United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-90/033
September 1990
&EPA
Superfund
Record of Decision
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50272-101
I REPORT DOCUMENTATION 11 REPORTNO. 12
PAGE EPA/ROD/R01-90/033
3. RecIpient's ACC88810n No
4. TItle ellll SubtIle
SUPERFUND RECORD OF DECISION
Old Springfield Landfill, VT
Second Remedial Action - Final
7 Aulhor(e)
5. Report Ollie
.
.
09/29/90
6.
8 Performing OrllenlZAllon RepL No
1 P8rf0rmlng Orge.nlZllllon "'1118 ellll AcId....
10 ProjectlTe8klWork Unit No
11 Contrect(C) or Grent(G) No
(C)
(G)
12. Sponsoring Orllenlz8tlon NllIII8 end Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 0' Report & Period Covered
Agency
800/000
14
15. Suppiemenlery Nole8
16. Abstrect (Unlit. 200 words)
The Old Springfield Landfill site is a 27-acre inactive municipal lind us trial landfill
approximately one mile from the Springfield city center in Windsor County, Vermont.
Land use within a one-mile radius of the site includes commercial activities, low
density housing, light agriculture, and undeveloped forest land. The landfill was
operated by the town of Springfield between 1947 and 1968, accepting industrial waste
and municipal trash. The site was closed in 1968, and subsequently sold and developed
for use as a mobile home park. Municipal water lines were extended to serve the mobile
homes. A nearby resident's complaint about foul-smelling water prompted an investigation
of the site by the State, which revealed VOC contamination in a nearby spring and the
residential well. Because of the VOC-contaminated water, the affected home near the
mobile home park was connected to the public water supply. Currently the mobile home
park is unoccupied except for the property owner who still resides on site. The site has
been divided into two operable units. Operable unit one is documented in a 1988 Record
of Decision (ROD) which addressed management of migration of the contaminated seeps and
ground water from the site and required that additional studies would be conducted to
determine the source control remedy for the site. This second operable unit ROD
(See Attached Page)
17 Document Analysle L Descrlptore
Record of Decision - Old Springfield Landfill, VT
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics (PAHs,
PCBs)
b. IcfenlilieralOpen.Encfecf Terms
... COSA 11 ReIcflGroup
18 Av8l'ebillty Stelement
11 Security Cleee (Th18 Report)
None
21 No 0' Pellee
371
..,
20 Security Clese (thiS Psge)
Nnn~
22 Price
(See ANSI-Z31 18)
See'MtrucIJone on Rewree
2fZ (4-77)
(Formerly NTIS-35)
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EPA/ROD/R01-90/033
Old Springfield Landfill, VT
Second Remedial Action - Final
I
Abstract (Continued)
documents the source control remedy, which addresses the risks associated with the
inhalation of landfill gases and dermal contact with and ingestion of contaminated soil.
In addition, this ROD also addresses risks associated with the ingestion of contaminated
ground water. The primary contaminants of concern affecting the soil and ground water
are VOCs including benzene, PCE, TCE, toluene, and xylenes; and other organics including
PAHs and PCBs.
The selected remedial action for this site includes placing a multi-layer cap over
approximately eight acres (120,000 cubic yards of contaminated soil) where waste has been
disposed of or has come to be located or where the soil cleanup levels are exceeded;
collecting ground and surface water in french drains and extracting ground water with
source control wells with treatment, as necessary, in the treatment system developed in
operable unit one or other equivalent treatment system (not specified); stabilizing the
side slopes of the waste mounds; active gas collecting and passive gas venting of
landfill gases, followed by treatment using vapor phase carbon adsorption; operating and
maintaining these components; ground water and air monitoring; and implementing
institutional controls, including deed restrictions. The estimated present worth cost of
this remedial action is $8,692,800, which includes an annual O&M cost of $123,000.
PERFORMANCE STANDARDS OR GOALS: Goals for soil cleanup (i.e., areas of contamination to
be capped) are based on total carcinogenic risk levels of 10-5 and include PCBs 6,000
ug/kg (5 x 10-6 level of risk) and PAHs 3,000 ug/kg (5 x 10-6 level of risk).
Chemical-specific ground water treatment goals are based on SDWA MCLs and State standards
and include benzene 5 ug/l (MCL), TCE 5 ug/l (MCL), xylenes 400 ug/l (State standard),
and PCE 5 ug/l (proposed MCLs/quantitative limit). Because EPA has determined that in
this circumstance it is technically impracticable, from an engineering perspective, to
establish a standard below a practical quantitative level, EPA is ~nvoking a waiver from
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nECLARATION POR ~
RECORD OP DECISION
8ITE BANE AND LOCATION
Old Springfield Landfill
Springfield, Vermont
8TATEMENT OP PURPOSE
This decisjon document presents the second selected" remedial
action for the Old Springfield Landfill site (the .site"),
located in Springfield, Vermont. This document was developed in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Aaendments and Reauthorization Act of 1986 (SARA),
and to the extent practicable, the National Contingency Plan
(NCP); 40 CFR Part 300 et sea. (1990). The Regional
Administrator for Region I of the United States Environmental
Protection Agency (EPA) has been delegated the authority to
approve this Record of Decision.
The State of Vermont has concurred on the selected remedy and
determined, through a detailed evaluation, that the selected
remedy is consistent with Vermont laws and regulations.
STATEMENT OP BASIS
This decision is based on the administrative record compiled for
the site which was developed in accordance with Section 113(k) of
CERCLA. The administrative record is available for public review
at the Springfield Public Library in Springfield, Vermont, and at
the EPA Region I Waste Management Division Record Center in
Boston, Massachusetts. The administrative record index (attached
as Appendix F to the ROD) identifies each of the items which
comprise the administrative record upon which the selection of
the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, Dr the environment.
DESCRIPTION OP THE SELECTED REMEDY
This operable unit is the second remedial action selected for the
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management of migration portion of the remedy, and included the
construction. of leachate collection and groundwater extraction
syste~s. Th~s second operable unit addresses the risks
assoc1at~d w1th ingestion of contaminated groundwater, inhalation
of landf111 gases, and dermal contact with and ingestion of
contaminated soils through source control remedial actions.
The remedy selected in the ROD incorporates the following
components:
*
capping of Waste Areas 2, 3 and 4:
collection of ground and~surface water in french
drains:
*
*
extTaction of groundwater with source control wells:
stabilization of the side slopes:
*
*
collection and venting of landfill gases:
operation and maintenance of these components:
*
*
institutional controls: and
*
five-year reviews.
CaDDina of Waste Areas 2. 3 and 4
The principal component of the selected remedy will be the
placement of a mUlti-layer cap over those areas in or contiguous
with Waste Areas 2, 3 and 4 where waste has been disposed or has
come to be located or where the soil cleanup levels are exceeded.
. The cap will reduce the infiltration of water into the waste
areas which would otherwise come into contact with contaminated
waste material or soil and leach contamination into the
groundwater. The cap will also allow for the collection of
landfill gases containing VOCs and prevent direct contact with
soils containing PCBs and PARs. The cap will be designed to meet
or exceed the performance requirements set forth in 40 CFR
sections 264.111, 40 CFR 264.310 and the technical guidance
document Final Covers on Hazardous Waste Landfills and Surface
ImDoundments (EPA/S30-SW-SS-047, July 1989) or in a manner which
achieves performance equivalent to that required by 40 CFR
sections 264.111, 264.310 and the technical guidance.
Collection of Ground and Surface Water in French Drains
~wo french drains will be constructed at specified locations
around the perimeter of the above-noted waste areas. A french
drain involves the placement of perforated pipe along the bottom
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of a ~rench so ~at water flowing ~rough or over ~e soil will
drain into ~e trench and be collected in ~e pipe. ~he first
french drain will be constructed along ~e upgradient western and
southern perimeters of Waste Area 4 to intercept both overland
and shallow subsurface groundwater flows from the surrounding
uplands and ~o prevent ~his water from entering Waste Area 4.
The second french drain will be constructed in ~he uncapped area
along the no~ern edge of Waste Area 4 and ~e western edge of
Waste Area 3. The purpose of ~e second drain is to prevent
:h:ll~~ s~surface water which may flow horizontally above ~e
till from entering Waste Area 3.
.
.
Extraction of Groundwater with Source Control Wells
Source control extraction wells vill be installed in Waste Area
3. Source control extraction wells will be placed in locations
~at allow for the capture of groundwater which would otherwise
move east towards the Black River. The number of wells will be
sufficient to maintain maximum practical contaminant removal.
Collection and Ventina of Landfill Gases
Active gas collection and passive gas venting will be used to
prevent the harmful buildup or release of landfill gases from ~e
areas beneath the cap and the stabilized slopes. Waste Areas 2
and 4 will have a passive gas venting system installed as part of
~e cap. An active gas collection system will be used in Waste
Area 3. The landfill gases will be treated using vapor phase
carbon or an equivalent method of treatment.
Stabilization of the Side SlODes
The eastern slopes of Waste Areas 2 and 3 will be stabilized to
prevent any slope failure which could damage the cover system,
allowing releases of waste and leachate to surrounding soils and
groundwater. Each slope will be designed to withstand ~e
loading and hydraulic conditions to which it will be subject
during the cap's construction and post-closure periods. In .
addition, ~e slopes of Waste Areas 2 and 3 will be stabilized so
that a greater ~an 1.25 long-term factor of safety is achieved.
Each slope will be stabilized to prevent or minimize, to the
degree practicable, shifts, cracks or slumpage in ~e slope in
excess of ~ose expected by waste settlement and to prevent a
decrease in the integrity, permeability or effectiveness of the
cap.
CDeration and Maintenance
All of the components of the selected remedy described above will
be operated in order to maintain the effectiveness of the
remedial response action. The cap must be maintained for at
least thirty years and thereafter until EPA determines that
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further maintenance is'not hecessary. This maintenance may
include reconstruct~on of all or a part of the cap, active gas
collection and passlve gas venting systems, french drains, water
treatment systems, and/or stabilized slopes.
The french drain and source control extraction wells will be
operated and maintained until the cleanup levels described in
section X.A for groundwater at the boundary of the waste
management unit and in the water collected in the french drain
and source control extraction wells are achieved. Landfill gas
monitoring will be used to optimize the gas collection and
treatment processes to meet the performance standards and ensure
that the concentration of contamin!nts in air emissions and
ambient air are protective of human health and the environment.
Monitoring will &lso be required to ensure -compliance with 40 CFR
Part 264, Subparts F~ G and N.
Sampling and/or testing will be performed as soon as practicable
after the completion of the respective components and continue
through the operation and maintenance period for the following:
(1) water collected from the french drains and source control
wells; (2) landfill gas; and (3) the stability of side slopes.
Groundwater sampling and testing will begin during remedial
design activities and will continue through remedial action and
operation and maintenance.
Institutional controls
In conjunction with this remedy, a public information program
will be used to educate the public about the hazards of the site.
Deed restrictions will be imposed to restrict the use of the site
within the fenced area. This will include restricting excavation
or any activity that Diqht co~promise the integrity or
performance of the cap, french drains, wells, slopes or other
remedial features. Institutional controls restricting
groundwater use at the site and land use beyond the fenced area
are contained in the ROD for the first operable unit. This
remedy does not limit or modify the institutional controls found
in the first operable unit ROD.
Five-vear review
As required by law, EPA will review the site at least once every
five years after ~he initiation of remedial action at the site if
any hazardous substances, pollutants or contaminants remain at
the site to assure that the remedial action continues to protect
human health and the environment. EPA will also evaluate risk
posed by the site at the completion of the remedial action (i.e.,
before the site is proposed for deletion from the NPL).
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DECLARATION
This selected remedy is protective of human health and the
environment, attains 811 Federal and State requirements that are
applicable or relevant and appropriate (ARAR) to this remedial
action except one state ARAR for which EPA bas justified a
waiver, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable. ~he remedy does not meet the preference for
remedies that employ treatment as a principal element.
Additionally, because the remedy will result in hazardous
substances remaining in the soil on the site above health-based
levels, a review wi~l be conducted (at a minimum) within five
years after co~encement of the remedial action to ensure that
the remedy continues to provide adequate protection of human
health and the environment.
~v
Julie Belaga
Regional Admini
u.s. EPA, Region
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UcnOB . x
DooRD OP DBCISIOB 8tJJDmRY
SEPTEMBER 28, 1"0
OLD SPRINGFIELD LANDFILL
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contents
I.
II.
III.
IV.
v.
VI.
VII.
VIII.
IX.
X.
XI.
ZII.
XIII.
Old springfield Landfill
TABLE OF CON'1'EN'1'S
.. Paae Numher
SITB DXE, LOCATION DI> DESCRIPTION.
. . . . .
. . .
SITE HISTORY' BNFORCEMENT ACTrvITIBS .
. . . . . . .
A.
B.
Land U.e , aesponse History. . . . . . . . . . .
Bnforcement History. . . . . . . . . . . . . . .
COHKUNITY PARTICIPATION. . . . .
. . . . . . .
. . .
SCOPE' )tOLE OF OPBRABLE UNIT OR RESPONSE ACTION.. .
StTHHARY OF 8ID CJtlJtACTEUB'J'ICS .
. . . .
. . . . . .
SUMMARY OF SITE RISKS. . . . . .
. . .
. . . . . . .
DEVELOPMEN'1' AND SCREENING OF ALTERNATIVES.
. . . . .
A.
B.
statutory Requirement./Response Objectives. . .
Technology and Alternative Development
and screening. . . . . . . . . . . . . . . . . .
DESCRIPTION OF ALTERNATIVES. . . . . . . .
. . . . .
SUHKARY OF 'l'JIE COMPARATIVE ANALYSIS OF ALTBRNATIVES .
THE SELECTED REMEDY. . . . . . . . . . . . . . . . .
A. Cleanup Levels. . . . . . . . . . . .
B. Description of the aemedial component.
. . . . .
. . . . .
STATUTORY DETERMINATIONS
. . .
. . .
. . . . .
. . .
A.
The Selected Remedy is Protective of Human
Health and the Environment. . . . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . .
The Selected Remedial Action is Cost Effective.
The Selected aemedy utilizes Permanent Solutions
and Alternative Treatment or .esource Recovery
Technologie. to the Maximum Extent Practicable. .
The Selected .emedy satisfies the Preference
for Treatment as a principal Element. . . . . .
B.
c.
D.
E.
DOCUKEN'1'ATION OF SIGNIFICANT CHANGES
. . . . . . . .
STATE ROLE
. . . . . .
. . . . . .
. . . . . . .
APPENDIX A - ~iqures
APPENDIX B - contaminants of Concern
APPENDIX C - ARARs
APPENDIX D - Letter of Concurrence
APPENDIX E - aesponsivene.s Summary
APPENDIX ~ - Administrative Record Index
1
2
2
4
5
,
7
10
15
15
15
17
21
27
27
31
37
37
37
41
41
42
43
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ROD DECISION SUXMARY
September 28, 1"0
%.
.
arTE DKE, I.OCA'1'ION AND DBSCRIPTION
The 27 acre Old Springfield Landfill (the site) is located
approximately one mile southeast of the city center in the Town
of Springfield, Windsor County, Vermont (See Figure 1, Appendix
A). The site is situated on an upland plateau with slopes that
Qesc~i1~ ste~ply to the north, east and west. Seavers Brook runs
west of the site and the Black Riv.r runs east of the site.
Seavers Brook flows Dorthward until 1~ reaches the Black River,
which flows to the south and empties into the Connecticut River.
Will Dean Road is located along the western side of the site.
Will Dean Road intersects ~oute 11 just north of the site. Route
11 runs past the eastern side of the site.
The 1980 National Census lists the population of the Town of
Springfield at 10,180. The Villages of Goulds Mill and
Hardscrabble Corner are located within a one-mile radius of the
site. The land use within a one-mile radius of the site is
primarily low density residential housing, light agriculture,
undeveloped forest land and commercial. Approximately 15 homes
are located within a one-half mile radius of the site, along with
a few commercial establishments. Three homes are on the plateau
adjacent to a former mobile home park. Approximately 200 homes
and condominiums are located within a one-mile radius of the
site, housing an estimated population of between 650 and 750
. people.
Natural resources in the vicinity of the site include
qroundwater, surface water, fish and game, arable land, forest,
woodland and minerals.
A bedrock aquifer is a current source for drinking water in the
area of the site. Users of the bedrock aquifer qroundwater in
the site vicinity are located primarily upgradient of the site.
Groundwater users have also been identified downgradient of the
~ site, but presently their water supply remains unaffected by the
o site. All other residents in close proximity to the site receive
municipal water from the Town of Springfield.
A more complete description of the site can ~e found in Section
1.1 of the 1988 Feasibility Study (FS) Report.
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%1.
SITB BISTORY aND BNFORCZKBNT ACTIVITIBS
&. Land 0.. and a..pon.. Bistory
The Old Springfield Landfill, also referred to as the Will
Dean Dump, was operated by the Town of springfield between
1947 and 1968. Hazardous industrial waste from local
industries was co-disposed with municipal trash. The
industrial waste was disposed both in discrete trenches and
mixed with municipal solid waste. Most hazardous material
was disposed in bulk liquid arid semi-liquid form. Shortly
after the site was closed in ~968, it was sold and developed
£or use as a .obile home park, known as the Springfield
Mobile Home Estates. At the time of the mobile home park's
development, the Vermont Department of Health (DOH)
recommended that drilled wells not be used to supply water
to the mobile homes because the development was located over
areas that bad been used for chemical disposal. Municipal
water lines were extended to serve the mobile homes.
Springfield Mobile Home Estates is no longer occupied. Only
the owner of the property still resides on the site. A six-
building condominium complex and 13 single family residences
are located north of the site.
Shortly after the opening of Springfield Mobile Home
Estates, a nearby resident's complaint about foul-smelling
water prompted an investigation of the site by the Vermont
DOH and the Vermont Agency of Environmental Conservation
(VTAEC). In response to finding volatile organic compounds
(VOCs) contamination in a spring located near Seavers Brook
and in the residential well near the mobile home park, the
spring was abandoned and the affected home near the mobile
home park was connected to the public water supply.
In 1976, EPA reviewed the Vermont Department of
Environmental Conservation's (VTDEC) data on residential
wells near the site. In 1982, after the VTDEC requested
that the site be reviewed for inclusion in the Superfund
Program, the site was added to the National Priorities List
of hazardous waste sites eligible to receive federal funding
for study and cleanup. The results of EPA's initial
Remedial Investigation (RI), released in September 1985,
showed contamination in site soils, seeps and groundwater.
EPA determined that a supplemental RI was necessary to
delineate the former waste areas, and to better define the
nature, extent, and potential adverse human health effects
of site contamination.
Supplemental RI activities included taking samples from
soil, leachate seeps, residential wells, groundwater and
sediment at the site, as well as instituting a soii boring
program in the mobile home area. The soil boring program
took place between July 6 and July 18, 1987. Because of the
potential for mobile home park residents to be exposed to
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contamin~tion during the soil boring program, EPA
tem~orar~ly relocAted ~obile home park residents during that
per~od. EPA completed Phase I field investigations 1n
October 1987, and Phase II in May 1988, and released the
final Supplemental RI report in June 1988. EPA conducted
the Phase II investigations simultaneously with the FB,
released ~n June 1988, to identify and evaluate cleanup
alternatives for the site.
In June 1988, EPA issued a Proposed Plan for remedial
activities at the site. As a result of comments submitted
during the public comment period on the Proposed Plan, EPA
decided to separate the remedial action into two operable
units. On September 22, 1988; EPA signed a Record of
Decision (ROD) for the first operable unit, which involved
the aanagement of migration of contaminated seeps and
groundwater from the sit.e. wrhe 1988 ROD also required that
additional studies be done in order to determine the source
control remedy for the site. These studies were needed to
provide a better understanding of the relationship between
groundwater and the waste areas.
In 1989, EPA entered into an Administrative Order by Consent
(AO), with two potentially responsible parties (PRPs) at the
site. Under the AO, the PRPs agreed to perform the addi-
tional studies called for in the 1988 ROD and to prepare a
Focussed Feasibility Study (FFS) Report based upon the
results of those studies. The 1988 ROD and 1989 AO defined
the scope of the FFS. The field work for the FFS began in
August 1989. The first draft FFS Report was submitted to
EPA in April 1990 and a second draft in June 1990. In
response to deficiencies in the FFS Report, EPA prepared a
Detailed Evaluation Memorandum (Detailed Evaluation Memo) in
July 1990 evaluating the alternatives retained for final
consideration in the FFS based upon the nine criteria set
forth in the National Contingency Plan (NCP) for review of
remedial alternatives (40 CFR section 300.430(C)(9)(iii».
