). Concerning special notice of potential liability for first operable
unit remedial design/remedial action.
11. Letter from Merrill S. Hohman, EPA Region I to Robert L. Gulley,
Browning-Ferris Industries, Inc. (May 17, 1989). Concerning special notice of
potential liability for first operable unit remedial design/remedial action.
12. Letter from Merrill S. Hohman, EPA Region I to Harold Millay (May 17, 1989).
Concerning special notice of potential liability for fmt operable unit remedial
design/remedial action.
13. Letter from Merrill S. Hohman, EPA Region I to President or General Manager,
Bryant Computer (May 17, 1989). Concerning special notice of potential
liability for first operable unit remedial design/remedial action.
14. Letter from Merrill S. Hohman, EPA Region I to President or General Manager,
Bryant Grinder Corporation (May 17, 1989). Concerning special notice of
potential liability for first operable.unit remedial design/remedial action.
15. Letter from Merrill S. Hohman, EPA Region 1: to President or General Manager,
Fellows Gear Shaper (May 17, 1989). Concerning special notice of potential

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Page 8
11.9 ~RP-Specific COITespondence (cont'd.)

16. Letter from Merrill S. Hohman, EP A Region I to President or General Manager,
J~nes and Lamson (May 17, 1989). Concerning special notice of potential
liability for first operable unit remedial design/remedial action.
17. Letter from Merrill S. Hohman, EP A Region I to President or General Manager,
Lovejoy Tool Company, Inc. (May 17, 1989). Concerning special notice of
18 potential liability for first operable unit remedial design/remedial action.
. Letter from Merrill S. Hohman, EP A Region I to Han-y Shephard
~ay 17, 1.989). Concerning special notice of potential liability for first operable
umt remedial design/remedial action.
19. Le~er from Merrill S. Hohman, EPA Region I to William Steele, Town of
Spnngfield (May 17, 1989). Concerning special notice of potential liability for
first operable unit remedial design/remedial action.
20. Letter from Merrill S. Hohman, EPA Region I to Emma Watkins
~ay 17, 1.989). Concerning special notice of potential liability for first operable
umt remedial design/remedial action.
21. Letter from Timothy M. Conway, EPA Region I to Harold Millay
(October 5, 1989). Concerning need to obtain further information relating to
Mr. Millay's status as a PRP.
22. Letter from David M. Webster, EPA Region I to Daniel H. Squire, Skadden,
Arps, Slate, Meagher & Flom (Attorney for Textron Inc.) (January 16, 1990).
Concerning progress of the Focused Feasibility S~dy.
23. Letter from BaITy Malter, Swidler & Berlin (Attorney for Emhart Industries,
Inc.) to Timothy M. Conway and Edward M. Hathaway, EPA Region I
(July 26, 1990). Concerning request for extension to the public comment
period.
24. Letter from John Parker, Parker, Lamb & Ankuda (Attorney for Town of
Springfield) to Timothy M. Conway and Edward M. Hathaway, EPA Region I
(July 26, 1990). Concerning request for extension to the public comment
period.

13.0 Community Relations
13.1 CoITespondence
1.
Letter from Paula Lia Fitzsimmons, EP A Region I to John Bond
(September 13, 1988). Concerning return of the remedial project manager to
Town of Springfield to hold an informal discussion session with members of the
community .
Letter from Paula Lia Fitzsimmons, EP A Region I to John Bond
(September 28, 1988). Concerning transmittal of the September 22, 1988
Record of Decision for the site.
Letter from Paula Lia Fitzsimmons, EPA Region I to William Steele, Town of
Springfield (September 28, 1988). Concerning transmittal of the
September 22, 1988 Record of Decision for the site.
Letter from Paula Lia Fitzsimmons, EP A Region I to Maury Levin, Palmer and
Dodge (December 8, 1988). Concerning transmittal of Summary Endangerment
Assessment and Proposed Plan for the site.
Letter from Paula Lia Fitzsimmons, EPA Region I to John Bond
(December 9, 1988). Concerning transmittal of "Superfund Law."
Letter from Paula Lia Fitzsimmons, EP A Region I to Mr. and Mrs. Harold
Millay (December 14, 1988). QJncerning transmittal of "Superfund Law."
Letter from Paula Lia Fitzsimmons, EP A Reg1.on I to John Bond
(December 22, 1988). Concerning impact of the site and extraction wells on
adjacent property.
2.
3.
4.
5.
6.