The Detailed Evaluation Memo also contains a comparative
analysis of all alternatives retained for final consider-
ation. EPA also prepared a Supplemental Feasibility Study
(SFS) Report which reevaluated alternative 2 from the 1988
FS based upon new site information. All of these documents
are available in the Administrative Record.
A more detailed description of the site history can be found
in the 1985 RI and 1988 Supplemental RI Reports at section
1.2, and in the 1988 FS Report at section 1.1.
B.
Enforcement History
On January 6, 1984, April 17, 1987 and May 14, 1987, EPA
notified approximately nine parties who either owned or
operated the site, generated wastes that were shipped to the
site, arranged for the disposal of wastes at the site, or
transported wastes to the site of their po.tential liability
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with respect to th~ &i~e.
In January 1984, EPA had discussions with Emhart Industries,
Inc.(Emhart), Textron Inc. (Textron), the Town of~Springfield
and other PRPs about installing a water line to two private
homes and conducting a Remedial Investigation and
Feasibility study (RI/FS) at the site. Emhart,. Textron and
the Town of Springfield reached an agreement with EPA on the
installation of the water line only. EPA then used
Superfund monies to conduct the RI/FS which formed the basis
for the first operable unit ROD.
~?A met ~ith a committee of PRPs several times between June
26, 1987 and September 19, 19~7 to keep them apprised of
findings at the site. EPA also met with a committee of PRPs
on June 29, 1988 to present the results of the FS and the
Proposed Plan for remedial action at the site. EPA con-
tinued to meet with the PRP committee in July and August of
1988. In June 1988, EPA published a Proposed Plan for
remediation of the site which included both management of
migration and source control components. As a result of
comments received from the public, the state of Vermont and
PRPs, EPA decided to delay the source control remedy until
additional studies were conducted. In the Responsiveness
Summary issued with the 1988 ROD, EPA did not respond to
comments it received relating to the source control portion
of the remedy. The Responsiveness Summary for this ROD
addresses those comments.
In March 1989, EPA and two PRPs, Emhart and Textron, entered
into an Administrative Order by Consent (AO) under which
these PRPs would implement the additional studies required
by the 1988 ROD. The results of these studies were to be
included in a FFS Report. As previously mentioned, these
PRPs submitted the first draft FFS Report to EPA in April
1990 and a second draft in June 1990.
In May 1989, EPA sent special notice letters to fourteen
PRPs announcing the beginning of the 60 day negotiation
period concerning the implementation of the first operable
unit remedy as described in the 1988 ROD. These nego-
tiations resulted in a Partial Consent Decree between the
United States, the State of Vermont, and four settling
parties. The four settling parties are Emhart, Textron,
Browning Ferris Industries of Vermont, Inc, and the Town of
Springfield. The Partial Consent Decree required these
parties to reimburse EPA for its past costs and to implement
the management of migration remedy under EPA oversight.
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. .
%%1. COMMUNITY PARTICIPATION -
Throughout the site's history, community concern and involvement
has been high. EPA has kept the community and other interested
parties apprised of site activities through informational
meetings, fact sheets, press releases and public meetings.
In A~ril 1990, EPA released a community relations plan which
o~t~1ned a program to address community concerns and keep
C1t1zens informed about and involved in remedial activities.
On July 12, 1990, EPA made the AdJlinistrative Record for the
second operable unit available for public review at EPA's offices
in Boston and at the Springfield Public Library. EPA published a
notice and brief analysis of the Proposed Plan for the second
operable unit in the Springfield Reporter on July 9, 1990 and on
July 12, 1990 made the Proposed Plan available to the public at
the Springfield Public Library.
. Also, on July 12, 1990, EPA held an informational meeting to
discuss the cleanup alternatives presented and discussed in the
1988 FS, 1990 FFS and 1990 SF5, the Detailed Evaluation Memo and
EPA's Proposed Plan. The Agency answered questions from the
public during this meeting. From July 13 to September 10, 1990,
EPA held a 60 day public comment period to accept public comment
on the alternatives presented in the three feasibility studies,
the Detailed Evaluation Memo, the Proposed Plan and any other
documents previously released to the public. On August 2, 1990,
EPA held a public hearing to discuss the Proposed Plan and to
accept any oral comments. A transcript of this hearing, copies
of the written comments and EPA's response to comments received
. during the public hearing or in writing during the public comment
period are included in the attached Responsiveness Summary.
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xv.
t '.
SCOPE aND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
In response to public and state concerns over the need for
additional studies concerning the hydrology of the site, EPA
decided in 1988 to delay a decision on the source control portion
of the remedy and to remediate the site in operable units. EPA
proceeded with the management of migration portion of the remedy
at that time. The ROD for the management of migration operable
unit was signed in September 1988. The 1988 ROD required the
construction of leachate collection and groundwater extraction
systems. The ROD also included a requirement for additional
studies relating to the source control operable unit.
..
The additional studies required by the 1988 ROD have been
completed and the selected remedy described in this" ROD addresses
the source control portion of the cleanup. The remedy provides
for the following components: capping of Waste Areas 2, 3 and 4:
collection of water in french drains: extraction of groundwater
with source control wells: stabilization of the side slopes:
collection of landfill gases: institutional controls: and
operation and maintenance of these components. The source
. control operable unit in combination with the previously decided
" management of migration operable unit will result in the
comprehensive remediation of the Old Springfield Landfill. The
first operable unit will mitigate the risks associated with the
leachate seeps, but only partially addresses the risks associated
with ingestion of groundwater, ingestion or contact with soils,
and inhalation of contaminants. This second operable unit
remedial action will address the following principal threats to
human health and the environment posed by the site:
- ingestion of contaminated groundwater:
.
- long-term exposure to PCB and PAR contamination in
the soil from handling or ingestion of the soil: and
- inhalation of contaminants in landfill gas.
Thus, the source control operable unit will complete the
mitigation of the site related risks as described in section 1.4
of the 1988 FS.
-------
v. SUKKARY OF SITE CHARACTERISTICS
. .
Chapter 1 of the 1988 FS contains an overview of the 1988
Supplemental RI. The significant findings of the inv~stigations
at the site are summarized below.
&.
80il.
Four waste areas were described in the 1988 RIfFS reports
(See Figure 2 Appendix A). These are areas where drilling
encountered evidence of buried wastes. Further investi-
gations have revealed that Waste Area 1 is not a significant
source of w~ste or contamination. Waste Area 1 was
originally identified as a result of low level contamination
in a single soil boring- Other borings in the area of Waste
Area 1 were not cont~minated. Further consideration of the
information and the absence of contamination in wells
downgradient of Waste Area 1 led to the determination that
Waste Area 1 did not represent a threat to human health or
the environment.
Waste Areas 2, 3 and 4 are clearly the major locations of
soil contamination at the site. Waste Areas 2 and 3 are
ravines filled with 6400 and 72,000 cubic yards of
contaminated waste and soil, respectively. Waste Area 4 is
not a filled ravine, but is most likely a series of trenches
dug for waste disposal. Waste Area 4 has an estimated
volume of 42,500 cubic yards. Waste Area 4 was the last
active portion of the landfill.
The waste areas contain both industrial and municipal waste.
Volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), metals, polycyclic aromatic hydrocarbons
(PAHs), and polychlorinated biphenyls (PCBs) have been
identified in the soils of the three major waste areas.
Waste Areas 2 and 3 are mostly unsaturated, which means that
the majority of the waste is above the water table. Waste
Area 4 is mostly saturated and the water table is at ground
surface for most of the year.
PCBs and PAHs are found in the surface soils and near
surface soils of all three waste areas. Waste Area 3 has
the highest levels of VOCs. Waste Areas 2 and 4 have lower
levels of these compounds. The VOCs are the most mobile of
the contaminants found at the site. The majority of the
SVOCs are found in Waste Areas 3 and 4, with smaller amounts
in Waste Area 2.
The sediments of both the eastern and western leachate seeps
contain detectable levels of site related contaminants.
The soils of the steep outslopes along Waste Areas 2 and 3
were not investigated due to the difficulty in accessing
these locations. .
-------
B.
Groun4water
One of the prime objectives of the 1990 FFS was to obtain a
better definition of groundwater flow at the site. Each of
the three major waste areas has a different flow system.
The amount of water flowing into and exiting each waste area
is important because this water can leach contaminants from
the waste areas into deeper groundwater systems. Many of
the potential cleanup alternatives focus on ways to reduce
~he flow of water into the waste areas.
The groundwater contamination:at the site is located in:
4)
5)
the waste itself:
the soil below and downgradient of the three major
waste disposa~ areas;
the sand and gravel unit which runs underground
from waste area 3 to the western seeps near
Seavers Brook Road;
the bedrock along Seavers Brook Road; and
the weathered bedrock between the site and the
Black River.
1)
2)
3)
Waste Area 3 appears to be the most serious source of
groundwater contamination, while Waste Areas 2 and 4 also
contain significant levels of contamination. The water is
contaminated primarily by VOCs.
Waste Areas 2, 3 and 4 receive about 60t of their inflow
from precipitation. This means that rainfall and snowmelt
are responsible for the majority of the water entering each
waste area. Most of the water exiting Waste Area 4 flows
down to Waste Area 3. This connection .ust be taken into
account when evaluating alternatives for Waste Areas 3 and
4. The majority of the vater leaving Waste Areas 2 and 3
flows out the leachate seeps to the east. The remaining
water (15-30t) flows into the deep groundwater. The sand
and gravel unit transmits some of this contaminated water to
the western leachate seeps along Seavers Brook Road, while
the rest flows into the weathered bedrock and migrates
toward the Black River.
Recent water level measurements indicate that there may be
significant seasonal variation with respect to water £low.
During periods of high water levels, bo~izontal flow may
exist in the sand deposit above the till.
Horizontal groundwater flow approaches the site from the
south. Once the water reaches the plateau it encounters a
groundwater divide which results in some water flowing west
towards Seavers Brook and east towards the Black River.
There is a large downward component of groundwater flow
across most of the site.
-------
The leachate seeps and springs on the outslopes of the site
are the major groGndwate~ discharge zones. ApproximatelY
80% of the groundwater"entering Waste Areas 2 and 3 'flowS
out the seeps for those waste areas. The eastern leachate
seep at Waste Area 3 is the most contaminated. ~
The 1990 'FFS Report also confirmed the presence of .
contamination along Route 11 in a sand and gravel unit wh1ch
may be connected with the Black River.
c.
Burface Water
s~~~~~= Prook and the Black River are the major surface
water bodies Which could pote~tially be affected by the
site. The Black River discharges into the Connecticut River
a short distance from the site. Ho significant impacts have.
been detected in the surface water bodies.
D.
Air
The generation of volatile organics either carried on
methane generated in the landfill or released from the
leachate seeps was evaluated in the field studies and
reports. High concentrations of methane gas were noted
during the onsite boring, well installation and test pit
programs. The release of landfill gas provides a convective
force by which contaminants can be released to the air. Air
sampling was performed during the Supplemental RI and during
the 1990 FFS. Both sets of data were rejected during
validation: therefore, no valid chemical specific air
monitoring data exists. A three stage exposure model was
then used to estimate potential concentrations in the air.
The model predicted that hazardous substances would be
emitted in the l~ndfill gas. The invalidated air monitoring
results also provided a qualitative indication that
hazardous substances are being emitted in the landfill gas.
E.
side Slopes
Waste Areas 2 and 3 each have steep outslopes. These
outslopes are not stable and could potentially fail. A
significant portion of the waste underlies these outslopes.
A complete discussion of site characteristics can be found in the
1988 Supplemental RI Report and a summary can be found in section
1.3 of the 1988 FS and sections 2.1 - 2.5 of the 1990 FFS.
-------
VI.
SUMMARY OF SITE B%81S
An Endangerment Assessment (EA) for the site vas perfQrmed in
1988 to estimate the probability and magnitude of potential
adverse human health and environmental effects from exposure to
contaminants associated with the site. ~e assessment of public
health risk followed a four step process: 1) contaminant
identification, which identified those hazardous substances
which, given the specifics of the site, were of significant
concern; 2) exposure assessment, which identified actual or
potential exposure pathways, characterized the potentially
exposed populations, and determined the extent of possible
exposure; 3) toxicity assessment, which considered the types and
magnitude of adverse health effects associated with exposure to
hazardous substances, and 4) risk characteriza~ion, which
integrated the three earlier steps to summarize the potential and
actual risks posed by hazardous substances at the site, including
carcinogenic and non-carcinogenic risks. The results of the
endangerment assessment for the site are discussed below followed
by the conclusions of the environmental risk assessment.
Twenty-four conta~inants of concern, listed in Tables 1 through
11 found in Appendix B of this ROD, were selected for evaluation
in the 1988 EA. These contaminants constitute a representative
subset of the more than 7S contaminants identified at the site
during the 1988 Supplemental RI. The 24 contaminants of concern
were selected as representative of potential site related hazards
based on toxicity, concentration, frequency of detection, and
mobility and persistence in the environment. A summary of the
health effects of each of the contaminants of concern can be
found in Appendix D of the 1988 EA.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future
uses and location of the site. The following is a brief summary
of the exposure pathways evaluated. A more thorough description
can be found in Chapter 3 of the 1988 EA.
For inhalation of landfill gas emissions, a three stage exposure
80del was used. The three stages were: (1) estimate equilibrium
vapor density in the soil pore spaces; (2) estiaate the flux rate
caused by diffusion and convection; and (3) estimate the ambient
air concentrations based on the flux rate, the area of the waste
disposal, and the local climatic conditions. ~is model was used
to predict ambient air concentrations for on-site and off-site
residents and was evaluated for a resident who~ay spend 24
hr/day for 70 years breathing the predicted air concentrations.
Dermal contact and incidental ingestion of soils was evaluated
for an adult who may be exposed 24 times per year under average
conditions and 48 times per year under the reasonable maximum
-------
scenario with an . .
aver' 1ngest10n rate of 50 mg/day and 100 mg/day for
th age and reasonable maximum scenarios respectively. Each of
ese exposures was avlraged. over 70 yea~s.
Dermal contact and incidental ingestion of soils was also
evaluated for children ages 6-11 assuming 48 events per year
under average conditions and 96 events per year under the
reasonable ma»imum scenario vith an ingestion rate of 50 mg/day
and 250 mg/day for the aver~ge and reasonable maximum exposures,
respectively.
CUr~ent ingestion of qroundwater vas evaluated based on
mon1toring results from existing off-site wells. Future
ingestion of qroundweter for the eastern side of the landfill was
evaluated aSBaaing steady state conditions would eventually be
reached between the bedrock and the waste. Future ingestion of
qroundwater from the western side of the site vas evaluated based
upon monitoring wells 9 and 9D. ~l groundwater exposures assume
that the person will ingest 2 liters of water per day for 70
years.
For each pathway evaluated, an average and a reasonable maximum
exposure estimate was generated corresponding to exposure to the
average and the maximum concentration detected in that particular
medium.
Excess lifetime cancer risks were determined for each exposure
pathway by mUltiplying the exposure level by the chemical
. specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to
reflect a conservative "upper bound" of the risk posed by
potentially carcinogenic compounds. That is, the true risk is
very .unlikely to be qreater than the risk predicted. The
resulting risk estimates are expressed in scientific notation as
a probability (e.g. 1 x 10.6 for 1/1,000,000) and indicate (using
this example), that an individual is not likely to have qreater
than a ona in a million chance of developing cancer over 70 years
as a result of site-related exposure as defined for the compound
at the stated concentration. CUrrent EPA practice considers
carcinogenic risks to be additive when assessing exposure to a
mixture of hazardous substances.
The hazard index was also calculated for each pathway as EPA's
measure of the potential for non-carcinogenic health effects.
The hazard index is calculated by dividing the exposure level by
the reference dose (RfD) or other suitable benchmark for non-
carcinogenic health effects. ~eference doses have been developed
by EPA to protect sensitive individuals over the course of a
lifeti.e and they reflect a daily exposure level that is likely
to be without an appreciable risk of an adverse health effect.
RfDs are derived from epidemiological or animal studies and
incorporate uncertainty factors to help ensure that adverse
health effects will not occur. The hazard index is often
expressed as a single value (e.g., 0.3) indicating the ratio of
the stated exposure as defined to the reference dose val~e (in
-------
this example, the exposure as characterized is approximately one
third of an acceptable ,xposure level for the given compound).
The hazard index is only considered additive for compounds. that
have the same or similar toxic endpoints (for example: the hazard
index for a compound known to produce liver damage shQuld not be
added to a second whose toxic endpoint is kidney damage).
Table 1 below depicts the cumulative risk summary for the
carcinogenic and non-carcinogenic contaminants of concern for
each pathway analyzed. The hazard indices for the individual
contaminants of concern and their target endpoints can be found
on pages 4-15 thru 4-39 of the 1988 EA. For a more detailed
analysis on the risk for each contaminant of concern, see Tables
4-2 though 4-22 in the 1988 EA.
.
.
The following is a summary of the major conclusions of the 1988
EA. A more detailed description can be found in Section 1.4 of
the 1988 FS.
*
Inhalation exposures to current and future site residents
due to landfill gas and exposure to nearby residents due to
release of volatiles from seeps represent current exposure
pathways with the highest risk estimate. Total excess
lifetime cancer risks range from 9X10.s to 5X10.3 for average
and reasonable maximum cases for exposure to landfill gas.
The reasonable maximum e~osure does not fall within EPA's
risk range of 10.4 to 10.6 for remedial action. The chemicals
contributing most to the carcinogenic risk are benzene,
chloroform and trichloroethene. This assessment was based
on a contaminant transport model that predicted the movement
of contaminants through the soil. Air emissions from the
landfill were assumed to remain constant over time so that
current and future risks were the same. The cumulative
hazard index estimated for inhalation exposure did not
exceed one, indicating that adverse health effects from non-
carcinogenic compounds are unlikely from this exposure
pathway.
Future consumption of ground water from the bedrock aquifer
may exceed EPA's acceptable risk range of 10.4 to 10.6. The
principal contributors to the carcinogenic risk from the
ingestion of groundwater are vinyl chloride, 1,1-
dichloroethene and polychlorinated biphenyls(PCBs). Vinyl
chloride's maximum concentration of 420 ppb (ug/l) exceeded
the Maximum contaminant Level of 2 ppb established under the
Safe Drinking Water Act. The 1,1-dichlo~oethene at 140 ppb
and the polychlorinated biphenyls at 72 ppb also exceeded
the Maximum contaminant Levels established under the Safe
Drinking Water Act of 7 ppb and .5 ppb respectively. The
hazard index exceeds one. The major contributors to the
hazard index are trans-1,2-dichloroethene, 1,1,1-
trichloroethane, 1,2-dichlorobenzene and ethylbenzene with a
hazard index of 12.
*
-------
!'able I
CUmulative carcinogenIc ai.1t Bstimate. ud CUmulative ','
Bazard Indices by Bxpoaure Pathway Bvaluated tor Old Springfield site
Expoure Pathway Cancer Riak "Bazar4 %D4ex
CUrrent-On aite Averaae Maximum Averaae Maximw
Dermal contact and ingestion lX10.7 2xlO.s 6X10.s lX10~Z
of soil by children
Dermal contact and ingestion 3X10.7 2X10.s 1X10.s lxlO.3
~f ~o11 ~y 8dults
7nhalation of chemicals 9X10.s SX10.s 2X10.' 2X10.2
from landfill gas
CUrrent-off-site 2X10.' 2xlO.z
Inhalation of chemicals 9X10.s SX10.3
from landfill gas
Inhalation of chemicals from lxlO.' lX10.3 2xlO.3 lX100
Volatilization from leachate
seeps
Future-On aite 8xlO.s 3X10.z
Dermal contact and ingestion 1X10.7 9X10.s
of soil by children
Dermal contact and ingestion 3xlO.7 lX10.' 2X10.s 2X10.3
of soil by adults
Inhalation of chemicals 9X10.s SxlO.3 2xlO.' 2xlO-z
~rom landfill gas
~ermal Contact and ingestion 2xlO.7 SX10.6 3xlO.5 7X10.'
of soil during construction
Consumption of ground- 1X10.3 7X10.z 9xlO.z 12
water from bedrock,
eastern area(based on
steady state model)
Consumption of ground- 4X10.Z 6X10.Z 11 S4
water from bedrock,
eastern area(based on
leaching model)
Puture-Off site 6xl0.' 7Xl0.' lXl0.' lxlO.'
Consumption of ground-
water, western off-site area
-------
.
. .
Future consumption of qroundwater from the bedrock aquifer
based on the leaching model may exceed EPA's risk range of
10.' to 10.6. The principal contributors to the carcinogenic
risk are benzene at 550 ppb and tetrachloroethene at 150 ppb
which exceed the Maximum contaminant Levels established
under the Safe Drinking Water Act of 5 ppb for benzene and 5
ppb for tetrachloroethene. The hazard index exceeds one.
The major contributors to the hazard index are
tetrachloroethene, 1,2-dichlorobenzene, chloroform,
chlorobenzene, trans-1,2-dichloroethene, 1,1,1 -
trichloroethane, and bis(2 ethyl bexyl) pthalate with a
hazard index of 50.
~
Future consumption of groundwater west of the site may
exceed EPA' s risk range of 10.' to 10.6. The principal
contributor to the carcinogenic risk is vinyl chloride,
whose maximum concentration of 7 ppb exceeds the Maximum
contaminant Level established under the Safe Drinking Water
Act of 2 ppb. The hazard index does not exceed one.
The excess lifetime carcinogenic risks associated with direct
contact with soil by children and by adults and direct contact
with soil during construction exceeds EPA's point of departure of
10.6. The chemicals contributiong most to this risk are the
polychlorinated biphenyls (PCBs) and the carcinogenic polycyclic
aromatic hydrocarbons (PARs). The hazard index does not exceed
one.
*
An ecological risk assessment was also performed. The main
conclusion of the ecological assessment is that adverse effects
\ on wildlife and aquatic life may be expected due to copper,
nickel, and PCBs in leachate seeps and sediments, estimated
concentrations of these and other chemicals in the Black and
Connecticut Rivers are not expected to pose a risk to wildlife.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare or the environment.
-------
. "
VII. DEVELOPMENT AND SCREENINO- OF AL'l'BRDTIVES
a. statutory Requirements/Re.pon.. O~j.CtiV.8
Under its legal authorities, EPA's primary responsibility at
superfund sites is to undertake remedial actions that are
protec-tive of human health and the environment. In
addition, Section 121 of the Comprehensive Environmental
Response, compensation, and Liability Act (CERCLA)
establishes several other statutory requirements and
preferences, including: a requirement that EPA's remedial
action, when complete. must C9mply with all federal and more
stringent state environmental" standards, requirements,
criteria or limitations, unless a waiver is invokedf a
requirement that EPA select a remedial action that is cost-
effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicablef and a
preference for remedies in which treat~ent which permanently
and significantly reduces the volume, toxicity or mobility
of the hazardous substances is a principal element over
remedies not involving such treatment. Response
alternatives were developed to be consistent with these
congressional mandates.
Based on preliminary information relating to types of
contaminants, environmental media of concern, and potential
exposure pathways, remedial action objectives were developed"
to aid in the development and screening of alternatives.
These remedial action objectives were developed to mitigate
existing and future poten-tial threats to public health and
the environment. These response objectives were:
..
Prevent the leaching of 80il contaminants to the
groundwater.
Prevent the migration of contaminated groundwater to
the rest of the aquifer.
..
..
Prevent contact with contaminated soil or leachate that
may present a risk.
Prevent further migration of contaminated groundwater
offsite.
..
..
Prevent the uncontrolled emission of landfill gases
containing hazardous substances.
B. ~ecbnoloqy and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. In accordance"with
-------
these requirement~, a ~ange of alternatives was developed
for the second operable" \lid t. '"
The 1988 RIfFS developed a range of alternatives in which
treatment that reduces the toxicity, mobility, or volume of
the hazardous 8ubstances is a principal element. This range
included an alternative that removes or destroys hazardous
substances to the maximum extent feasible, eliminating or
minimizing to the degree possible the need for long term
management. This range also included alternatives that
treat the principal threats posed by the site but vary in
the degree of treatment employed and the quantities and
=~~r~=teristics of the treatment residuals and untreated
waste that must be managed1 a~ternative(s) that involve
little or no treatment but prbvide protection through
engineering or institutional controls1 and a no action
alternative. The 1990 FFS Report also contains additional
alternatives with respect to source control.
As discussed iD Chapter 4 of tbe 1988 FS Report, the RIfFS
identified, assessed and screened technologies based on
imp1ementabi1ity, effectiveness and cost. These
technologies were combined into source control (SC) and
management of migration (MM) alternatives. Chapter 5 of the
1988 FS Report presented the remedial alternatives developed
by combining the technologies identified in the previous
screening process in the categories identified in Section
300.430(e) (3) of the NCP. The purpose of the initial
screening was to narrow the number of potential remedial
actions for further detailed analysis while preserving a
range of options. Each alternative was then evaluated and
screened in Chapter 6 of the 1988 FS Report. The 1990 FFS
Report followed the same procedures in evaluating
alternatives.
The 1988 FS evaluated and screened seven source control
alternatives. The 1990 FFS screened an additional nine
source control alternatives. The 1990 SFS updated source
control alternative 2 from the 1988 FS based upon current
site information. The presence of three reports which each
evaluate remedial alternatives resulted in a larger than
usual number of alternatives being retained for final
consideration.
In summary, of the sixteen source control remedial
alternatives screened in Chapter 6 of the 1988 FS Report and
Chapter 4 of the FFS Report, eleven were retained for
detailed analysis. In response to deficiencies in the FFS
Report, EPA prepared a Detailed Evaluation Memo evaluating
the alternatives retained for final consideration in the FFS
based upon the nine evaluation criteria set forth in the NCP
for review of remedial alternatives. The Detailed
Evaluation Memo also contains a comparative ana1ysi~ of all
eleven alternatives retained for final consideration.
-------
VIII.
.
DESCRIPTION OP ALTE~TrvES
This Section provides a narrative summary of each alternative
evaluated. Due to the existence of two separate feasibility
studies, the numerical designations of the alternatives in the
1990 FFS were changed. Alternatives 1 through 5 in this ROD are
numbered as they appear in the 1988 FS Report. Alternatives 6
through 11 in this ROD correspond to alternatives number 2, 3, 5,
6, 7 and 9 of the 1990 FFS Report, respectively. A detailed
tabular assessment of alternatives 1-5 can be found in Table 7-
28 of the 1988 FS Report and a detailed assessment of
alternatives 6 througb 11 can be found in the July 1990 Detailed
Evaluation Memo. .
Alt~rnative 1. No Action. This alternative was evaluated in
detail in the 1988 FS Report to serve as a baseline for
comparison with the other remedial alternatives under
consideration. Under this alternative, no treatment or
containment of soil or qroundwater contamination would occur and
. no effort would be made to restrict potential exposure to site
contaminants. The only cost associated with this alternative
would be the cost of the five year reviews required for an
alternative that leaves waste in place.
~~~i:~~~ ;i: ~g: ~~~~~IO~~N;~~~I~~~I:~ APPLICABLE
ESTIMATED CAPITAL COST: NOT APPLICABLE
~;fT~ONT AND MAINTENANCE COST (PRESENT WORTH): $23.000.
----~ _OS- (PRESENT WORTH. 10%. 30 YEARS) $23.000
~;;:~:t~~: ~'n~~~~i~~~t:r:nc~o~~a~nc A~t~~eEG~s C~;lec;i~~ and d
-' e '-- - m. c on ro x rac 10n e s. an
Side SIODe Stabilization.
This alternative is described in detail in section X, nThe
Selected Remedy"-
:~~i~~~~ ;i~ ~~: ~~~~~io~N:;R~~~~N~03;~AisYEARS
~STIMATED CAPITAL COST: $7.517.000
. ~~~RAT~gN. AND MAINTENANCE COST (PRESENT WORTH): $1.159.500.
--_AL __ST (PRESENT WORTH. 10%. 30 YEARS) $8.692.000
Altern~tive 3. On-site Landfill of contaminated Solids. This
alternative would involve excavating waste and placing it in a
two to four acre landfill to be constructed in the northern
portion of the former mobile home park site. The landfill would
be built to specifications outlined in the Resource Conservation
and Recovery Act (RCRA) which require a double liner beneath the
waste and other precautions to ensure that contaminants do not
leach out of the landfill. Once the contaminated waste material
has been placed in the landfill, the area would be capped as
described in the selected alternative.
-------
ESTIMATED TIME FOR DES~GN. CONSTRUCTION: 3-4 YEARS
ESTIMATED TIME FOR OPERATION.: AT LEAST 30 YEARS
ESTIMATED CAPITAL COST: $23.339.000 .
OPERATION. AND MAINTENANCE COST (PRESENT WORTH): $978.000.
TOTAL COST (PRESENT WORTH. 10%. 30 YEARS) $23.317.000
Alternative 4. On-Site Incineration. ~i& alternative would
involve excavating waste and burning it at very high temperatures
to destroy contaminants. Air pollution control devices on the
incinerator would significantly reduce the risks to public health
and the environment from contaminated emissions released during
incineration. The contaminated ash produced during the
incineration, as well as waste items such as appliances that are
too large or that are otherwise unsuitable for incineration,
would be placed in an on-site RCRA 1andfill, as described in
alternative 3. A detailed analysis of several cleanup levels is
presented in the 1988 FS Report.
ESTIMATED TIME FOR DESIGN. CONSTRUCTION: 7 YEARS
ESTIMATED TIME FOR OPERATION: AT LEAST 30 YEARS
ESTIMATED CAPITAL COST: $197.892.000
OPERATION. AND MAINTENANCE COST (PRESENT WORTH~: $945.000
TOTAL COST (PRESENT WORTH. 10%. 30 YEARS) $198.837.000
Alternative 5. In-Situ Vitrification. This alternative would
require excavating contaminated waste and 80il and placing it in
on-site trenches for vitrification treatment. Electrodes would
be placed in the waste trenches to melt, or vitrify, the waste.
The extremely high temperatures generated would destroy many of
the contaminants and solidify any remaining contamination into a
glass-like substance. The trenches would be covered with fill
and seeded to provide a vegetative covering.
ESTIMATED TIME FOR DESIGN. CONSTRUCTION: 20 YEARS
ESTIMATED TIME FOR OPERATION: AT LEAST 30 YEARS
ESTIMATED CAPITAL COST: $128.280.000
OPERATION. AND MAINTENANCE COST (PRESENT WORTH): $881.000
TOTAL COST (PRESENT WORTH. 10%. 30 YEARS) $129.161.000
Please Dote ~hat ~he cost .stimates for alterDatives , ~hrouqh 11
are taken from ~he 1"0 FFS prepare4 by REHCOR, IDC. ~he ~i.e
.stimates were a4juste4 ~o reflect ZPA'8 ju4qement cODcerDiDq
CODstruction, operation, an4 .aintenaDce 8che4ules
Alternative 6. Fencina and Coverina of Contam~nated Soils.
This alternative would involve covering 80il& that present an
unacceptable can~er risk from direct contact or incidental
ingestion of contaminated 8011. This would require placing a two
foot cover of fill over an area of approximately 1.6 acres. A
3500 ft chain link ~ence would be constructed around Waste Areas
2, 3 and 4 and the eastern seeps to prevent access to the site
areas of concern. Nothing would be done to stabilize the side
slopes. Surface drainage controls would be used upgradient of
Waste Area 4 to protect the integrity of the cover. .
-------
-
~~~i~~~g ~i~ ~g: ~;~~~iO~~~~~~~N~Oly~~~
~~~~T~i:~~~!~~~7~~~Q~~~~~!~~~~~~ooS131.000
Alternative 7. Fencina: Installation of Source control Well: and
Coverina of Contaminated Soils. This alternative would includ~
all of the elements of alternative 6, as well as the installat10n
of a source control vell. The source control well would be
desiqned to remove contaminated groundwater from the sand and
gravel unit underneath Waste Area 3. This well would pump water
into the groundwater treatment &ys~em.
~~~i:~~g ~i: ~g: ~;~~~iO~~Ni~~~~N~02 Y~~~
~STIMATED CAPITAL COST: ~9~.000
;~;~T~g~T ~~~E~~~~~R. 1~~: i~R;~i:~)W~:~~~~00$197.000
~~;~~~~;:o~ipn7f~~~n~~s~~s~~~I~}O~n~f~~~~i~ac~t~~~t::I~;ted
~ Areas outside Waste Area 3. This alternative would include all
of the elements of alternative 7, as well as the implementation
of a soil vapor extraction system to remove volatile organic
compounds from the unsaturated soil/waste in Waste Area 3.
Approximately 20-25 vapor extraction wells would be installed.
The deep wells would 8150 remove shallow groundwater. The gases
withdrawn by the soil vapor system would be treated to prevent
. the release of contaminants into the air. It is estimated that
90-95 percent of the waste in Waste Area 3 is unsaturated. Soil
vapor extraction would decrease the concentrations of those
contaminants still in the waste.
~STIMA:D ;iME ~OR DE~IGN. CONSTRUCTION: 1 YEAR
STI~ D ME OR OF RATION: AT LEAST 30 YEARS(3-3.5 YEARS FOR
YAPOR EXTRACTION SYSTEM)
~S~IMATED CAPITAL COST: $1.638.000
1PTRAT~ONT AND MAINTENANCE COST (PRESENT WORTH): $875.000
o AL OS (PRESENT WORTH. 10'. 30 YEARS) $2.513.000
~~~~~~t~~eW:~teF:~~~na~: ~~~t~~;:;~~~ ~~ ~~~~~:i~~~;~O~o~~li;eas
putside Waste Area 3. This alternative would include fencing, a
source control well, and a .5 acre cover over contaminated soil
outside Waste Area 3, as described in alternative 7. It would
also include the installation of a RCRA Cap on the 2.5 acre
plateau portion of Waste Area 3. The cap would include a passive
soil venting system and treatment of the collected gases.
~STIMATED ~IME FOR DESIGN. CONSTRUCTION: 2-2.5 YEARS
i~~i~~~g c~~Ti~Rcg~;~;i~~~6~~0~AST 30 YEAR~
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~~;~T~~~T ~~E~;~T~~~~: i~~~ ~~~~~~)W~~:~~~.0~~42.00~,
Alternative 10. Fencina: Installation of Source Control Well:
CaDDina of Waste Areas 3 and 4: and Coverina of contaminated Soil
Outside of Waste Area 3. This alternative would include all of
the elements of source control alternative 9 as well as the
placement of a RCRA Cap on Waste Area 4. An additional 2.2 acres
would be capped under this alternative. .
ESTIMATED TIME FOR DESIGN. CONSTRUCTION: 2-2.5 YEARS
F~~1M~TED TIME FOR OPERATION: AT LEAST 30 YEARS
ESTIMATED CAPITAL COST: $2.367.000.
OPERATION. AND MAINTENANCE COST (PRESENT WORTH): $446.000
TOTAL COST (PRESENT WORTH. 10%. 30 YEARS) $2.813.000
Alternative 11. Fencina: Installation of Source Control Well:
CaDDina of Waste Area 3 with Perimeter Slurrv Wall: and Coverina
Of contaminated Soils Outside of Waste Area 3. This alternative
would include all of the elements of source control alternative 9
as well as the desiqn and construction of a slurry wall around
the perimeter of Waste Area 3. The wall would be a 900 ft long,
45 ft deep solid barrier reducing qroundwater flow into the
waste.
ESTIMATED TIME FOR DESIGN. CONSTRUCTION: 3 YEARS
~MATED TIME FOR OPERATION: AT LEAST 30 YEARS
ESTIMATED CAPITAL COST: $3.198.000
OPERATION. AND MAINTENANCE COST (PRESENT WORTH): $403.000
TOTAL COST (PRESENT WORTH. 10%. 30 YEARS) $3.601.000
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xx.
I
8t1HKARY OP ~ COKPARA'i'In ANALYSIS OP ALTERNATIVES'"
.
Section 121(b) (1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory mandates,
the NCP articulates nine evaluation criteria to be used in
assessing the individual remedial alternatives.
A detailed analysis was performed on the alternatives using the
nine evaluation criteria in order to select a site remedy. The
foilowing l~ a summary of the comparison of each alternative's
strength and weakness with respectito the nine evaluation
criteria. ~hese criteria and theirdefinitions are as follows:
~hresbold Criteria
The two threshold criteria described below must be met in
order for the alternatives to be eligible for selection in
accordance with the NCP.
1.
OVerall protection of human health and ~h.
eDvironmeDt addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced or controlled through treatment,
engineering controls, or institutional controls.
Compliance with applicable or relevant and
appropriate requirements (ARABS) addresses
or not a remedy will meet all of the ARARs
other Federal and State environmental laws
provide grounds for invoking a waiver.
2.
whether
of
and/or
Primary Balancin9 criteria
The following five criteria are utilized to compare and
evaluate the elements of one alternative to another that
meet the threshold criteria.
3.
4.
Long-term effectiveness and permanence addresses
~e criteria that are utilized to assess alter-
natives for the long-term effectiveness and
permanence they afford, along with the degree of
certainty that they will prove successful.
aeduction of toxicity, .obility, or volume through
treatment addresses the degree to which
alternatives employ recycling or treatment that
reduces toxicity, mobility, or volume, including
how treatment is used to address the principal
threats posed by the site.
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5.
6.
7.
8hort-term effectiveness addresses the period of
time nee~ed to achieve protection and any ~dverse
impacts on human health and the environment that
may be posed during the construction and
implementation period, until cleanup goals are
achieved.
Xmpl..entability addresses the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to impleaent a particular option.
Cost includes estimated capital and Operation and
Maintenance (O&M) costs, as well as present-worth
costs. .
Mo~ifyinq criteria
The modifying criteria are used on the final evaluation of
remedial alternatives 9enerally after EPA has received
public comment on the RI/FS and Proposed Plan.
8.
8tate acceptance addresses the state's position
and key concerns related to the preferred
alternative and other alternatives, and the
State's comments on ARARs or the proposed use of
waivers.
community acceptance addresses the public's
general response to the alternatives described in
the Proposed Plan and RI/FS reports.
A detailed tabular assessment of alternatives 1-5 according to
the nine criteria can be found in Table 7-28 of the 1988 FS
Report. A descriptive assessment of the remaining alternatives
based on the nine criteria can be found in the July 1990 Detailed
Evaluation Memo.
9.
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of
each alternative against the nine criteria, was conducted. The
comparative analysis for the eleven alternatives retained for
detailed evaluation is in the Detailed Evaluation Memo.
The discussion below presents the nine criteria and a brief
narrative summary of the alternatives and their strengths and
weaknesses according to the detailed and comparative analyses.
1.
OVerall Protection of Human .ealth and the Environment.
Alternatives 2 through 5 would provide for overall
protection of human health and the environment by preventing
direct contact with contaminated soils, preventing the
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!
inhalation of contaminants in landfill gas, and reducing the
infiltration and andergropnd migration of water to prevent
the continued leaching 'of contaminants into the groundwater.
Only alternatives 4 and 5 would use treatment which
permanentl~ reduces the toxicity, mobility, or volume of the
contaminants. Alternatives 2 and 3 would provide for the
significant immobilization of contaminants in the
unsaturated zone. Of the alternatives which satisfy this
criterion and which leave the waste in place, alternative 2
provides for the greatest degree of containment of the
wastes. It is also the only one of these alternatives that
considers the potential £ailure of the side slopes and
includes aeasures to prevent such a failure.
Alternative 1, the no action alternative, would not satisfy
this criterion, nor would alternatives 6 through 11. The no
action alternative does not include measures which provide
for protection of human health and the environment.
Alternatives 6 and 7 do not address the potential risk
associated with the inhalation of landfill gas emissions for
the entire site. Alternatives 9 and 11 do not address the
potential risk from inhalation of landfill gas emissions
from Waste Areas 2 and 4. Alternative 10 does not address
the potential risk from inhalation of landfill gases from
Waste Area 2. Alternative 6 does not reduce or control the
risk posed by ingesting contaminated groundwater or prevent
the leaching of soil contaminants into the groundwater.
Alternatives 7 and 8 do not prevent the infiltration of
vater which could contact contaminated waste or soil and
carry the contamination into the groundwater. Alternatives
9 and 11 do not prevent the infiltration of water through
the unsaturated zone containing contaminated soil/waste.
Alternatives 6 througb 11 would reduce the direct contact
threat.. Alternatives 1 and 6 through 11 do not include
measures to prevent the failure of the side slopes.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
Alternatives 2 through 5 would meet all ARARs, with the
exception of the Vermont Groundwater Protection Act
enforcement standard for tetrachloroethene. This ARAR would
be waived. Alternative 1 and alternatives 6 through 11 do
not satisfy ARARs. The 80il cover contemplated by
alternatives 6 through 11 does not satisfy the RCRA
requirements for bazardous waste landfill closure and would
not encompass &11 three waste areas. Of all the
alternatives which would leave waste in place (alt. 1, 2, 3
and 6 through 11), only alternative 2 would include a cover
over all of the area subject to the RCRA closure
regulations. Alternative 2 also would involve construction
of a cap consistent with RCRA technical guidance for final
covers on hazardous waste landfills.