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Page 9
13.1 Correspondence (cont'd.)

8. Letter from Paula Lia Fitzsimmons, EPA Region I to Wayne Golec
(March 29, 1989). Concerning transmittal of the March 10, 1989 Administrative
Order for the site.
9. Letter from Paula Lia Fitzsimmons, EPA Region I to Russell Moore, Springfield
Town Library (March 29, 1989). Concerning transmittal of the March 10, 1989
Administrative Order for the site.
10. Letter from Paula Lia Fitzsimmons, EP A Region I to John Bond
(May 31, 1989). Concerning transmittal of the special notice letters and
attachments.
11. Letter from John Bond to Edward M. Hathaway, EPA Region I
(November 20, 1989). Concerning negative effects of pumping at the site on
private well and pond.
12. Letter from Edward M. Hathaway, EPA Region I to John Bond
(November 20, 1989). Concerning response to November 20, 1989 letter.
13. Letter from Edward M. Hathaway, EPA Region I to Edward Battle
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
14. Letter from Edward M. Hathaway, EPA Region I to John Bond
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
15. Letter from Edward M. Hathaway, EPA Region I to Doris M. Clark
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
16. Letter from Edward M. Hathaway, EPA Region I to Richard and Sally
Cofrancesco (January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
17. Letter from Edward M. Hathaway, EPA Region I to Flora Gallagher
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
18. Letter from Edward M. Hathaway, EPA Region I to Vincent Grochowik
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
19. Letter from Edward M. Hathaway, EPA Region I to Paul Laflamme
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
20. Letter from Edward M. Hathaway, EPA Region I to Harold Maxwell
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
21. Letter from Edward M. Hathaway, EPA Region I to Frances Mumford
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
22. Letter from Edward M. Hathaway, EPA Region I to Richard Stevens
(January 12, 1990). Concerning content and transmittal of attached
August 1989 residential well water sample results.
23. Letter from Edward M. Hathaway, EPA Region I to Mr. and Mrs. John Bond
(June 19, 1990). Concerning content and transmittal of attached
February 1990 residential well water sample results.
24. Letter from Edward M. Hathaway, EPA Region I to Flora Gallagher
(June 19, 1990). Concerning content and transmittal of attached
February 1990 residential well water sample results.
"25. Letter from Edward M. HathaJ"ay;EPA RegiQl'l I to Mr. and Mrs.Vincent
Grochowik (June 19, 1990). Concerning content and transmittal of attached

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Page 10
13.1 €orrespondence (cont'd.)

26. Letter from Edward M. Hathaway, EP A Region I to Harold Maxwell
(June 19, 1990). Concerning content and transmittal of attached
February 1990 residential well water sample results.
27. Letter from Edward M. Hathaway, EPA Region I to Frances Mumford
(June 19, 1990). Concerning content and transmittal of attached
2 February 1990 residential well water sample results.
8. Letter from Edward M. Hathaway, EPA Region I to Richard Stevens
(June 19, 1990). Concerning content and transmittal of attached
2 February 1990 residential well water sample results.
9. Letter from Edward M. Hathaway, EPA Region I to Richard and Sally
~o~cesco (June 25, 1990). Concerning content and transmittal of attached
e ruary 1990 residential well water sample results.
30. Letter from Edward M. Hathaway, EP A Region I to Paul Laflamme
(June 25, 1990). Concerning content and transmittal of attached
February 1990 residential well water sample results.
31. Letter from Edward M. Hathaway, EPA Region I to Wayne Golec
(July 20, 199O~. Concerning request by local residents to relocate command
post/decontamInation facility.
32. Lener fr?m D.avid~. Webster, EPA Region I to Bill Newman (July 24, 1990).
Concernmg discussIons on bioremediation technologies at the July 12, 1990
Public Meeting.
13.2 Community Relations Plans
"Final Revised Community Relations Plan for the Old Springfield Landfill Site,"
EBASCO Services Incorporated (May 4, 1990).