2.
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3.
Long-term Eff~cti~en~88 and Permanence.
Alternatives 4 and 5 would have the most long-term
effectiveness and permanence because the waste would be
treated. Alternative 3 would achieve long-term ~
effectiveness by removal of the waste and placement into an
on-site RCRA landfill. Alternative 2 would be effective in
reducing the long-term generation of leachate, controlling
landfill gas emissions and preventing dermal contact and
ingestion of 80il provided that the cap is maintained.
Alternatives 6 through 11 would be less long-term effective
because all of the waste would not be capped. For
alternatives 1, 2, 3 and 6 through 11, the waste would
remain in place. Alternative."S would reduce the volume of
contamination in the unsaturated zone for Waste Area 3,
which would have a significant impact on reducing the level
of VOCs in landfill g85.
c.
.eductioD of ~ozicity, Mobility, or Volume through
treatment.
Only alternatives 4 and 5 would achieve a significant
reduction in volume, mobility, or toxicity through
treatment. Alternative S would reduce the volume of
contamination in the unsaturated zone through vacuum
extraction and vapor phase carbon treatment. An active gas
collection system, included in alternative 2, would also
achieve some reduction in the volume of the VOCs in the
unsaturated zone through treatment of the collected gases.
Alternatives 7 through 11 and alternative 2 would all reduce
the mobility and volume of contaminants in the deep
groundwater through the use of source control extraction
welles) to pump contaminated groundwater to the leachate
collection and treatment system. Alternatives 1, 3 and 6
would not reduce toxicity, mobility, or volume through
treatment.
5.
Short-term Effectiveness.
With the exception of alternative 1, all of the alternatives
would be effective in the short-term. Because of the
potential for release of contaminants during any excavation
activities, special engineering precautions would have to be
taken to minimize the potential for contaminant emissions to
ensure short-term protection of workers and area residents
during construction activities. Alternative 2 would be
completed in a shorter time frame than alternatives 3
through 5. Except for alternative 1, alternatives 6 and 7
would be constructed in a shorter time trame than any of the
other alternatives. None of the:alternatives that would
leave the waste in place would result in the cleanup of the
site in a time frame significantly shorter than any other
alternative that leaves waste in place.
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I.
xmpl...ntability.
.
All of the alternatives evaluated would be implementable.
Alternative 2, and alternatives 6 through 11 would be
implementa~le because caps, french drains, and gas
collection systems are commonly used engineering practices.
Alternative 5 would ~nvolve the use of an innovative
technology (in-situ vitrification) which would require
careful design studies. Alternative 8, soil vapor
extraction, would require a pilot study prior to full scale
implementation. Alternative 2 includes side slope
stabilization which would be difficult to implement in
certain areas of the site. Tpe side slope stabilization of
Waste Area 3 would involve the use of common construction
techniques. The side slope stabilization of Waste Area 2
would require more complex engineering practices. The
construction of the french drain to 25 feet would require
the use of specialized construction practices.
7.
Cost.
Alternatives 3, . and 5 are more expensive than alternative
2. The costs for alternatives 6 through 11 ~ay be
underestimated due to the lack of a~ate controls relating
to qroundwater flow and side slope stabilization.
Alternative 2 is the least costly of the alternatives which
are adequately protective and attain ARARs. Alternative 2
is at least an order of Dagnitude less expensive than the
waste treatDent alternatives that satisfied the two
threshold criteria. Costs for alternatives 2 through 5 are
shown in Table II.
!lable II
Cost of Alt.rnati~e8 which 8atisfy
the two ~hr.8hold C%iteria
(costs in ~housands)
Alternative capital 0 , K .et pr..ent
~ Cost Value
2 5,568 1,15' 8,1'2
3 22,340 '78 23,317
.. 1'7,8'2 .45 1'8,837
5 128,280 871 12',161
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8.
. I .
State Acceptance. .
The Vermont Department of Environmental Conservation (VT
DEC) has been involved in the aite from the time~it was
operated by the Town of Springfield as summarized in Section
II of this document, .Site History and Enforcement
Activities". The VT DEC bas reviewed this document and
concurs with the selected remedy for the source control
operable unit remedy as documented in the attached
Declaration of Concurrence.
I.
Community acceptance.
.
.
The comments received in writing during the public comment
period and orally at the public hearing held on August 2,
1990 are included in the Responsiveness Summary which 1s
attached to this ROD. Comments from citizens were divided
between those who want 80re permanent remedies and others
who called for less costly remedies. ~he PRPs submitted
their own recommendations concerning remediation.
In accordance with requirement. of the .CP, ZPA aay only .elect a
remedy which aatisfies the two threshold criteria, overall
protectiveness and compliance with aRARs. Pollowing the
evaluation of the eleven alternatives retained for detailed
evaluation, EPA determined that alternative 1 and alternatives'
through 11 do Dot .atisfy the two threshold criteria.
Consequently, alternative 1 and alternative. , through 11 can Dot
, be .elected a. the source control remedy. Alternatives 2 through
- 5 do satisfy the two threshold criteria and .ere then further
compared using the five balancing criteria. (.ee July 1"0
Detailed Evaluation Hemo)
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x.
.
~BE SELECTED REKEDY
The selected remedy described herein is for the second operable
unit for the Old Springfield Landfill site. It involves the
source control portion of the cleanup and will be implemented in
addition to the first operable unit remedy to provide for the
comprehensive cleanup of the site. .
A.
Cl8&DUp Levals
Cleanup levels have been established for those contaminants
that were identified in the 19&6 EA which were found to pose
an unacceptable r~sk to either public bealth or the
environment. Cleanup levels have been set based on the
identified ARARs (e.g. Safe Drinking Water Act [SWDA]
Maximum contaminant Level Goals [MCLGs] and Maxim~m
Contaminant Levels [MCLs]), if available. The 10. risk
level was used as the point of departure for determining
remediation goals for carcinogenic effects when ARARs were
not available. A concentration corresponding to a hazard
index of one for compounds with non-carcinogenic effects was
used as the point of departure when setting cleanup levels.
In instances in which the values described above were not
feasible to quantify, the practical quantitation level (PQL)
was used as the cleanup level.
Periodic assessments of the protection afforded by remedial
actions will be made as the remedy is being implemented and.
at the completion of the remedial action. If the remedial
action is not found to be protective, further action will be
required.
1.
Grounc!water
Because the aquifer at and beyond the compliance
boundary of the site has a groundwater classification
of Class IIB, which is a potential source of drinking
water, MCLs and non-zero MCLGs established under the
Safe Drinking Water Act are ARARs. The Groundwater
Protection Act Standards of the state of Vermont are
also ARARs. The compliance boundary was established as
the perimeter of the waste management unit.
Cleanup levels for known and probable carcinogenic
compounds (Class A & B) have been set at the appro-
priate MCL. Cleanup levels for the Class C, D and E
compounds (possible carcinogens not classified and no
evidence of carcinogenicity) have been set at the MCLG,
if available. In the absence of a MCLG, a MCL, state
standard, or a proposed drinking water standard or
other suitable criteria to be considered (i.e. health
advisory), a cleanup level was derived for carcinogenic
effects using the 10.6 excess cancer risk leve~ as the
-------
point of dep&rtur~ in considering the potential
ingestion of groundwater. . .
Cleanup levels ~or compounds in qroundwater exhibiting
non-carcinogenic effects have been set at the MCLG, if
available. In the absence of a MCLG, cleanup levels
for non-carcinogenic effects have been .et at a level
thought to be without appreciable risk of an adverse
effect when exposure occurs over a lifetime (hazard
index - 1).
Table III summarizes the cleanup levels for a subset of
~e carcinogenic and non-carcinogenic contaminants of
concern identified in qrpundwater. Groundwater
standards were originally established in the 1988 ROD.
Since 1988, two standards more stringent than federal
IfCLs have been promulgated by the State of Vermont.
The standards relate to the compounds
tetrachloroethene and xylenes. The Vermont primary
groundwater enforcement standard for tetrachloroethene
is 0.7 ppb. However, in place of the 0.7 ppb standard,
the practical quantitation limit (PQL) of 5 ppb, based
on SDWA analytical methods, will be used as the
performance standard for tetrachloroethene. The
Vermont primary groundwater enforcement standard for
xylenes (400 ppb) will also be included as a
performance standard.
~ABLE III: GROUND WATER CLEANUP LEVELS
Carcinogenic
contaminant. of
Concern
Benzene
~ricbloroetbylene
1,1-dicbloroetben8
Vinyl Chloride
~etracbloroethen8
Ron-carcinogenic
Contaminants of
Concern
~etrachloro8thene
1,1 Dichloroethene
Xylene.
Cleanup
Level (pDb)
5
5
7
2
5
.a.i.
Level of
Risk
4xl 0 -~
2xlO-6
1xl0 -4
1Z10-4
7Z10-6
MCL
XCL
XCL
XCL
PQL
Cleanup
Level
(oDb)
5
7
400
'l'arget
Endpoint
of ~oxW tv
liver
liver
CNS effect.,
reduced ~dy .eight
Hazard
Index
Ba.i.
PHCL
XCL
nateS
.01
.02
.006
These cleanup le~els must be met at the compl~tion of
the remedial act10n at the points of compliance
described in the 1988 ROD and at the "boundary of the
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waste management unit as described in section X.A.3. of
this ROD. R
Also, sampling results from the 1990 Frs indicate the
presence of contamination in the groundwater along
Route 11. The first operable unit ROD requires that as
additional areas of groundwater contamination are
identified, the management of migration system will be
expanded to include these waters if such actions are
determined by EPA to be practical and consistent with
the management of migration system. Should EPA make
this determination for the area along Route 11 where
contamination is present, the management of migration
system of the first ope~le unit shall be extended to
include this area AS an action covered by the first
operable unit.
These cleanup levels are consistent with ARARs for
ground water and attain EPA's risk management goal for
remedial actions (carcinogenic risk level between 10.'
and 10.'), unless the MCL and/or MCLG is outside the
risk range due to the PQL for the particular hazardous
substance being above the 10.' excess risk level.
Vinyl chloride and 1,1 DCE are two substances whose
MCL's are set at the PQL and the PQL represents an
excess risk level greater than 10.'. The PQL for these
compounds has been used to establish. the performance
standard.
2.
soil Cleanup Levels
Cleanup levels for ~own and suspected carcinogens have
been set to total 10. excess cancer risk level
considering exposures via dermal contact and ingestion
of soil conta~inated with PCBs and PARs. Exposure
parameters for dermal contact and ingestion of soil
have been described in the 1988 rs Report in section
1.4.1. Table IV summarizes the cleanup levels for
carcinogenic contaminants of concern in soils.
~ABLE YVI SOIL CLEANUP LEVELS
Carcinoaenic
Contaminants of
Concern
Cleanu~
level (D~b)
Level of
~
PCBs
cPAKs
.,000
S,OOO
5Z10~
IZ10~
lZ10~
s~
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3.
other Cl~&Dup.L8v.18
,
The area of contamination (AOC) is comprised of the
portion of the site on which disposal of industrial
waste or cO-disposal of municipal and industrial waste
occurred. This area covers approximately eight acres.
Tbe cap will be placed over those areas in or conti-
guous with Waste Areas 2, 3 and 4 where waste has been
disposed or has come to be located or where the soil
cleanup levels are exceeded. This area includes all of
Waste Area 4, the plateau portions of Waste Areas 2 and
3, and the contamination adjacent to the western side
of Waste Area 3. '!'he cap shall extend to the west
beyond the boundary of Waste Area' 3 approximately to
the location of boring 70. The waste management unit
is the area which includes the cap, groundwater
extraction wells adjacent to the waste area, side
slopes of Waste Areas 2 and 3 and the eastern leachate
collectors. ~he remedy will be implemented and main-
tained to achieve the specified groundwater and soil
cleanup levels at the boundary of the waste management
unit.
If Waste Area 2 is completely excavated as part of the
remedy, the following performance standards will apply.
Waste Area 2 will be excavated until: (1) all of the
waste material is removed; (2) only natural soil (no
deposited waste) remains; (3) a soil testing program
demonstrates that at the vertical and lateral limits of
excavation, there are no volatile or semi-volatile
contaminants above contract laboratory program
detection limits and that all metals are below three
times the background level. All of these conditions
must be attained to meet the performance standards for
complete excavation of Waste Area 2.
The selected remedy does not require that isolated
areas of organic contamination (e.g. Waste Area 1) be
excavated and placed under the cap because these areas
are not of sufficient volume to pose a significant
threat to qroundwater nor do they pose other
unacceptable risks. If, however, during the
implementation of the remedy, significant volumes of
isolated organic contamination are discovered which
would exceed soil cleanup levels or otherwise represent
a qroundwater, direct contact, or air emission risk,
this contamination would be excavated. Such material
would be consolidated under the cap unless such action
was prohibited by federal land disposal restrictions.
The selected remedy will result in the covering of all
areas identified as representing a total direct contact
threat of 1X10.5 or greater. In addition, although the
cleanup standards for PCBs and PARs are 6 and 3 ppm,
respectively, the cap will cover all soil which prior
-------
sampling has shown to be contaminated with PCBs or pARs
above 1 ppm.t The selected remedy will also result in
the containment of those areas with sufficient ~olumes
of waste or contaminated soil or both to pose a long-
term. threat to groundwater. ~
B.
Description of Remedial Components
The selected source control remedial alternative will
constitute a containment option with little or no treatment
of the waste. It is designed to: (1) prevent dermal contact
with and ingestion of contaminated soil: (2) reduce or
prevent, to the extent practi~able, infiltration of surface
and/or groundwater into waste areas and leaching of
contaminants from waste areas into the groundwater below and
downgradient of the waste: and (3) control the harmful
buildup or emission of landfill gases.
The major components of the selected remedy are listed and
described in further detail below.
s.
6.
7.
8.
Two French drains
Source control extraction wells
Capping Waste Areas 2, 3 and 4
Active gas collection and passive gas venting
systems
Side slope stabilization
Operation and maintenance of the selected remedy
Institutional controls to restrict future site use
5 year reviews of the effectiveness of the remedy
1.
2.
3.
4.
The bushes and trees in Waste Areas 2, 3 and 4 will be
cleared and grubbed to facilitate side slope stabilization,
french drain installations, and construction of a multilayer
cap and side slope covers. A chain link fence approximately
8 it high will be constructed to restrict access to the
waste management unit. Warning signs will be posted on the
perimeter fence as necessary. The fence and signs will be
subject to periodic inspections and maintenance.
Two french drains (see Figure 3, Appendix A) will be
constructed at specified locations around the perimeter of
the vaste areas. Construction of a french drain involves
the placement of perforated pipe along the bottom of a
trench so that water flowing through or over the soil will
drain into the trench and be collected in the pipe. The
french drains or some equivalent method of water collection
must be designed, constructed, and maintained to achieve the
objectives and specifications established in the following
paragraphs.
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The first french drain-will be constructed along the
upgradient western and southern perimeters of Waste Area 4
to intercept both overland and shallow subsurface
groundwater flows from the surrounding uplands and to
prevent this water from entering Waste Area 4. It is
anticipated that the french drain will be approximately 650
ft long and up to 2S feet deep. ~e water collected in the
french drain will be analyzed in a representative manner.
If the water collected in the french drain exceeds the
groundwater cleanup levels, it will be treated in the
management of migration treatment system or other equivalent
treatment system. The french drain will be operated and
~~intQined until the cleanup levels described in section X.A
for groundwater at the boundaty of the waste management unit
and in the water collected in-the french drain are achieved.
If the performance standards are exceeded after the use of
the french drain is discontinued, the french drain will be
brought back into operation.
The second french drain vill be constructed in the uncapped
area along the northern edge of Waste Area 4 and the western
edge of Waste Area 3 in the area of monitoring wells 28, 21
and 38. The purpose of this drain is to prevent shallow
subsurface water which may flow horizontally above the till
from entering Waste Area 3. It is anticipated that this
french drain will be approximately 200 ft long and 25-35 ft
deep. The vater collected in the french drain will be
analyzed in a representative manner. If the water collected
in the french drain exceeds the groundwater cleanup levels,
it will be treated in the management of migration treatment
system or other equivalent treatment system. The french
drain will be operated and maintained until the cleanup
levels described in section X.A for groundwater at the
boundary of the waste management unit and in the water
collected in the french drain are achieved. If the
performance standards are exceeded after the use of the
french drain is discontinued, the french drain will be
brought back into operation.
Source control extraction wells will be installed in Waste
Area 3. Source control extraction wells will be placed in
locations that allow for the capture of water which would
otherwise move east towards the Black River. The number of
wells will be sufficient to maintain the maximum practical
contaminant removal. In evaluating the number and location
of source control extraction wells, th~ impact of stagnant
zones, pump rates, and the potential for extracting clean
water from beyond the area of contamination will be
considered, at a minimum. The water collected in the source
control extraction wells will be analyzed in a represent-
ative manner. If the water collected in the source control
extraction wells exceeds the groundwater cleanup levels, it
will be treated in the management of .migration treatment
system or other equivalent treatment syste~. The source
control extraction wells will be operated and maintained
-------
until the cleanu~ levels described in section X.A for.
groundwater at the boundary of the waste management.un1t and
in the water collected in the source control extraction
wells are achieved. If the performance standards are
exceeded after the use of the source control wells is
discontinued, the source control extraction wells will be
brought back into operation.
The principal component of the selected remedy is place~ent
of a multilayer cap over those areas in or contiguouS w1th
Waste Areas 2, 3 and 4 where waste has been disposed or has
come to be located or where the soil cleanup levels are
exceeded. This area includes. all of Waste Area 4, the
plateau portions of Waste Areas 2 and 3, and the
contamination adjacent to the western side of Waste Area 3.
The cap shall extend t.o the 'West beyond the boundary of
Waste Area 3, approximately to the location of boring 70.
(see Fiqure 4, Appendix A for estimated location and Fiqure
5, Appendix A for a typical cap cross-section). The plateau
portions of Waste Areas 2 and 3 are those locations which
have a slope of less than or equal to 3:1. The side slopes
(or outslopes) are those areas of Waste Areas 2 and 3 which
have a slope of greater than 3:1. The cap will be designed
to meet or exceed the performance requirements set forth in
40 CFR 264.111, 40 CFR 264.310 and the qui dance document
Final Covers on Hazardous Waste Landfills and Surface
ImDoundments, July 1989 (EPA/530-SW-89-047) (Technical
Guidance) or in a manner to achieve performance equivalent
to that required by 40 CFR sections 264.111, 264.310 and the.
Technical Guidance. Site specific conditions will be
considered in determining the most effective cap design. A
typical RCRA ~echnical Guidance cap includes a 1 foot gas
vent layer over prepared subgrade, followed by a geotextile
filter, a 2 foot low permeability soil layer, a
geomembrane, a 1 foot drainage layer, a geotextile filter,
with a cover of sufficient soil and topsoil to provide for a
grass cover and to provide adequate frost protection. The
finished surface of a typical cap is seeded with grass.
To expedite the construction of a cap on Waste Area 4,
additional measures to dewater the waste area (e.g. pumping)
will be considered, and, if found appropriate by EPA during
remedial design, implemented. The cap must be maintained
for a minimum of thirty years from the date the cap is
completed and thereafter until EPA determines that further
aaintenance is not necessary. This maintenance may include
reconstruction, if necessary, of all or a part of the cap,
active gas collection and passive gas venting systems,
french drains, water treatment systems, and/or stabilized
slopes.
Active gas collection and passive gas venting will be used
to prevent the harmful buildup or release. of landfill gases
from the areas beneath the cap or the stabilized_lopes.
The landfill gases will be treated using vapor phase carbon
-------
or an equivalent Jethod. of treatment. Waste Areas 2,,,and 4
will have a passive gas venting system installed as part of
the cap. A passive gas venting system (see Figure 5,
Appendix A) ~nvolves installing gas vents into the cap. A
sufficient Dumber of gas vents will be installed! (1) to
prevent the harmful buildup of ~ethane and/or carbon
dioxide, and (2) ~o provide for the collection and treatment
of landfill qases containing hazardous substances. The
passive gas venting systems for Waste Areas 2 and 4 will be
operated and maintained as part of the maintenance of the
cap. The treatment of landfill gases will continue until a
demonstration is made that ha~ardous substances in the
landfill gas do not represent.a potential threat to human
health or the environment. Ip making the demonstration and
in monitoring gas emissions, the landfill gas will be tested
at the source of emission (e.g. at the gas vents).
An active gas collection system (see Figure 6, Appendix A)
will be used in Waste Area 3. The active gas collection
system will involve the use of vertical wells or equivalent
method to increase the flow of landfill gases to the
collection system. The system will involve the placement of
sufficient vertical gas collection wells and vents to
prevent the buildup of methane and to provide for the
collection and treatment of landfill gases containing
hazardous substances. The active gas collection system will
also be designed to prevent or minimize, to the extent
practicable, the escape of landfill gases containing
hazardous substances from the side slope of Waste Area 3.
If the side slopes are covered in a manner which allows for
the installation of a passive gas venting system, a passive
gas venting system may be considered in place of the active
gas collection system provided the same level of performance
will be achieved and maintained. If the passive gas venting
system for Waste Area 3 fails to achieve the performance of
an active gas collection system, then the system will be
converted to an active gas collection system. The treatment
of landfill gases will continue until a demonstration is
made that hazardous substances in the landfill gas do not
represent a potential threat to human health or the
environment. In making this demonstration and in monitoring
gas emissions, the landfill gas will be tested at the source
of emission. The active gas collection system will be
operated and maintained as part of the cap maintenance.
The eastern slopes of Waste Areas 2 and 3 (aee Figure 4,
Appendix A for estimated locations) will be stabilized to
prevent any slope failure which can damage the cover system
or which could allow releases of waste and leachate into
sU~Dundinq 80ils and groundwater. Each slope must be
designed to withstand the loading and hydraulic conditions
to which it will be subject during the cap's construction
and post-closure periods. In addition; the slopes.of Waste
Areas 2 and 3 will be stabilized so that a greater than 1.25
long-term factor of safety is achieved. Each slope will be
-------
stabilized to prevent or minimize, to the degree
practicable, .shift.s, cracks or slumpage in the slope in
excess of those expected by waste settlement and to prevent
a decrease in the integrity, permeability or eff~ctiv~ness
of the cap. The cover used on these eastern slopes wJ.ll
minimize infiltration of water through the cover and willi
to the degree possible, attain the performance standards inll
40 CFR 264.310. The best method of slope stabilization w
be determined during remedial design. The side slope covers
and stabilization will be maintained as part of the
aaintenance of the cap.
The excavation of a portion of the side slope of Waste Areas
2 or 3 to achieve the desired'qrade is one method of
stabilization. Any material removed from Waste Areas 2 or 3
to achieve the slope stabilization standards of this section
or removed :from elsewhere within the area of contamination
to remediate the site can be consolidated in Waste Area 3
beneath its cap. This consolidation of waste material may
include a portion or all of Waste Area 2. A design or
remedial action decision regarding the appropriate extent of
this excavation will be governed by the nine criteria as
described in the NCP, :focusing on faplementability and cost
of alternative design approaches to meet the performance
standards for the soils and cap. If, after such possible
excavation in Waste Area 2 and consolidation in Waste Area
3, it is demonstrated that there is no wa,te material or
contaminated soil in a portion or all of Waste Area 2 (i.e.
the performance standards in section X.A are attained), no
cap would be required over those portions of Waste Area 2.
.In order to monitor the performance of this remedial
alternative, sampling/testing of the following will be
performed before and during the 0 , M period: (1) the
stability of side slopes: (2) water collected from the
french drains and source control wells: (3) landfill gas:
and (4) groundwater. Landfill gas monitoring will be used
to optimize the gas collection and treatment processes to
meet the performance standards and ensure that the
concentration of contaminants in air emissions and ambient
air on- and off-site are protective of human health and the
environment. Monitoring will also be required to ensure
compliance with 40 CFR 264, Subparts P, G and N.
In conjunction with this remedial action, a public
information program will be used to educate the public about
the hazards of the site. Deed restrictions will be imposed
to restrict the use of the site within the fenced area.
This will include restricting excavation or any activity
that might compromise the integrity or performance of the
cap, french drains, wells, slopes or other remedial
features. Institutional controls restricting groundwater
use sitewide and land use beyond the fenced area are
contained in the ROD for the first operable unit. .This
remedy does not limit or modify the institutional controls
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found in the first operable unit ROD.
e . -
Based upon the current delineation of the site resulting
from the sampling and analysis of the completed studies, the
area outside the waste management unit which is not required
for use during implementation of the selected remedy will
not be restricted from use after the construction of the
remedy. Any excavation activity occuring outside of the
waste management unit, but within the boundary of the 27
acre study area or the general area of the landfill and the
plateau should include sampling for site related
contamination and should proceed with caution. The
restrictions on qroundwater use established by the first
operable unit will remain in place until qroundwater cleanup
levels in section X.A are achieved.
As required by law. if any hazardous substances, pollutants
or contaminants remain at the site, EPA will review the site
at least once every ~ive years after the initiation of
remedial action to assure that ~he remedial action continues
to protect human health and the environment. EPA vill also
evaluate risk posed by the site at the completion of the
remedial action (i.e., before the site is proposed for
deletion from the NPL).
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XI.
STATUTORY DETERMEN1TION~
~he remedial action selected for implementation at the Old
springfield Landfill site is consistent with CERCLA and, to ~e
extent practicable, the NCP. ~he selected remedy is protect1ve
of human health and the environment, attains ARARs, with the
exception of one state ARAR which is being waived, and is cost
effective. Additionally, the selected remedy utilizes alternate
treatment technologies or resource recovery technologies to the
maximum extent practicable.
A.
~h. Selecte4 aeme4y i. protective of Human Health an4
1;ba s'nvironment .
The remedy at this site will permanently reduce the risks
posed to human health and the environment by elimi~ating,
reducing or controlling exposures to human and env1ronmental
receptors through treatment, engineering controls, and
institutional controls. More specifically, the cap will
reduce the infiltration of water into the waste areas which
would otherwise come into contact with contaminated waste
material or soil and leach contamination into the
groundwater. The cap will also allow for the collection of
landfill gases containing VOCs. The selected remedy
requires the treatment of these gases. The selected remedy
will also prevent direct contact with soils containing PCBs
and PARs. Moreover, the selected remedy will result in
human exposure levels that are wi thin the 10.' to 10.6
incremental cancer risk range or are consistent with
regulatory standards if those standards are outside the risk
range and compliance with the risk range is not feasible due
to PQLs and that are within the hazard index of one for non-
carcinogens. More specifically, all of the identified risks
which exceed the point of departure which were not fully
addressed by the 1988 ROD will be addressed by the selected
remedy. Finally, implementation of the selected remedy will
not pose unacceptable short-term risks or cross-media
impacts. The possible excavation of material from the waste
areas to construct the cap and stabilize the side slopes is
the activity with the most significant potential short-term
impacts. Careful construction practices and air monitoring
will be used to minimize any potential short term impacts
which may occur during excavation.
B.
~be Selecte4 aeme4y Attains ~s
This remedy will attain all applicable or relevant and
appropriate federal and state requirements that apply to the
site, with the exception of one state ARAR which is being
waived pursuant to section 121(d) (4) (C) of CERCLA because it
is technically impracticable from an engineering
perspective. Environmental laws from which ARAR~ for the
selected remedial action are derived, and the specific
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.
ARARs, include:
Chemical SDecific
Safe Drinking Water Act (SDWA)
Vermont ARS Public Water System
Vermont Ground Water Protection Standards
Vermont Water Quality standards
National Ambient Air Quality standards
Vermont Air Pollution Control Regulations
Location SDecific
Fish and Wildlife Coordination Act
RCRA Location Standards
The site is not located within a wetland, wilderness area,
wildlife refuge, or critical habitat, nor will the selected
remedy impact wetlands.
Action SDecific
Resource Conservation and Recovery Act (RCRA)
Occupational Safety and Health Act (OSHA)
Clean Air Act (CAA)
Clean Water Act (CWA)
National Pollution Discharge Elimination System (NPDES)
'Fish and Wildlife Coordination Act
To Be Considered
National Primary and Secondary Drinking Water Regulations:
Proposed Rule
Federal Ambient Water Quality criteria
EPA Risk Reference Doses (RfDs)
EPA Carcinogen Assessment Group Potency Factors
Federal Threshold Limit Values (TLVs)
Executive Order 11988 Protection of Floodplains
EPA Groundwater Protection Strategy
EPA Technical Guidance Document on Final Covers
Closure with Waste In-Place
Interim RCRA/CERCLA Guidance on Non-Continguous Sites
Interim Policy for Planning and Implementing CERCLA Response
Actions
Proposed Standards for Control of Emissions of Volatile
Organics
Proposed Standard on Gas Collection
Appendix C to this ROD lists all ARARs for the site and
whether they are applicable, relevant and appropriate or to
be considered. Any changes to applicability or .
appropriateness or relevance of an ARAR or the waiver of an
ARAR are discussed below.
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Chemical Specific.
. .
The bedrock aquifer at and beyond the compliance
boundary of the Landfill is a possible dri~ing water
source. Maximum contaminant Levels (MCLa) promulgated
under the Safe Drinking Water Act which regulate. public
drinking water supplies, are appliCable to drink1ng
water at the tap and are not applicable to groundwater.
However, because the groundwater may be used as a
potential drinking water source, MCLs are relevant and
appropriate.
~he Vermont Groundwater frotection Act establishes
primary groundwater qual~ty standards and contains
enforcement standards. Under the Act, two enforcement
standards have been established which are more
stringent then MCLs. The standards are for
tetracholoroethene and xylenes. EPA has incorporated
the enforcement standard for xylenes as the cleanup
level for this contaminant of concern. Pursuant to
CERCLA section 121(d) (4) (C) and section
300.430(f)(1) (ii) (C)(3) of the NCP, EPA is invoking a
waiver of the enforcement standard for tetra-
chloroethene. EPA has determined that in this
circumstance it is technically impracticable from an
engineering perspective to establish a standard below a
practical quantitation level (PQL). The PQL is the
lowest concentration that "can be reliably measured
within specified limits of precision and accuracy
during routine laboratory operating conditions." 54
~. ~. 22062, 22100 (May 22, 1989). For evaluating
standards set with respect to drinking water, EPA uses
the methods determined by the SDWA. Therefore, the PQL
determined in accordance with SDWA methods will be the
cleanup level for tetrachloroethene. This level is
equivalent to the MCL for tetrachloroethene.
1.
2.
Action Specific.
RCRA hazardous waste closure requirements, 40 CFR Part
264, Subpart G, and hazardous waste landfill closure
requirements, 40 CFR 264.310, Subpart N, are ARARs for
a substantial part of the remedial action. Under Part
264, Subpart G, closure of a hazardous waste disposal
facility must be done so as to control, minimize, or
eliminate "post-closure escape of-hazardous waste,
hazardous constituents, leachate, contaminated run-
off, or hazardous waste decomposition products to the
ground or surface waters or to the atmosphere".
Section 264.11l(b). Section 264.310, Subpart N,
provides specific closure requirements for a hazardous
waste landfill.
Pursuant to the NCP, EPA has determined that the RCRA
-------
hazardous wa~e cl~sure requirements (40 CFR 264.111,
264.310) are not applicable to the site because'the
RCRA requirements were promulgated after the Old
Springfield Landfill ceased operation. However, EPA
has determined that these RCRA hazardous waste closure
requirements are relevant and appropriate to the
remedial action. The 1988 FS indicates the presence of
RCRA-listed hazardous wastes at the site. In addition,
other substances disposed of and found at the site are
similar to RCRA hazardous wastes. Objectives of the
remedial action, such as preventing the leaching of
soil contaminants to the groundwater and preventing
public contact with contaminated .oil or leachate that
may present a risk, are similar to the purposes of the
RCRA hazardous waste landfill closure requirements.
The source control operable unit is itself similar to
the closure activities required by RCRA, and the medium
to be addressed is similar to the medium regulated by
RCRA requirements.
In certain areas of the site, however, the RCRA
requirements, while relevant, have been determined not
to be appropriate to the remedial action. The side
slopes along Waste Areas 2 and 3 are sufficiently steep
so that a multi-layer cap would not be suitable. For
the limited area of the steep side slopes along Waste
Areas 2 and 3, EPA has determined that the RCRA
hazardous waste landfill closure requirements are not
appropriate.
In addition to considering the RCRA landfill closure
requirements relevant and appropriate, EPA also
considers the July 1989 Technical Guidance Document,
Final Covers on Hazardous Waste Landfills and Surface
ImDoundments, a To Be Considered (TBC) criterion for
help in determining the protectiveness of alternatives.
This guidance document provides the technical basis for
implementation of the RCRA ARAR and recommends the use
of a multi-layer cap with natural and synthetic
materials.
RCRA includes specific provisions restricting the
placement of hazardous waste into a land-based unit,
which includes a landfill. The RCRA Land Disposal
Restrictions (LDRs) are not applicable to consolidation
of material under the cap which has been taken from any
of the three waste areas that have been identified.
The movement of waste within a land-disposal unit does
not constitute land disposal for purposes of
application of RCRA LDRs. The area of contamination
(AOC) at the Old Springfield Landfill is comprised of
the approximately eight-acre portion of the Landfill on
which co-disposal of municipal and industrial ~aste
occurred. References to three "waste areas" in this
ROD and the feasibility study reports .'are used for
-------
descriptive purposes to indicate those areas where
drilling endbunte~ed evidence of high concentrations of
contaminants. Historical photographs of the site
provide evidence of the random disposal of ~aste within
the "OC. Given the .random nature of disposal at the
site, the three waste areas are part of one continguous
(AOC). ~herefore, consolidation of waste under the cap
does not qualify a. placement into a unit but is merely
movement within the unit.
c.
~he S.lec~.4 a..edial Action is Cost-Bffective
In the Agency's judgment, th~.selected remedy is cost
effective, i.e., the remedy affords overall effectiveness
proportional to its costs. In selecting this remedy, once
EPA identified alternatives that are protective of human
health and the environment and that attain, or, as
appropriate, waive ARARs, EPA evaluated the overall
effectiveness of each alternative by assessing the relevant
three criteria--long term effectiveness and permanence:
reduction in toxicity, mobility, and volume through
treatment: and short term effectiveness, in combination.
~he relationship of the overall effectiveness of this
remedial alternative was determined to be proportional to
its costs. A detailed description of the costs of this
remedial alternative are shown in Figure 7 of Appendix A.
Of all the alternatives which met the two threshold
criteria, the selected alternative is the least costly. ~he
selected alternative was at least an order of magnitude less
-expensive than the other alternatives which satisfied the
two threshold criteria. Due to the large volume of waste
material, the other alternatives have costs which are
substantially greater than the selected alternative.
~he Selected Remedy utilizes Permanent Solutions and
Alternative ~reatment or Resource aecovery ~.chnologies
to the Maximum Extent Practicable
Once the Agency identified those alternatives that attain
or, as appropriate, waive ARARs and that are protective of
human health and the environment, EPA identified which
alternative utilizes permanent solutions and alternative
~reatDent technologies or resource recovery technologies to
the maximum extent practicable. ~his determination was made
by deciding which one of. the identified alternatives
provides the best balance of trade-offs among alternatives
in terms of: 1) long-term effectiveness and permanence: 2)
reduction of toxicity, mobility or volume through treatment:
3) short-term effectiveness: 4)implementability: and 5)
cost. ~he balancing test emphasized long-term effectiveness
and permanence and the reduction of toxi~~ty, mobility and
D.
-------
volume through treatment; and considered the preference for
treatment as a pri~cipal ~lement, the bias against off-site
land disposal of untreated waste, and community and state
acceptance. The selected remedy provides the best balance
of trade-offs among the alternatives. The selec~ed remedy
is not permanent and does not involve treatment as a
principal element. However, it will be effective in the
long-term provided the remedy is maintained. In addition,
the selected remedy exceeds all other alternatives for the
criteria of short-term effectiveness, implementability and
cost effectiveness.
The selected remedy will provide for the shortest period of
construction. It will also require lower volumes of
excavation than alternatives a through 5. This will result
in less risk from potential volatilization of organic
compounds during the excavation of 80il or waste. The
selected remedy will also have greater short-term
effectiveness by achieving the reduction in risks from
direct contact with soils and landfill gas emissions in the
shortest time. The selected remedy will be the most
implementable and least costly of the alternatives which
satisfy the two threshold criteria. It provides the
greatest benefit in proportion to cost. The Old Springfield
Landfill site is a landfill with approximately 125,000 cubic
yards of mixed industrial and municipal waste. All of the
alternatives which would treat this volume of waste would be
considerably more expensive. On balance, the selected
remedy provides adequate protection at the least cost.
~he Selected Remedy does Dot satisfy the Preference for
~r.atment Which Permanently and Significantly reduces
the ~oxicity, Kobility or Volume of the Hazardous
Substances a8 a principal Element
The selected remedy does not satisfy the preference for
treatment which permanently and significantly reduces the
toxicity, mobility, or volume of the hazardous substances as
a principal element due to the large volume of heterogenous
material. The selected remedy is consistent with EPA's
preference for containment of wastes which it is not
practicable to treat. Of the alternatives which satisfied
the two threshold criteria, the two alternatives which
involved treatment, alternatives 4 and 5, would have each
cost more than 100 million dollars.
E.
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XII. DOCUKBNTATION OF SIGNIFICANT CHANGES
EPA presented a Proposed Plan (preferred alternative) ~for
remediation ot the site on July 12, 1990. The preferred
alternative included capping of Waste Areas 2, 3 and 4, .
construction of french drains, active gas collection and pass1ve
gas venting systems, side slope stabilization, installation of
source control extraction wells, and institutional controls. The
selected remedy includes all of the components of the preferred
alternative as listed in the Proposed Plan. However, the
selected remedy establishes performance standards and objectives
for attainment of cleanup levels in lieu of setting construction
specifications. This will allow tbr flexibility in design of the
selected remedy and does not require additional public comment.
The ROD contains the addition of the National Primary and
Secondary Drinking WateT ~equlations (NPSDWR), Proposed Rule, as
a To Be Considered. The NPSDWR proposed rule provides guidance
for the use of practical quantitation levels, which are the
lowest concentration levels that can be consistently measured in
the laboratory. The Vermont Groundwater Protection Act is an
ARAR for the site. The Act establishes enforcement standards for
groundwater. A waiver is being invoked for the enforcement
standard for tetracbloroethene on the basis of technical
impracticability a There are no changes in procedural or process
requirements as a result of this waiver, nor does it alter the
feasibility of the selected remedy. Invoking this waiver does
not require additional public comment.
The preferred alternative also included an option which would
involve the complete excavation of Waste Area 2 and the placement
of the material in Waste Area 3. The selected alternative is
consistent with the Proposed Plan in calling for a multi-layer
cap and side slope stabilization. However, the option to
excavate Waste Area 2 has been incorporated into the selected
remedy as a design consideration. Further geotechnical analysis
will allow for a better determination of the cost and design
approach for stabilizing the slope along Waste Area 2. Either
excavation or capping with slope stabilization of Waste Area 2
meet the two threshold criteria. Therefore, EPA will be guided
by the remaining seven criteria in reviewing design approaches
for Waste Area 2.
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ZIII. STATE ROLE
The Vermont Department of Environmental Conservation has reviewed
the various alternatives and has indicated its support for the
selected remedy. The state has also reviewed the Remedial
Investigation, Endangerment Assessment, Feasibility study,
Focussed Feasibility Study, Supplemental Feasibility study and
Detailed Evaluation Memorandum to determine if the selected
remedy is in compliance with applicable or relevant and
appropriate State Environmental laws and regulations. The state
oi vf:rIi:lont ,"oncurs with the selected remedy for the Old
Springfield Landfill site. A copy.:of the declaration of
concurrence is attached as Appendix D.
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APPENDIX A
FIGURES
-------
. '..
LOCATION IIA'
CAVENDISH
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W~Wcl~@IN11r
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OLD SPRINGFIELD
LANDFILL SITE
FIGURE 1
SITE LOCATION MAP
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-------
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SPRINGFIELD
MOBILE HOME ESTATES
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OLD SPRINGFIElD LANDFJU. SITE
6PR~GFELD, VERMONT
ADAPTm FROM: REMCOR..eo
FIGURE 2
BURIED WASTE
AREA LOCATIONS
NOT TO ICALE EB ASCO
-------
1) UPCftAOIOfT Of "Am MEA ..
2) 1IE1WttN "Am AREAS 3 AND ..
Ct01tX1U:
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-------
. . .