13.3 News Clippings/Press Releases
1.
1. "Environmental News - EPA to Hold Press Conference Regarding Possible
Relocation of Residents at Old Springfield Superfund Site," EP A Region I
(June 1988).
2. "Environmental News - EP A to Propose Permanent Relocation of Residents
from Old Springfield Superfund Site," EPA Region I (June 23, 1988).
3. "Environmental News - EPA to Hold Public Infonnation Meeting on Old
Springfield Superfund Site," EPA Region I (June 30, 1988).
4. "Environmental News - EP A Announces Extended Comment Period for Old
Springfield Superfund Site," EPA Region I (August 2, 1988).
5. "Environmental News - EP A Announces Cleanup Plan for Old Springfield
Superfund Site," EPA Region I (September 23, 1988).
6. "Environmental News - Public Meeting to Describe Selected Remedy at the Old
Springfield LandfIll Superfund Site Announced," EPA Region I
(October 20, 1988).
7. "Environmental News - Potentially Responsible Parties to Conduct Study at Old
Springfield Landfill Site," EPA Region I (March to, 1989).
8. "Environmental News - EPA to Hold Public Meeting to Discuss Work Plan at
Old Springfield Superfund Site," EPA Region I (August 4, 1989).
9. ''Environmental News - EPA to Install Temporary Fence Around Portion of the
Old Springfield Landfill Superfund Site," EPA Region I (August 25, 1989).
..10. "Environmental News - EPA toRoId Meeting on Springfield Cleanup Plan,"
EPA Region I (June 28, 1990). . ..
11. "Environmental News - EP A Extends Comment Period on Springfield Cleanup

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Page II
13.3 ~ews Clippings/Press Releases (cont'd.)

12. "Environmental News - EPA Selects Cleanup Plan for Old Springfield Landfill
Superfund Site," EPA Region I (September 28, 1990).
13.4 Public Meetings
EPA Region I Meeting Summary, Focused Feasibility Study Work Plan Public
Meeting for the Old Springfield Site, EPA Region I (August 15, 1989) with
attached:
A. EPA Region I Meeting Agenda, Public Meeting for the Old Springfield Site
(August 15, 1989). Concerning the Focused Feasibility- Study Work Plan.
B. "Environmental News - EPA to Hold Public Meeting to Discuss Work
Plan at Old Springfield Superfund Site," EPA Region I (August 4, 1989).
C. EPA Region I Attendance List, Focused Feasibility Study Work Plan
Public Meeting for the Old Springfield Site (August 15, 1989).
D. "EPA Commitments/Promises," EPA Region I (August 15, 1989).
EPA Region I Final Public Meeting Summary, Public Meeting for the Old
Springfield Landfill Site (July 12, 1990). Concerning findings of the Focused
Feasibility Study and release of the proposed source control cleanup plan.
Cross-Reference: Transcript, EPA Region I Public Hearing to Receive
Comment on Proposed Plan for Second Record of Decision for the Old
Springfield Landf1l1 Site (August 2, 1990) [Filed and included as Attachment C
to Appendix E in entry number 1 in 5.4 Record of Decision (ROD)].