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--: WASTE AREA 1 Y~O~ARY
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OLD SPRINGFIELD
LANDFILL SITE
FIGURE 4
SITe MAP
- - - - PENCH DRAW
A IOURC! CONTROL WEU.S
lOURce: R!MCOA. .80
OWC: !PAOli
-------
VAPOR
PHASE
AC11VA1EO
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CAS MICRA 1ION
CAS MlCftA110N
FIGURE - S
WASTE
TYPICAL LANDnU GAS
COLLECTION/TREATMENT
SYSTEM CROSS-SECTIONS
CAS MICRI\110N
flOf 10 SCAlE
OLD SrRltlCriElD lAHOrlll snt
-------
2. ACl1VE LANDFIll CAS SYSmot (WAS1[ AREA 3)
24 INCH ClEAN F'IlL LAYER
12 INCH DRAINACE lAVER
24 INCH COMPACttO ClAY LAYER
12 INCH CAS------
VENT LAYER
.. INCH DIAMETER 0 0
PERFORA TED HORIZONTAl
RIDCE COllECTOR
o HOOKUP TO
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WAS1E
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BOREHOlE
ttlESCOPINC 'iERl1CAl
EXTRAC110N YlEll.
PERF'ORA TED PYC
(4 INCH NOMINAL DIAMETER
OU1t:R SCREEN. 2 INCH
NOMINAL DIAMETER INNER
SCREEN)
CONTROl ASS04BlY
Ft.4l B0011£ ern')
~
FlDlllll: MEM8AANE
LINEA ~M1l HOPE..
8L-
TO CAS COllECl1ON
HEADER (HOOKUP AS
IDENl1F1ED ABOVE)
o
o
WASHED
CRUSHED
STONE
(TyP)
o
o
FIGURE. 6 :
TYPICAL LANDFILL GAS
COLLECTION / TREATMEN\
CROSS-SECTIONS
-------
I'IGURE 7
EPA COST ESTIMATB FOR SELECTED REMEDY
COMPONENT
~
1.
SUPPORT FACILITIES
55,200
92,800
..
4..
~r:Ct~!TY ~ENCING
.
3.
FRENCH DRAIN WAt4
WAf3
1,244,600
332,440
4.
SOURCE CONTROL WELLS 12)
DECOMISSIONING OLD WELLS
CAP '3 & 4
1,576,040
59,000
5.
6.
22,300
1,977,200
7.
CAP , 2
SIDE SLOPE STABILIZATION &
COVER OF SIDE SLOPE:WASTE AREA 3
290,200
191,000
8.
SIDE SLOPE STABILIZATION &
COVER OF SIDE SLOPE: WASTE AREA f 2
10. DEWATERING WASTE AREA 4
9.
1,050,000
43,200
11. SOIL VENTING SYSTEMS
12. DEED RESTRICTIONS
200,300
10,000
13. PUBLIC AWARENESS
10,000
---------------------------------------------------
TOTAL CAPITAL COSTS
CONTINGENCY (20'>
ENGINEERING (10'>
5,568,800
1,113,800
556,900
LEGAL AND ADMIN. (5')
TOTAL
278.400
7,517,900
ANNUAL 0 , M
NPV (10'> 0 , M
5 YEAR REVIEWS
NPV (10'0
123,000
1,159,500
10,000
15,400
----------------------------------------------------
TOTAL NPV OF ALTERNATIVE
-------
APPENDIZ B
CONTAMINANTS 01' CONCERN .
-------
CODtami~a~ts
9f Concern
~ABLE 1 t 8t7HKARY 0' CONTAMINANTS
D' CONCER.N IN GROt1ND WATER
EASTERN MONITORING WELLS
e .
avera;e Xaz1aua
Conc.Dtratio~ Co~ceDtratio~
. flla/l' "Jail'
Frequ.~c7
of Detection
vi~71 Cblori~e 11
Metbyle~e Chlori~e 1500
1,1-Dicbloroethene 1.4
1,1-Dicbloroetbane I.'
trans-l,2-Dicbloroetbene 10.2
1,1,1-~richloro.tb&D. I.'
~richloroetben. 20.'
~etracbloro.tb8D. ..,
.enzen. 1.2
Cblorofor.a 4.7
~olYene 8
ChlorobenzeDe '.7
1,2-Dichlorobenzene 10.3
Etbylbenzen8 7.7
Xylene.' 12.'
~cetone 11.1
Dietbylptbalate '.3
lis (2-etbJlbexyl)ptbalat.15.3
Naptbalene 13.'
Di-n-bYtylptbalate ,
'PCB-1254 0.'
PCB-12'0 0.'
Copper 18.'3
Nickel 28.43
Cobalt 14.41
..20
1500
140
180
4100
1100
'100
'200
- 710
1.3
"0
42
51
140
1341.'
4381.8
3
350
57
10
?2
2.1
112
332
~0.3
3/13
1/1
2/13
1/13
5/13
5/13
1/13
1/13
2/13
./13
4/11
1/11
3/12
2/11
3/11
1/7
1/11
4/12
3/12
3/11
1/12
1/12
5/11
'/11
-------
'l'A~L~ 2: 8t1YJO.RY 01' C~NTAMINANTS
01' CONCERN IN ~ROUND WATER
WESTERN MONITORING WELLS
Contaminant.
of Concern
&VlPraqe.
Concentration
lua/l)
Maximum
Concentration
lua/l)
Frequency
of Detection
ViDyl Chloride ...
1,I-Dichloroethen8 I.'
1,1-DichloroethaDe I.'
~raD'-1,2-DichloroetheD8 1.5
1, 1, l-Trichloroethan8 3.4
~richloroethene 5.4
~etrachloroethene 2.1
Benzene 2.5
~oluene 1.1
Chloroform 1.3
Chlorobenlene 2.5
Zylene. 2.7
Bi.(2-etbylhexyl)pthalate 8.5
Napthalene 13.'
Copper 13.75
Cobalt 18.06
.'
110
~.,
".4
3'.8
14
150
1
1.2
".4
1.1
I.'
".2
5.'
57
57.3
37.8
1/11
3/11
J/l1
"/11
J/l1
"/11
1/11
1/11
../'
1/11
1/10
1/'
2/11
3/12
4/11
-------
!'A'SL! 3 t StOOO.RY O~ CONTAMINANTS
0' CONCERN IN ZASTERN LEACHATE SEEPS
contaminut.8
pf Concern
Avera;e
Concentration
fucr/l)
lIuimla
Concentration
fucr/l)
~Z'equency
of Detection
vinyl Chloride 11.1
1,1-Dicbloroetbene J..
1,1-DicbIoroetbane 4.'
~r&D.-1,2-Dicbloro.thene 1.3
1,1,1-~ricbloroetbane ...
~Z'icbloroetbene 5.'
~etracn~o~o.~b.~. 4.1
1,2-Dicbloro~enlen8 10.'
X118ne. 2.'
Acetone 4.3
Bi.C2-ethylhexyl)ptbalat810.3
Naptbalene 11..
Copper 11.'5
Nictel 25..
Co~alt 12.1'
3.5..
S'.l
4'.1
J...5
2...
112.5
. 10.3
~. 1'.1
1.3
10
12
10.'
'8
45
13
2/'
2/'
1/'
2/'
2/'
Z/,
1/'
1/'
1/5
1/5
1/'
11'
2/'
4/'
1/'
nELE 4 t SUHH),RY 07 CONTAMINANTS
07 CONCERN IN WESTERN LEACKATE SEEPS
Contamina.nt.
of Concern
Avera;e
Concentration
fucr/l)
MulJDum
Concentration
fucr/I)
I'requencJ
of Detection
Vinyl Chloride '.2
1,1-Dichloroeth8ne 4.1
1,1-Dichloroetha.ne 3.4
tra.ns-l,2-Dicbloroethene 12.1
1,1,1-Tricbloroethane '.5
~richloroethene 28.1
~8trachloroetben8 J.l
.8nl8ne DC
~oluene DC
Cbloro~enlene DC
Ztbylbenzene DC
Xylene. DC
78.2
10.7
'.3
".3
.8.8
223.1
4.1
2.3
1.'
2.4
2..
2..
. .
2/3
2/3
2/3
2/3
2/3
2/3
1/3
1/3
1/2
1/3
1/3
-------
Contaminant.
of Co~cern
~~1!LE 5: S~RY OF cONTAMIJfJmT'8
OF CONCERN IN,~OIL 10.5-2.5 ft.)
. average Maximum
Concentration Concentration
lucr/l) . fua/l)
Frequency
pf Detection
Xethylen ehloriae C.1
tran.-l,2-Dichloro'thene C.l
1,1,1-Trichloroethane 4.5
~riehloroetbene '.3
~etrachloroetbene 5.0
.enlene 5.2
~oluene ~2.2
Chlorofo~ 5.3
Chlorob8Dzane z4
1,2-DicnloroQ.A.8Ae D4
Sylene. 5..
.i.C2-etbylhezyl)ptbaI.te ~32~'
5apthaliDe 221.8
BenloCa,anthr.c8De 122.5
BenloCa)pyrene ~.~.,
Benzo(b)fluorantbene 214.8
Blnzo(k)fluoranthene 22'.8
Chry.ene 230.8
Indeno(1,2,3-c4)pyr8ne 221.5
PCB-125e 14.5
PCB-121C 2'.3
Cadmium 1'0
xercury 21
7,500
1.0
1,'00
5,100
51
5,100
2,300
280
D4
D4
C,200
11,000
C,'OO
12,000
10,00D
11,000
.,200
12,000
4,400
12,000
5,281
C,'OO
1'0
1/11
1/3'
1/32
7/31
2/31
5/31
14/2'
'/30
D4
D4
3/31
3/22
1/3'
C/3.
5/2'
'/31
2/3.
5/3.
1/3.
5/3'
3/38
12/42
-------
!'A!!L! 1 I StrHMARY OP CON'rAHINJ.N'l'S
or CONCERN IN SOIL 15-7 ft.)
e>ntulnl.Dt.
f Concern
. .
avera;e
Concentration
lua/l)
riebloro8tb8n8 me
e>lu8n8 .1
b1orobenzene 10
,2-nieb1orobenzaD8 1'1
r1en8. f.
l.(2-etby1bezy1)pthalatel,"S
aptba1en8 .18
Inlo(a)antbracen8 .71
Inzo(a)pyren8 800
Inzo(b)fluorantbene ICS.
bry.ene 81'
:1-12IC '12
:1-1210 ."
admium 600
Ircury 100
Mui.WI
Concentration
l12a 11 ,
13
a,.oo
1,700
17,000
11,IIC
23,000
1,'00
. .70
1.,100
"'1,10
1,000
1.,000
'20
a,.oo
110
Frequ8ncy
of Detection
1/10
1/7
1/10
1/10
1/.
1/7
3/10
1/10
1/'
1/.
a/.
./10
1/10
2/.2
2/17
'J'A!!L! 7 I StTKHARY OP CON'r).MINANTS
OF CONCERN IN SOIL 17-' ft.'
~ntamil1ant.
f Concern
avera;e
concentration
l12a 11 ,
atracb1oro8tbene 171
r1ene. '33
L.(2-etby1bezy1)ptba1at811,000
:1-12IC .81
Ircury 100
Kui.WI
Concentration
l12a/H
11,000
1,'00
11,000
.2,000
110
Frequ8ncy
of Detection
2/1
1/3
1/1
2/3
-------
~ABLZ .: ItrMMARY 0" CO)rr"'jo!J:~~
0" CONCERN IN SOIL ".12 ~t.)
contaminant.
of Concern
avera;e
concytration
1\10' /1) . . -
~ran.-l,2-»icb1or~etbene DC
~ricb1oroetbene 20
~etracbloroetbene 17
~ol\1ene ,.
.aptba1ane 2"
.enloCa)antbracane 42.
..nloCa)pyrane 4.5
Benlo(~)fluorantb~. 473
BenloCt)~l\lor~tbeB. 4"
Chry.en8 107
%ndenoCl,2,,-cd)pyrene 4.3
»ib8nloCa,bJantbracene 431
PCB-1254 11'
Cadmium .'00
Xercury 100
J(ulmum
Concentration
1\10' /1 )
15
2'
130
8.
1,100
11,000
40,000
32,000
'0,000
45,000
""23,000
20,000
.,100
7,'00
1.0
Frequency
of t>etec~.~oD
2/'~
2/'
2/'
1/1
1/'
1/'
1/5
1/5
1/5
1/5
1/5
1/5
1/4
1/5
1/5
'1'ABL!: ,: ItOOotARY 0" CONTAMINANTS
OF CONCERN IN SOIL 112-17 ft.)
contaminant.
of Concerz
.Average
Conc.utratlo~
1\10'/1)
~rlcb1oroetbene 13
~8tracb1oro.tb.n8 5.
~Ol\18n. 104
%y18n8. 171
Bi.C2-8tby1bexy1)ptha1ate2,111
PCB-1254 1004
Xercury 100
Mulmum
Concentration
1\10' /1 )
18,000
15,000
35,000
110,000
27,000
4.,000
170
Frequency
of t>etection
2/5
3/5
4/4
1/4
1/2
3/5
-------
:ontami~a~t8
If COJ'lcern
!rABLE 10: StnOU.RY 0' CONTAMINANTS
0' CONCERN IN SOIL (19-22 ft.)
. .
Average-
Co~c8ntrl1tion
lua/l)
;ran8-1,2-Dicbloroetbue 8e
.,1,1-'l'riCbloroetbaD8 laC
~lu8ne 8C
!hloroform 3
:ontaminants
If Concern
.,2-Dicblorobenaene
.01-1254
!a4mi um
tercuzy
.uiaum
Conc8ntration
(ua/l)
,
1
7
4
Frequency
of t>e~tection
1/3
1/2
1/3
1/2
!l'ABU 11: StnonQJtY 0' CONTAMINJ.N'l'S
OY CO~CERN IN &OIL (25-43 ft.)
average
Concentration
(ua/l)
DC
81'
800
100
Maximum
Concentration
(ua/l)
"
1,100
3,000
230
Frequency
of Detection
1/3
3/3
1/3
-------
APPENDIX C
ARARs, CRITERIA, ADVISORIES
AND GUIDANCE
-------
TAlLE C-'
CIltMICAL-SPECIFlC AIIAIIS A. CIlITEIIA, .YlSOIIES, A. IIIIDAIIC!
OlD SPlllGFIElD LANDFilL SI'E
FEASIIILITY STUDY IIEPOIT
IRllJIII/AUTHOIITY IfGUIRtMEIT STAM IfGUIREMEIT "IOPSIS tOIISIHIATlOII III TIlE 11/"
Ground Veter
F.r.I .. lIelevent MClt h8ft hHn prcIIIIUII.t~ for . rutIer UMft tile ,lat. to ...,.,. ....1 th .. to
letUI.tory end of eOllllClft orlenle end I""',enle e_~tlan of Iraurdletw wr. ..a..aed,
lequlrttllenta Approprlat. eant..hwnta. Theae leye'a retUI.t. the eoncentr.tfGM of eant-lfl8nta of eoncem I"
eoncentr.tfan of eant..1"..ta In""1 Ie th.II/'I, Includl", vlnrl ehlorl~. 1.1-
drlnltl", _ter ...",1 lea. but -¥ .Iao be dlehloroethene. 1,1.1-trlehloroethene,
eCIMI~red relev.nt end epproprl.te for benrene, end 1,~-dleh'orobtftl"- WI'. eGIIIp8I"ed
Ir"""ter equlfen potentl...y used for to their Mela. RCla...,.. used to aet c:t"'"
drlnltl", _tel'. leftl. for th... eant_lnenta.
St.te legulatory AWl-PUblic Uater ..I.....t Y..-.ant 8dapta ''''''1 MCla or ...,tent "nee Alii drl"I", ..,., .t"""'" .... the .
lequlrttllent. Syat.. end Yeter ~IIty erlt.rl., ~Ichever 18 ~ a- .. "Cta, p"'CllUII.tedl'Cla ...... UHd to
Stend8rds Approprl.te atrlntent .. coneentr.tlan of a.t cte.... lewl. 'or eant..lnent. of ecn:"",
eont..lnenta U. drl"I", ...ter at"""'. Includl", ~Inrl chloride, 1.1.dlchloroeth..-,
lite MCla, th... leyela regul.t. the ',1,'-trlehloroeth8nt, trlchloroethene,
ecn:entr.tlan o' eont..lnenta In fl'bl te benzene; end 1,Z-dichlor"'I..-.
drl"I", ...ter .tendlrds.
10 V.I.A. ell.., C8 lel.....t Cant.I.. . wreundWet., c'..alft.etlan Cantel.. """ter ...1 I ty .t"'" for .
Vf er.nIw8ter end aette. end ...0undw8ter "'''ty .tend8rch. ..rlety of eCllllPO'hl8 detected In alte
'roteetfan Act Approprl.te IrCU1dll8ten.
Feder.I Crlter'. m .I.t 1.'8r8nee '0 be IfDa .. ... lwei. deftlaped by the EPA E'. I- ...... ...ed to eh8reet.,I" ,I.h "-
end Advla...I.. DoH8 eRfDa) Cans I derecl for noneerclnovenlc effecta- to e.".,ur. to eant_lnenta I" If'CIIUI'dw8ter, ..
w.. .. oth-.. 8ecI1.. They...... eansl~ for
_thyl..- chloride end tetr8Chloroethl..-.
''''''1 ...Ient '0" ''''''1 AUDC .. ....1 th-be8ecI c,It.,I. AUDC ...... U8ecI to eh8t'8Cterhe healt" 'lat.
...ter OuIlity Cans lderecl ~Ich 188ft been ...Iaped for 'IS eM! to eant..lnent eoncentr.Uans In drlnltl..
trlterl. e.relnovenle end none.relnovenle weter. 'hey wre eanalderecl for chlorof0n8.
e~. tol""'. ehlorabtnlene, .thylbenzene. blaeZ-
ethylhe.,I)phth.I.t., dl-n-butyl phth.I.te.
_thyl..- chloride, copper end "Idel.
-------
f~A C.rciftOgen To h@ Poteney 'ector. .... ~'oped by the rPA rPA C.relr...-nlc 'oteney 'ector. wre VIed to
~..esSM8ftt Croup Considered fru. Re.'th rffeet. A.8e.S~t. or c~e the fndlylciJe' Incrflllente' CIIncer rlat
pot~ Feetor. evaltMtlon by the C.rclnogenlc Ass...."t ,.esultl", ,,.011 exposure to alte cont.l".,t_.
Croup. Inc'udf", benrene. bla(Z-ethylheRyl)phthelate.
..thylene chloride. tetrech'oroethene. end
trlch'oroethene.
..th,.", ,,.f.,.,. end To be 'thla praposed ru'e Cont.IM the prectlc.I "'I. ... conaldartel In .te,.lnl", de.....-
Seeonda"Y Dr I nlll", Considered ~tft.tfon 'eve' for tet,.ochloroethene. leve'. In the lOb.
V.ter IIellUl.tlOM:
Proposed Itule
54 ~. !!s. ZZ062
(May 22. 1989)
Vel'llllnt Vel'llllnt 0,.1..1.. To be AIlS helth AcM.ori.. II,.. ",Idenee AIlS 11..1 tit AcM.ori.. ..,.. conslde,.ed tIten
Crfterl., Vete" "Hltlt Cons fdered crlterl. 'or drfntl", Meter. dewlapl", eleecq» leve'. 'or ,r0undw8ter.
Advllorf.., end Advf.orl.. "
Gufd8nce
DI.cher. to
Surfece "ete,.
It.t. levu'.tory un.V.,..,..t VIIt.,. Appllcebl. un VIIt... Cluellty St""" .re II"" 'or lequl Nllenta for dl aaol wet ayfIn, t...,....t.....
lequl,.flllenta Cluel f ty St"" dl.aolved ORygeft, t~,..ture Inc,.e..e, Inc.....e, pit end tot.' CoII'o", .1" be
pit, end tot.' Coli '0l'1li. .U.lnest: Itowwr, '1.118 ere aet on . c...-
by-c..e ""1. 'or cont-lnenta 'ound In the
Old Sprl""Ieid """",t.,. ...IeII ....Id be
dlacherted to eurfec8 ...t.,., _ed on AUQC end
bl088." reIU'ta.
,,,,..1 ,,,,,., --lint To be ,,,,,., Avac: ere ""1 th-"ed crl terl. Avac: ...... ~I""" In dt8reet.,.Iat.. ......
C,.lt...I., VIIte,., Clue' I ty Consldlred ....leII hew lIMn dnoe'aptd for 95 he.lth ,.I.ta to aquatic Of'I8"f... dUe to
Advllor I.., end Crlterf. (AUQC) c.relnotenlc end nonc.rclnotenfc cont_l".,t concent,..tlons fn aurfece 8I8ter.
,Guldence cCllllpCM1dt. lee..... thle ...t... II not Uled .. . drlntf..
8I8t... eourc., the crUe,.I. II dnoe'oped for
aquatic 0f'I8"1- protection end I","tlon of
cont_f".,t aquatic ortenl... wen conslde,.ed.
AUQC .1" be used for "'I..tl", II.It. on ."
chealc.I. dllcharted to eur'ece 8I8ter.
M!'
'eder.' CAA.".tlone' Air leI event tfIeH .t""" 818,.. prl.,."y clew I aped It""" for p81'tleul.t. _U... .HI - used
levul.tory aue, fty St""" end to reau'ete Iteck end 8Ut~I'e IIIen ..a"ll.. eJlc8Y8t1on end .Iaalon
IIequlrelllMt. (NAOS)-'O CFII 'o. Approprl.te ..faelone. control. '0" aoll tre.t..nta.
Stete leguletory YTArC-Alr 'ollutlon leI event 'th... .t""" w,.. prf.,.IIy dnoelaptd Alt.matl... h'NOlyf", eRc8Y8tlon end ..Iaalon
IIequl rflllent a Control IIeguf.tlona end to ,.egulete atect end 8UtOMObI'e control a for .01' treet..nta, Inclner.tlon 8nd
-------
Federet
CrUerle.
Adv'eorln. end
Guld8nc:e
Thf'fthotd U.lt
. Vetun (flYe)
1o ..
Considered
lhese etenderdl wre 'esued .. consentU8
etend8rd8 for controU 'no elr ...1 tty In
wort plec. envlronnente.
3
flY8 nutd .. U'ted for ..efte'", .It.
-------
TAllE C-2
lOCATlOII-SPECIFIC AIAltS AIID CIITEIIA. MfISOllIEI. AND Q.lID~"CE
OlD SP.'NGFIElD lAIIDFlll SITe
'EAltllllT' STUDY ItEPORT
NED "M,AUTIIOIIITY
REClUIIa.I'
STATUS
.eClUIIEMEIT SYNOPSIS
COIISloelATlOII II 111£ II/n
At the current tiN. no potentlet 'oeetl....peclflc AltAI. heft been rcJentlfiM. Th. .It. I. not!
- A wtlend
- Vlthtn e floodp'eln
- VI thtn 100 ~er ftoodp'el"
- In e wi I.mes. ereo
- A wtldllfe refuge
. Vi thin en eree offectl", 0 net I..., ..Ud. seenle. or recreetlen ,Iwr
. A crlUn' hebltot upon "'Ich end8ngerM or threeteMd specie. depends
lovewr. ,elllediot eetl... -.y potentleU, Include ectl.lttes hwet.I", the foU_I", toeetlOft'.peclfic AltA...,
"oodDtoins
,.rol
Iteguletory
lequl relllents
'1-' end Vltdtl'.
CoorcJlneUon Act eta
U.S.C. 661)
Appt leebt.
Thle regutetlen ~Iret th.t .,.", 'eMret
Agency thet propotes to IIIOdI f, 0 body of
wter or potenUeU, effect fish end
"lIdllfe se...lces. This r...lrelllent Ie
eddres.M tnler aM Sectfon 404
requirelllents.
IICItA loeetlon
Stendardt (40 CFt
264.t8)
Appt leebt.
Thle ,,,,,,totlon autt lnet the requll'elllente
for conatruetf", e leu fecH It, en 0
'OO.yeor floodplel".
F.rel
IIon;.egutetory
Itequl relllent. to
be Consl.rM
E"ecutl.. Order
11988 'rotectlon of
'Ioodplel". (40
CFIt'. Appendl" A)
To be
C...I.rM
tnt.r thl. ,...,tetlen. F"ret 89t!Mles
er. requirM to ...Id 8d¥er.e effects.
.Inl.II' potentlel ho"., rntore end
preserve the neturel end beneflc:fet
..I.. of ftoocfph.lnI.
Durl", the ldentlflt8tlon. eereenl"" end
...tuetlon of etternetlwe. the effect. on
etre_"" veU"'. er. ...tuetM. If an
.It.matl.. lIIOdiflee . body of wte, or
pot~tlelt, offect. fl.h or "Itdllf., e'A 8Ult
conault the U.S. Fleh end VlIdllfe St!l'Ylce.
A 'eelt It? toe.ted en 8 'OO.yet, ftoocfptol"
_t be "I"", centtruetM. eperotM, ...
.Int.lned to prevent wahout or .,.", h.l.rdouI
....t. by e 'OO-yetr ftood. untes. ....te -.y be
f'eI8Oftd ..fet, before ftoodM8ter can reeeh the
fee'tlt, or no 8d¥ers. effecte on ........ heetth
end the erw'rorlll!ftt woutd resut t If tl8Shout
occurred.
.....I.t 8tternetl".. tlt8t hwot..
conatruetlon In ftoocfpl.ln .ree. "'t 'nctude
eU prectlcebl. -8M .f .Inl."1", he"..
"oocfpleln protectfen conal.,.UonI ~t be
'ncorporetM Into the pleml", end d!clslon-
-------
TAllE e.!
POf!WTIAl ACtIOM.SPfCI,te AtAtS
OlD ~t'G'tElD lAID,tll Slt£
'!ASIIlllt' StUDT t(POIt
AClIOI(S)
AWAR.
Federa'
An
os... - ......a' tniMtry
Stend8rds (Z9 tFt "'0)
An
OSM - utety end ""' th
St"'" (29 CFI "Z6)
An
""eurc. e8NH¥8Uen end
tec......', Act (tCIIA), ICItA
SUbtltte C, 40 CFt 260
An
OSIIA - lecerdkMP''',
leporll.., end let at'"
"...'.tl- (29 c'" ,.)
UStPA .....,...tw
'rotecllen Itr.t.., -
USEPA Po'ley St.t..m.
AuguIl 1"'
An
An
ICU - It"'" for
0Nner8 Oper.t.,... of
,....t tied 'ale"'" ....t.
'eel'ltl.. (40 CFt
264.10-Z64.8)
AU
ICU - "'.''''1 end
'rewntlan (40 C'I
264.30.264.31)
An
ICIIA - Cant Ingeney " 1ft
end E_rweneY Proc-.r..
(40 CFt 264.50-264.56)
A"
tCIIA - GroundYater
Protectlan (40 CFt
264_90.Z64.109)
StAtUS
App'Icab'.
App'lcab"
App'lcab'.
App'Icab'.
To be e_l..-...
I.'ewnt ...
Appropriate
".'ewnt ...
Approprlat.
"e'ewnt end
Approprl.te
t.tewnt end
Approprl.te
"EOUIIEMEI1 "MOPSIS
Thne r...tetlant epeelf, t... 8.hr. tt....1""'" IIWr... CIfte_retlen for wrlCIUI
orgenlc c~. tralnl", requl,......t. for tIortera .t "alardaut ...t. oper.tloN
.re lpee"led In 29 CF' ",0.1Z0.
T"I. ......1.Uen ~IfI.. the type of "'t" equlplfftt end ,.......... to ..
fot towel .....1.. lit. rtllldletfan.
'IICIIA ......'et.. the "",,'11.... Ir....,.t. It....... ,....tIIfnt. ... dl......' of
hal""" ....te. CUCLA epec:lflca", requl.... (In lectlan 104(cJ(JUln that
hal""" I""tane.. fNIIII 1''''''''' eell- be dlapolled of et fee" Itl.. In
c~tlene. with Subtlt'. C of leRA.
"'I. """etlan out'lnee t"e reclf'dt..1", - .....tl", requl~. for 1ft
~toyer under OSIA. .
ldentln.. .....,....t8f' .-' 111 t. III Idtlewd "'1", ,.....I.t eetl- ...... en the
aquifer eIIareeterl.tlcl and Ull.
Cenlr8t fee"Ity requlr.-nt. out"" ......, ..t. _,,,I., MCUrUy.........,
In8peetl~. end trel"I", requlre8ent..
"'II """.tlen outtlnee requlr88't1 for ..'ety equl.-nt end ",,,, ~rot.
"'I. .....,.tlen out'lnee the nqulr.-nt. for ~r...IC' pr~ to ... wed
fOUOMI", e.p'081_, fire., etc.
T"II reguletlan .ten. requlr88't. for a ,roundwet.r .,.,Itorl", progr811 to be
Instetted at the .It..
-------
An
Cepplng-
V8ste In
" ece
CI"" Closur.
(lIeIIIOV81)
Closur. ..Ith
Vaste In-
'Iece (Iybrld
Closure)
GroundMater
end Surf8ce
V8ter
MonUorlng
IlCIIA . CIOIUN ... PoIt-
Clos~ (40 C'II Z64."O-
264. '20)
IlCIIA - lend.IIII (4' C'II
264.]'OCa»
IlCIIA - lend.IIII (40 C,.
264.]'0(a»
IlCIIA - een.r.I It"''''
(40 CFII 264."7Cc»
!'A 'echnlc.I ...Id8nee
DocUll!nt: Flnel C0wer8
on lalardoul Vaste
lend."II end Sur'ace
I~tl U'A-SJO-
SV-89-CJ41)
IICII" - c.Mr81 It"""
(40 CFII 264.11')
IlCII" - "enlf..t I""
lIecordkMPI", end
lIeportint
'reposed lIul. '2 '11 8712
(not enected)
RCII" . "enlf..tl""
lIecordkeeplng end
lIeportlng (40 CFII 264.10-
264.77)
IlCIIA - Cromdwete,.
'rotectlon (40 CFII
264.91)
lIeinent end
Appropriate
lIelevent end
Appropriate
lIelewnt end
Appropriate
lIelevent end
Appropriate
'0 be ConII.,.1d
lIelevent end
Appropriate
AfJPllcable
'0 be Cons I.,....
Appllcabl.
'or c,.aundU8ter:
lIelevant end
Appropriate 'or
Sur'eee Vater:
'0 be consl.,.ed
'hi. retUI.tlon detalll lpeel.lc ,.equl~tl 'or closure end post-closure 0'
hallrdoul ....te f~IIItle..
"aclllll!nt 0' . ellp ~r ""te ,.equl,... . cowe,. ~IgMd end construeted to:
. 'rovlde lont-t8"'" ",'"I.trltlon 0' .I,,,.tlon of liquIds through the capped .re8;
. 'unction ..It~ -'"'.uN ...Intenenee:
. 'rOIIOte dr.lnege and .Inl.tre erosion .... ""Ion 0' the cove,.:
. AccOlllllOdllt8 lettllng end IWsld!nce .0 th.t the cover'l Int..,.Ity II ...Int.lned:
. 11_' perMI.,It Ity le.s then or ~I to t". pe~8bH Ity of any bottCIIII liner
I"tell! or Ntur,1 'WsoH. pr..ent.
'rftWlt run-on end run-o'f frCIIII "",1", eewe,..
lI..t,.Ict post-clOt..... use of preperty .. fttC..,.ry t. prewnt cI8II8ge t. the cover.
..
Thl, dDcuIIent IMludn !'A technlcl' .,lcIIne. ..... I""" I coverl end "...ent.
,.ec..AIII",,1ded technlc.I lpeelflc8t1one f.... ..uneyer land'" I cover deal,,"-
Cenef'.1 per'~ It...rd requl,... .I"I.tntion 0' Ned ..... 'urther _lnteIWtCe
end control: .Inl.llatlon or e"",lnetion of post-closure eecape of h.lerdout ....te,
h81ardoul constltuentl, leach.te, cont_INteel rut-off, .... It81.rdouI ,,"te
dec~ltlon ",,-.ctl. Allo ,.equl,... d18pol.1 .... decont.lnetlon of equlplllent,
Itruetur.., end 10"1.
Thll .......tlon lpeel".. the ..........,1", ... ,...tl", requll'8llfttl f.... IlCIIA
'acnltl...
lIequl,... ..-vel of -Jorlty 0' cant"Nt" _terl.II. All. ....1,... eppllcltlon
of cover end post-closure .....ltorl", ...eeI on ellposure pIItlnl8yCl) of concem.
Thl, retUI.tlon lpeelfl.. the recordkeepl", end repot'tl'" requll'tWl!fttl' for IlCII"
'ac" I tI...
-------
Construct I an
end Op@'IUan
of OMI te
lendf I I I
COMtructian
end Op@reUan
of OMlte
lnelneretor
Offllt.
Ol8POlei of
Solid Ve.tes
RelA . lendf"'1 (40 CF'
264, ""'rt I)
RelA lend 'an (40 CrR
268, StiJpe,t D)
lei""" end 10' fet ,,"te
Alhetd......tl of 19M (19M
'wenchel.tl to IeIIA) Pl
98-616, Federll l811
71:3101
telA. lne......tore (40
CFR ZI4, SUbpart 0)
RelA . (40 CF' 7&'.70)
CI.-n A'r Act (CAA) .
let'anel A'r Gulllt,
St8nd8rdt (lAOS) (440 CrR
, to 99)
Interf. RCItAICnClA
CUldlnee an Ian-
Cantl..... Sltel end
OMit. "M"lulent .f
v..t. end Trelted t...dUe
(USEPA pol'cy Stlte8ent
"erch 27, 1986)
It""" _I 'cab'. to
Trensport.re of 1111rdau8
v..t. . Rei" Sect Ian
300], 40 CFR 262 end 263,
40 eFR 170 to 179
Relevant end
Approprlete
A""IIclbi.
'elevent end
Appropr'ete
tel~ end
Appropr'lte
tel~ end
"pproprllt.
televant end
"pproprllt.
To be COM.cIered
"""I 'clbl.
.
. .
...,.,I.tel the "',", construction, ..,.,..tlon end clo...r. of I hel"'" ...t.
lendflt I.
After 1118188, plecMent on or 'n lend outll. un't boundery or -- of
cont.lnatlon "It I trlner lend dltposel r..,lrMent. .... rntr'ct'-. A'eo
requires treltllent by lest I)....,."trlted Aftltlble Technol"" (lOAf) before
p18Cellent.
Specific ....t.. .,.e prahlblted ,.... lend "......1 UI'IdPr the 19M ItCIA """"'''1.
'hll 'ncludes I ban on the plec~t of ....tM cantllnl", f," II.'.. AIIO,
lolwnt-contl'n'", 118stel Ire prohlb'ted f,.. lend dllposel. effectlft I."."",
1986. EPA'I .1.0 required to let trelt8eM leftll or -.thodl. ell"",'", truted
hlrerctaus ..tel frCIII the lend "ltpMII ban. 'o.te. these t...~ It""'"
h8Ye not been prGIIUI.eted. 'h. RelA -e..ctI..'htl "Itt .180 r..t,'ct the lendftlll".
of -.,.t IeIIA.lllted 118.tel by 1991 unl... t,.et8llnt It"'" I,.. IpKlfled.
..
I. It.. the ...'". CClMtructlon, ....retfon end clotUN o. h.I"'" ..te
lne'nerltorl.
lIltl epee'" ,...f.-nee It""'" 'or 'fte'MrI"~ of PClI.
"""tI.. t. -,or ItIU""" l0ure88 ..... .. t...~ un'tl thlt heft . pot......1
to -It 1',"'Ucent 8IOUI'Iti of pollutantl euch II lOx, ~. to. '-, ..-cur, end
perUcut.tel (eore than 250 tOM/yeer). ...,.,IIU_"', CAA . not IpIICIf'cltt,
,..,.,I.te _1...- ,,.. hel."" ....tl fne'neretora, but ft '1 I f,.I, ttlet
prewntlon ., "gn'Ucant Deterlorat'on (PSO) prOVfl'OM IIOU'" -" t. .. _fte
treet8ent 'ec"fty.
If I trHt8ent or Itor... unft fl to be CClMtructed for _ftl ,...,... edfon,
the,.. lhoul" ... I ctelr Intent to "I.....tte. NIIIMt, or clote the unit .'ter the
alCtA ectlon '1 ~Ieted. Should there ... pi... to eccept CCIIIIIIrC..1 ..te It
the feclt't, .ft.,. the alcu ..tl h.. ..... proc:...ed. It '1 EPA potley thlt I
leu pe,,'t ... abt.lned before the unit .. COMtructed.
r.tIM ..hII the relpanI.btl.ty of offl'te t,..,..t.rl of hel"'" ..t. fn the
hand""., t,_portetlon. and NI...ultnt of the ....18. lequlrel I 8ft1f..t,
recordkeepl"., end 1.....18te ecUon 'n the ewnt of . dl.cher.. of herlrd0u8 ..te.
-------
Onelte v.ter
'reltllleftt end
DI.ch.rge
r'A.Ad81"Iltered 'e~It
'rogr.. The "'llrd0u8
v..te 'e~It 'rogr.IClA
Section SOOS, 40 CFI 270,
124
rPA Interl. '01 Icy for
PI.....I", ..... I..,Ie8ffttl",
alelA l"paMe Actlena.
'reposed lule, 50 FI
45933 CICM!IIIJer 5, 19M)
..!tonel Pollution
DI.ch.rge Et 1.lnetion
lratelll CIIPOES) C" CFI
122)
lei event ...
Aevoprlltl
To be Canel"'ed
lelewnt ...
Approprl.te
CG'W'eN the lInic pe~'ttl"" "",IICltlon, IItIInUerl"l ..... repH'tI", requirelllefttl for
.ff.ltl h.llrdau8 ....t. __,UK"t fldlltlel.
Dl8tUl1" the need to cansl.r trelt...,t, reeyell~I, ..... reutl before offllte I'"
411'1'"11 II Uled. 'rohlblt. UI8 of 8 leltA feel"" for off.UI --tetll(nt of
Superfund h811rdou1 .ubstencet If It ~II II,"Iflc'~t ICIA vlolltlans.
...Iltet thl dl.ch..... of ..ter I"te .-.IIc eurfee. ..tera. AIIIanI other thlntl,
..Jor requlre8fftt. .re:
. "'. of best 8V8Ullble technol.., CIAT) ee...le.lly 8ehl8¥8l»I. II required to
eontrol tOllic end l'IOnComrentionei pollutantl. Ute of best eomrentlonel
pollutn control teehnology CICT) II r..lred to eontrol earwentlonel OIl
pollutentl. 'ee_Iogy-beled II.ltations .., be .t~Ined on I cne-by-en.
bull.
. "'Ilellti. ,....,t ty -.4*CMd It'tl .tet' -' flY It""'" _t be e...,1 led
..'th. Th"e Itlnderds .., be I" addltfon to It .... Itrlngent then other'
Federel atend8rd1 ~r the aM.
. The dl8eh.rge IIUIt conf~ to _IIe.II --ter ..IllY requl,.."tl ...... the
dl.ch.rge Iffectl I Itlt. other then the cer\Ifyl", Itlt..
. The dleehl'" IIIIIt be conelltent .Itll the requirelllefttl of 8 V8ter ...IIIY
".._g~.~.,t "en ~owd ." EPA.
. IfIChlrge II.lt.Uena -t be ..tllttlthed for III tOllIe po"utnl thlt I,. or
.., be dllehlrged It levell '"'ter then thlt ...Ich een be eehleved ."
technology-lined It"re.
. Dllch.,... IIIIIt be IItIInltored to lllUI'I ~"tnet. Dlee""'" "", ...Itor.
. 'h. .11 of eeeh pollutent.
. The vol- of .fftuent.
. 'r~y of dllehlr.. ... other ...........tl II eppreprl.to.
. AJlprowd telt _thods for "It. constltuentl to be IItIInltored _t be loll"".
Detllted requirelllefttl 'or _IyticII procecb'et ... ..lilY eontroll ".
provided.
. 'e~1t "",IIeltion I"'or.-tlon _t be ""Itted, Inctudl", 8 "erlptl. of
ICU.ltlel, "IU", o. envll'«Wentlt pe~Itl, etc. Oneltl dltchl"'" ,to aur'eee
IIItera ere ell..t frGIII procecb'II IIPDES ~It requlre8ffttl. (Sect I. 1Z1 of
SAltA ellMPt. anslte CEIClA eetl.ltl" fr. thtll"I", pe~ItI. IICNe'I'ef', the
aubstenUw requlre8fftta of the pe~It _t be _t.) O"IItl dllch"... *"'td
be required to "",Iy for ..... tht.I" en IIPHS pe~It.
. Monitor"'" report r..ultl II requlr. ." ,.,.It C.I"'- 0' .t Iellt ""'''yJ.
. C~ly ..Ith addltlonel ~It condltlena lueh ..:
. Duty to .Itl,lte any 8dYera. ef'eetl o. any dlaehl''': and
-------
Off.lte
DI.cherge to
POT"
tJlC8fttt an
en
Co II ec tt on
'ropos8d It""'" fOf'
Control of r-I..lone 0'
Yo'etn. OrIenic. . 52 ,.