13.5 Fact Sheets
1.
2.
3.
1.
"Superfund Program Cleanup Plan," EPA Region I (October 1988).
Concerning selection of cleanup plan for Old Springfield Landfill NPL Site.
"Superfund Program Fact Sheet," EPA Region I (May 1990). Concerning
CUITent status of the cleanup at the site.
2.
14.0 Congressional Relations
14.1 COITespondence
1.
Letter from Paula Lia Fitzsimmons, EPA Region I to Edgar May, Member of the
State of Vermont Senate (September 28, 1988). Concerning ttansmittal of the
September 22, 1988 Record of Decision for the site.
Letter from Paul G. Keough, EPA Region I to Peter Smith, Member of the State
of Vermont House of Representatives (December 22, 1989). Concerning
response to citizen's inquiry relating to EPA's activities at the site.
2.
17.0 Site Management Records
17.2 Access Records
1.
Letter from MeITill S. Hohman, EP A Region I to Anhur Becker and Edward
Emerson, Tamarac Hill Farm (March 21, 1989). Concerning request for
government access to Lot 58 on Map 10.
Letter from Paula Lia Fitzsimmons, EPA Region I to Wayne Golec
(April 6, 1989). Concerning government access to property for additional
testing. .

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Section II

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Page 12
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EPA Guidance Documents
1.
U.S. Environmental Protection Agency. Draft RCRA (Resource Conservation and Recovery
Act) Guidance Document - Surface Impoundments. Linear Systems. Final Cover and
Freeboard Control, July 1982.

U.S. Environmental Protection Agency. Office of Research and Development and Office of
Emergency and Remedial Response. Case Studies 1-23: Remedial Response at Hazardous
Waste Sites (EPA 540/2-84/002b), March 1984.
2.
3.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
Endangerment Assessment Handbook. August 1985.

U.S. Environmental Protection Agency. Chemical. Physical. and Biological Properties of
Compounds Present at Hazardous Waste Sites (OSWER Directive 9850.3),
September 27, 1985.
4.
5.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory
and Office of Emergency and Remedial Response. Handbook: Remedial Action at Waste
Disposal Sites (EPA 625/6-85/(06), October 1985.
6.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Remedial Design and Remedial Action Guidance (OSWER Directive 9355.0-4A),
June 1986.
7.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), October 1986.
8.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Test Methods for Evaluating Solid Waste: Laboratory Manual PhysicaVChemical Methods.
Third Edition (Volumes IA. lB. IC. and IT) (SW-846), November 1986.
9.
"Hazardous Waste Management Systems; Land Disposal Restrictions; Final Rule,"
Federal Register (Vol. 51, No. 216), November 7, 1986.
10. Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators, Regions I-X; Regional
Counsels, Regions I-X, Director, Waste Management Division, Regions I, IV, V, VII, and
Vill; Director, Emergency and Remedial Response Division, Region IT; Director, Hazardous
Waste Management Division, Regions ill and VI; Director, Toxics and Waste Management
Division, Region IX; Director, Hazardous and Waste Division, Region X; Environmental
Services Division Directors, Regions I, VI, and VII (OSWER Directive 9355.0-19),
December 24, 1986 (discussing interim guidance on Superfund selection of remedy).

11. "Estimated Soil Ingestion Rates for Use in Risk Assessment," Risk Analysis (Vol. 7, No.3),
1987.
12. U.S. E~:vi~onme~tal. Protection Ag~ncy. Off~e of ~.o.l~d Waste and Emergency Response.
Data QUalIty Oblecnves for RemedIal Response AcnV1tles: I«velopment Process

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Page 13
13. g~~fnyirC?n~ental Protecti0!1 Agency. Offic~ ?~Waste Programs E~f~rcement. ~.
S;. tr O~~tIves ~~r R~m~al Rg~n~ ActIV1t1es - Example Scenano. RIJFS AcuV1tIes at a
91te WIth ntamin ted oil and r n water (EPN540/G-87/004, OSWER Directive
55.0-7B), March 1987.

14. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
A.Col1}pendium of Superfund Field Operations Methods (EPN5401P-87/001, OSWER
DIreCtIve 9355.0-14), December 1987.

15. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
S~Ifund Exposure Assessment Manual (EPN540/1-88/001, OSWER Directive 9285.5-1),
Apnl 1988.
16. U.S. Env~nmental Protection Agency. Office of Emergency and Remedial Response.
Commum~ Relations in Superfund: A Handbook (Interim Version) (EPN540/G-88/002,
OSWER Duective 9230.0-3A), June 1988.

17. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Catalog of SupeIfund Program Directives (Interim Version) (OSWER Directive 9200.7-01),
July 1988.
18. U.S. Environmental Protection Agency. Hazardous Site Evaluation Division. Laboratory
Data Validation Functional Guidelines for Evaluating Inorganics, July 1, 1988.

19. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (Comprehensive Environmental Response. Compensation. and Liability Act)
Compliance with Other Laws Manual (EPN540/G-891OO6, OSWER Directive 9234.1-01),
August 1988.
20. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Technology Screening Guide for Treatment of CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) Soils and Sludges (EPA 540/2-88/(04),
September 1988.

21. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance for Conducting Remedial Investigations and !easibili~ Sr:u~ies Under CI?Rq.A
(Comprehensive Environmental Response. CompensatIon. and LIabIlIty Act) (lntenm Fman
(EPN540/G-891004, OSWER Directive 9355.3-01), October 1988.
22. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version), Chapter 6 (OSWER
Directive 9230.0-3B), November 3, 1988.

23. U.~. Environmental Protection Agency. Office of Emergency and Remedial R~sponse.
GUIdance on Remedial Actions for Contaminated Ground Water at Superfund SItes
(EPN540/G-881OO3, OSWER Directive 9283.1-2), December 1988.
24. U.S. ,Environmental Protection Agency. Office of Emergency .and ~emedial Response.
Users Guide to the Contract Laboratory Prowam (OSWER DIrectIve 9240.0-1),
December 1988.

25. U.S. Environmental Protection Agency. Office of Research and Development. Requirements
for Ha'zardous Waste Landfill Design. ConsQ-uctiori..and C~ (EPN625/4-891022),

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Page 14
26. "NationaJ Primary and"Secondary Drinking Water Regulations; Proposed Rule," Federal
Register (Vol. 54, No. 97), May 22, 1989.

27. U.S. Environmental Protection Agency. Risk Assessment Work Group, Reg~on I.
Supplemental Risk Assessment Guidance for the Superfund Program (Draft Fman
(EPN901/5-89/001), June 1989.
28. "RCRA Regulations," Code of Federal Re&ulations (Title 40, Part 264), July 1989.

29. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Preparin& Superfund Decision Documents (OSWER Directive
9355.3-02), July 1989.
30. U.S. Environmental Protection Agency. Office of Research and Development Technical
Guidance Document: Final Covers on Hazardous Waste Landfills and Surface Impoundments
(EPN530-SW-89-047), July 1989.
31. Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division, Region I to Merrill S. Hohman, Waste Management
Division, Region I (OSWER Directive 9355.0-28), July 12, 1989 (discussing air snipper
control guidance).

CERCLA (Comprehensive Environmental Res.ponse. Compensation. and Liability Act)
Compliance with Other Laws Manual - Part ll: Oean Air Act and Other Environmental
Statutes and State Requirements (EPN540/G-89/009, OSWER Directive 9234.1-02),
August 1989.
32.
33. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Development and Screening of Remedial Action Alternatives
(OSWER Directive 9355.3-OlFS3), November 1989.
34. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Getting Ready Scoping the RIIFS (OSWER Directive 9355.3-01FS 1), November 1989.
35. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Remedial Investigation: Site Characterization and Treatability Studies
(OSWER Directive 9355.3-01FS2), November 1989.
36. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. !ilik
Assessment Guidance for Superfund - Volume I: Human Health Evaluation Manual (Part A-
Interim Finan (EPN540/1-89/002), December 1989.
37. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Detailed Analysis of Remedial Action Alternatives (OSWER Directive
9355.3-01FS4), March 1990.
38. "National Oil and Hazardous Substances Pollution Contingency Plan," Federal Re~ster
(Vol. 55, No. 46), March 8, 1990, p. 8666.
39. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.

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Page 15
41. EPA Guide for Identifying- Cleanup Alternatives at Hazardous Waste Sites and Spills:
Biolog-ieal Treannent (EPN600I3-831063).

42. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Personnel Protection and Safety.
43. U.S. Environmental Protection Agency. Impact of the RCRA Land Disposal Restrictions of

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