3748 (,ebru8ry 5, 1987)
Toxic '0' tutent Effluent
Stend8rd8 (40 C'. 129)
'I.h end "I'dtlf.
CoontlneUan Act l'
USC66' eta 'eel.
C'.en Veter Act (M) (40
CF. 40])
IICItA . Ctntt'.t It"'"
(40 C,. 264.7' end
264.n)
eM . IAGA 'Of' Tote'
Ius"""" 'ertlcu'et..
(40 C,. '29.1", 750)
lend 18ft (40 CF' 268 .
WlpertD)
'ropoe8d St....rd . 52 ,.
3748 (2/5/87)
'0 be CClMlder8d
.e'event end
Approprl.te
Apptf cebt.
Appt Icebt.
..tewnt end
Approprl.t.
.etewnt end
AfJproprlete
Appt Icebt.
To be Conelder8d
'r..crltM8 proposed .tend8'" for ¥OC _I..Ione 'r- unit. 8Udt .. .Ir .trlpper..
It...,'et.. the dlscherge of the '0".1", fIOnutent.: e'df'h"dletdrl", DO', -..In,
tOJlept!ene, ",",I I dine, end PClI.
'hi. ect r~Iree thet before underte'I'" .., '.r.t ectlan th.t e8UI.. the
MdUIcetion of 8nY' body of nter 01' effect. "'" end ..Ud"fe, the followl",
8Ift1CI" _t bit consuUed: the 8PPf'11P"1et. SteU egtncy ellercl.I", Jurl.dlcUon
Oftr "Ud" fe .esources em the ".1. ".h ... "lid" fe Service.
Th... r...,I.t I.. controt the dltcher.. .f cant..lneted nter to POTU. ,he....
r...,'etlone -" reterd'''' of _.ther r.-dle' ectton dlsch.r... Into the .ewr
of tMICke n.te to POTU. ~olnt.f r.f.rence I. entry of fIO"utent. Into trnt..nt
.~t- e. the POTU. SGN of tile .Jot' .....If'elll!nt. of thne rewu'etlone ere:
. 'ollutent. thet pelS threuth the POTU ..Uhout treehlent, Interfe... "Uh POTU ..
Clp@retlan, Of' cant..I".t. I'OTV .t..... .,.. prahlbl ted.
. Specl"e prahlbltiCIM preclude t~ dl.cherge 0' pollutent. t. ""'" th.t!
. Creet. e Ur. Of' eJlpl..lon hel'''' In the POTU:
. Are co""1,,. (plieS.O):
. Are dl.cherged et . f'~ r.te end/or coneentr.tlan thet .Itt ,~t In
Interference:
. lner.... the t.....,.et18'8 of ....t....ter enterl", the tree'-"t ptent th.t IlllUld
result In Interferenc., hut I" .. e..e ~I.e the POTU Inf'uent t...,er.turt
.... 104 degren , (40 ..,..... CJ. .
. If. tnchete collection eyet.. I. lnet...8d end the dltche.... II lent to 8
POTU, the POTU _t h8¥l 8ft ....-ov8d pretreet..nt progr... The co"ected
Inchete Mn)ff _t bit In ~"ence "lth the ~ crved progr_. 'rlOf' to
dl.cher,I"" 8 report _t be .--Itt8d cantelnl", ldentlf"", Inf0fW8tlon, t I.t
of ....-0\Ied penllt., tlncrlptl.. of oper8tlone, now ...."..-nt., lIIMSur.."t
of pollutent., certlflee,I.. br 8 .."ffed prof...I...t, end . c~tl8r'1C8
.chedu'..
KltA pet"8ft.br.rut. requl..-.tl _t be ~tf8d ,,8th 'Of' dlsch.,... of KltA
h.lerdau8 ....t.. to POT'" br truct, nn, Of' dedlceted pi...
Thl. ,..,tetl.. epee"I" ..1- prl.ry end .ft...., 24.hr. eencentntfON fOf'
perUcul.t. .tter. ,,,,Ittp at _le.I.. frCIIII .n. eJlc8¥8tfon ectlvltl.. ."t
be .Int.'ned below 260 ",.. (prl.ry .t""rd).
After IIoftIItJer 8, 1988, ...t-nt of ..C8W8ttd .t.rl... te .... toe.U.. end
p'ec.."t In Of' .. ,end "I" trl...,. ,end dl.poe.' '"trlctlone.
ldentl".. ",opMed .tend8rd8 for controt of we _I..Ione.
-------
APPENDIX D
LETrB. 07 CONCURRENCE
7ROK STA'1'E OP VERHON'l'
-------
t
.~4 State of Verm~nt
~" ":.~
...:,~ ">r00.
.!ta~Yi££.
I~ft""""" .., r il" "n~' "II,Ir";I..
rl5:U8'1:f'\r.II. o. rU'I"'~'. ~nl'" "",. nto,,,,,,","i..,,
c.,.,,"'''''''' nt t. ,~'rn"" ..h'~1 1":u....or-'""i,,,.
lOt,..., (.'~I",iS\
"-,,,,u.a. n..c,Mlrcl~" r.:1,,'sr.,~..t'C\" t:u.."...1
ACiENC\' OF NATURAL RESOURCES
103 South MIIln Street
,",,'aterbury, Vermont 05676
..
Department or EnvironmeDtal ConNrv.dun
. Mr. Merrill Hohman
O.S. Environmental Protection Agency
Region I
Waste Management Division
. J.P. Kennedy Federal BUilding
BOlton, MA 02203
Sept~mbar 27, 1990
Dear Mr. Hohman:
I am writing to advise you of Vermont's concurrence with the
proposea source control reDledy for Old Springfield Landfill as
detailed in the draft Record ot Decision.
Through the Focused Feasi~ility Study effort the state and EPA
have been able to qain a JDore thorough understanding of .i te
conditions. The remedy as proposed reflects this understandinq and
presents a solution that is at once flexible and protective of
public health and the environment.
We appreciate the cooperative effort that we have experienced with
EPA in reaching this agreement, and look forward to working with
you and your staff in future Superfund efforts.
.~el~ :f1L
inald A. LaRosa, Acting Commissioner,
rmont Department of Environmental Conservation
RAL:dc
rod2 concur
-------
APPENDIX E
RESPONSIVENESS StJMHARy
-------
TABLE OF CONTENTS
Preface. . . . . . . . . . . . . . . . . . . . .
. . . . . .
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN . . . . . . . . . .
I:::'
r;ITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT
AND CONCERNS. .
,
. . . . . .
. . .
. . . . .
. . . . . .
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. . . . . . .
A.
Summar v of Resident and citizen Comments. . . . .
1. 1990 Comments. . . . . . . . . . . . . . . .
2. 1988 Comments (Deferred from 1988 ROD) . . . .
B.
Summary of Potential Iv Responsible Parties'
Comments. . . . . . . . . . . . . . . . . . . . .
1. 1990 Comments. . . . . . . . . . . . . . . .
2. 1988 Comments (Deferred from 1988 ROD) . . . .
C.
Summary of State of Vermont Comments. . . . . . .
1. 1990 Comments. . . . . . . . . . . . . . . .
2. 1988 Comments (Deferred from 1988 ROD) . . . .
IV.
REMAINING CONCERNS. . . . . . . . . . . . . . .
. . . .
ATTACHMENT A -
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
AT THE OLD SPRINGFIELD LANDFILL SUPERFUND
SITE IN SPRINGFIELD, VERMONT
DETAILED SUMMARY OF POTENTIALLY
RESPONSIBLE PARTY COMMENTS
ATTACHMENT B -
ATTACHMENT C -
TRANSCRIPT OF THE AUGUST 2, 1990 INFORMAL
PUBLIC HEARING
ATTACHMENT D -
EPA RESPONSE TO CONTAMINANT DESORPTION
MODEL
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OLD SPRINGFIELD LANDFILL RESPONSIVENESS SUMMARY
Preface
The u.s. Environmental Protection Agency (EPA) held a 60 day
public comment period from July 13, 1990 to September 10, 1990 to
provide an opportunity for interested parties to comment on the
Remedial Investigation (RI) reports, 1988 Feasibility Study (FS),
1990 Supplemental Feasibility Study (SFS), 1990 Detailed
Evaluation Memorandum (Detailed Evaluation Memo), 1990 draft
Focused Feasibility Study (FFS) reports, and the 1990 Proposed
Pl~u !v~ ~~Cv~d operable unit at th~ Old Springfield Landfill
Superfund site (the site) in Springfield, Vermont. The second
operable unit or source control portion of the site cleanup
addresses controlling the sources of contamination at the site
that present a hazard or contribute to the spread of
contamination- EPA made a preliminary recommendation of its
preferred alternative for source control in the Proposed Plan
issued on July 6, 1990, before the start of the public comment
period. Remediation for the first operable unit, addressing
contaminated water flowing from the site, was addressed in the
first Record of Decision for the site signed in September 1988
(the 1988 ROD).
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised durinq the 1990
public comment period as well as any comments pertaining to
source control from the 1988 ROD comment period. EPA considered
all of the comments summarized in this document before selecting
a final remedial alternative to address the source of
contamination at the site.
This Responsiveness Summary is organized into the following
sections:
I.
Overview of Remedial Alternatives Considered in the
Feasibility Studies and ProDosed Plan - This section
briefly outlines the remedial alternatives evaluated in
the FS, FFS, SFS and Proposed Plan, including EPA's
preliminary recommendation of a preferred alternative.
II.
site Historv
and Concerns
history, and
and concerns
and Backaround on Community Involvement
- This section provides a brief site
a general overview of community interests
regarding the site.
III. Summary of Comments Received Durina the Public Comment
Period and EPA ResDonses to These Comments - This
section summarizes and provides EPA's responses to the
comments received from residents, other interested
parties and Potentially Responsible Parties (PRPs) on
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both the sou~ce cont~ol action that was part of the
1988 Proposed Plari and this June 1990 Proposed Plan.
IV.
Rem~inina Concerns - This section summarizes comments
raised during the public comment period that cannot be
fully addressed at this stage of the Superfund process
and which thus will need to be evaluated during the
design and implementation of EPA's selected remedy for
the site. EPA provides responses to these comments and
will further address these concerns during the remedial
design and Remedial Action (RDjRA) phase of the
cleanup.
Attachment A - This attachment provides a list of community
relations activities that EPA has conducted to date at the site.
Attachment B - This section contains a detailed summary of
Potentially Responsible Parties' comments.
Attachment C - This attachment provides a transcript of the
August 2, 1990 informal hearing on the site, held in springfield,
Vermont.
Attach~ent D - This attachment contains EPA's comments on the
contaminant desorption model.
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDIES AND PROPOSED PLAN
Using information gathered during the RI (an investigation of the
nature and extent of contamination at the site), and the
Endangerment Assessment (EA) (an assessment of the potential
risks to human health and the environment associated with the
site contamination), EPA identified several cleanup objectives
for the site. The primary cleanup objective is to reduce the
risks to public health and the environment posed by exposure to
the site source areas or to contamination that has migrated, or
may potentially migrate, off the site.
After identifying the cleanup objectives, EPA evaluated potential
cleanup alternatives, called remedial alternatives. The FS, FFS
and SFS reports and the Detailed Evaluation Memo describe the
remedial alternatives considered for addressing contaminated
soil, groundwater and leachate, as well as the criteria EPA used
to narrow the list to eleven potential source control remedial
alternatives.
As indicated in the Proposed Plan, EPA's preliminary
recommendation of a source control preferred alternative involved
the following: capping identified waste areas, installing french
drains, gas collection and venting systems, source control
extraction wells, and stabilizing the waste area side slopes.
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REMEDIAL ALTERNATIVES EVALUATED IN THE FS, PI'S AND SFS
.
The eleven source control remedial alternatives considered
are listed below. The July 1990 Proposed Plan should be
consulted for a detailed explanation of these remedial
alternatives as well as EPA's preferred alternative.
by EPA
Alternative 1:
ALTERNATIVES TO ADDRESS SOURCE CONTROL
No Action
Alternative 2:
(Preferred
Alternative)
Alternative 3:
Alternative 4:
Alternative 5:
Alternative 6:
Alternative 7:
Alternative 8:
Alternative 9:
Alternative 10:
Alternative 11:
Capping, French Drains, Gas Collection and
Venting, Source Control Extraction Wells and
Side Slope Stabilization.
On-site Landfill of contaminated Solids
On-Site Incineration
In-Situ Vitrification
Fencing and Covering of Contaminated Soils
Fencing, Installation of a Source Control Well
and covering of contaminated Soils
Fencing, Installation of a Source Control Well,
Vapor Extraction from Waste Area 3, and Covering
of contaminated Areas outside Waste Area 3
Fencing, Installation of a Source Control Well,
Capping of Waste Area 3, and Covering of
contaminated Soil Areas Outside Waste Area 3
Fencing, Installation of a Source Control Well,
capping of Waste Areas 3 and 4, and Covering of
Contaminated Soil Outside of Waste Areas 3 and 4
Fencing, Installation
Capping of Waste Area
Wall, and Covering of
of Waste Area 3
of a Source Control Well,
3 with a Perimeter Slurry
contaminated Soil outside
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II.
I .
SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT"AND
CONCERNS
The Old Springfield Landfill site is located in springfield,
Windsor County, Vermont, approximately one mile southeast of the
commercial and residential center of the town. The site is a 27-
acre parcel of land on the former Old Will Dean Farm property.
The site study area is approximately bounded by will Dean Road to
the west, a housing development to the north, Route 11 to the
east, and residential property to the south.
From 1947 through 1968, the Town of Springfield operated a
landfill at the site that accepted both municipal and industrial
wastes. Industrial wastes are believed to have been disposed of
on approximately eight acres at the site and included oil,
solvents, and other industrial wastes.
In 1970, an area resident noticed an odor in his well water and
notified the Vermont Department of Environmental Conservation.
Complaints by other nearby residents prompted the state to begin
area drinking water studies. In 1982, EPA added the site to the
Superfund National Priorities List, making it eligible to receive
Federal funds for investigation and cleanup.
In 1985, EPA began the field investigations of the Old
Springfield Landfill site. An initial Remedial Investigation
(RI) report was prepared for EPA in 1985. Further investigations
were necessary in order to answer questions raised by the initial
study. These investigations resulted in the development, in
1988, of a supplemental RI, EA, and an FS.
Results of site investigations have identified that the soils in
Waste Areas 2, 3 and 4 are contaminated with volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs),
metals, polycyclic aromatic hydrocarbons (PAHs), and
polychlorinated biphenyls (PCBs). The groundwater is
contaminated primarily with VOCs.
The EA identified exposure pathways through which the public
could potentially be exposed to the contaminants of concern at
the Old Springfield Landfill site. CUrrent exposure pathways
include inhaling VOCs released to the air from leachate seeps or
landfill gas emissions and direct contact with contaminated soil.
If the site contamination is left untreated, there could be
potential future adverse human health effects from long-term
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.
exposure to site contaminants.
contaminants include:
Potential future risks from site
o
o
ingestion of contaminated groundwater,
long term exposure to PCB and PAH contamination in the
soil from handling or ingestion of the soil, and
inhalation of contaminants in landfill gas.
o
EPA issued the first proposed cleanup plan for public comment in
July 1988. Based upon comments received from the public and the
state of Vermont, EPA revised the preferred alternative and
separated the cleanup into two operable units. The Record of
Decision (ROD) for the first operaHle unit, signed by EPA in
September 1988, addresses the migration of contamination from the
site. The remedy selected in the 1988 involves collection and
treatment of contaminated leachate. The remedial design for this
remedy is currently being completed by four of the Potentially
Responsible Parties (PRPs) with EPA's oversight.
The september 1988 ROD also required an FFS be conducted to
collect additional data related to the second operable unit, or
source control portion, of the remedy. Source control studies
were necessary to better define the extent of deep groundwater
contamination, the feasibility of isolating the waste from
surface and groundwater, and the nature of sub-surface water
flow. The draft FFS Report was submitted to EPA in April, 1990
and a revised draft was submitted in June 1990.
Prior to 1989 much of the public concern regarding the site
centered on the citizens living in the mobile home park. The
mobile home park residents were concerned about potential health
threats and being forced to move out of their homes. These
concerns ended by 1990 when the last of mobile home park
residents moved from the site. citizens continue to be concerned
about the possible adverse economic effect that the site could
have on the town. Concerns range from the potential for raising
town taxes, due to the town's involvement with the site, to
property value decreases for residences in close proximity to the
site. citizens have also expressed some doubt about the actual
health risks from exposure to the contaminants at the site.
People want EPA to clarify what the risks are and how and when
people are at risk. People are also concerned about the present
and future site aesthetics. They feel EPA should give some
consideration to the visual impacts of the s~te activities on
nearby residences.
A complete list of community relations activities conducted at
the site is included in Attachment A at the end of this document.
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.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments received
during the public comment period held from July 13, 1990 to
September 10, 1990 and also those comments deferred from the
first ROD comment period ("1988 comments"). EPA deferred
responding to 1988 ROD comments that pertained to the source
control portion of the remedy until the comment period for the
second ROD.
The comments are categorized into fhree sections: Resident and
Citizen, PRP, and State. Each of these sections contains
separate subsections for comments received during the public
comment period for the current ROD ("1990 comments") and deferred
comments from the 1988 ROD ("1988 comments"). All of these
comments are summarized below. A detailed summary of PRP 1990
comments is included as Attachment B. A copy of the transcript
from the August, 1990 informal public hearing is included as
Attachment C of this document and is available in the
Administrative Record located at the site information
repositories at the Springfield Public Library, Main Street,
Springfield, Vermont and at the EPA Records Center, 90 Canal
Street, Boston, Massachusetts. A detailed summary of the PRP's
1988 comments and the transcript from the 1988 informal public
hearing are also available in the Administrative Record.
A.
Summary of Resident and Citizen Comments
Comments from residents and concerned citizens are summarized
below. The comments are organized into the following categories:
l.
2.
1990 Comments
1988 Comments (Deferred from 1988 ROD)
1.
1990 Comments.
a.
Comment: One person wanted to know if something would be
done with the town water line that runs through the site.
EPA Response:
EPA believes that the Town of Springfield is planning to
install a new section of water line which would allow for
the disconnection of the line running through the Old
Springfield Landfill. EPA would not require action
regarding the water line unless such action was necessary as
part of the remedial action. A further evaluation of the
water line will be made during remedial design.
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.
b.
Comment: One person asked if REMCOR was going to relocate
the existing command post and decontamination facility.
EPA Response:
EPA will do what it can to ensure that the command post and
decontamination facilities are relocated, but the citizen
must understand that EPA's Superfund authority only extends
to actions which directly relate to protecting human health
and the environment from a release or threats of a release
of hazardous substances. If the site owner requires the
loca~ion of equipment and fac~lities in a certain location
as part of the access agreement and that location does not
affect the remedial action or create a threat to human
health or the environment, then EPA cannot prohibit or
relocate such facilities.
c.
Comment: One person requested information about the
enforcement of the Town of Springfield Article 88-2. It
appears that the article is not being enforced and,
therefore, there is a potential for people to be digging on
the site. This individual also wanted to know if digging in
Waste Area 1 would be safe, since this area has been
referred to as a low hazard area.
EPA Response:
The first ROD called for the implementation of institutional
controls and referenced Article 88-2 in particular. At the
informational meeting on July 12, 1990, the Town indicated
that Article 88-2 was not in effect. EPA intends to ensure
that institutional controls are implemented.
Waste Area 1 does not contain sufficient hazardous
substances to represent a threat to human health. However,
EPA suggests that samples be taken if any excavation is to
occur to ensure that unidentified contamination is not
present.
Based upon the current delineation of the site resulting
from the sampling and analysis of the completed studies, the
area outside the waste management unit and which is not
required for use during implementation of the selected
remedy will not be restricted from use after the
construction of the remedy. Any excavation of the area
within the boundary of the 27 acre study area (with the
exception of the waste management unit), should include
sampling for s~te related contamination and should proceed
with caution. The restrictions on groundwater use
established by the first operable unit will remain in place
until groundwater cleanup levels in section X.A are
achieved.
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d.
Comment:. One person asked if the state had approved the use
of the Town's sewage treatment plant for treating leachate
from the site.
EPA Response:
The state of Vermont is currently reviewing the application
for discharge to the POTW submitted by the PRPs. This
application was filed as part of the activities required
~uder the first operable unit~
e.
Comment: A Town Representative expressed concern for the
town's financial condition and made suggestions for reducing
the costs of the preferred alternative. The representative
also stated that he supported the incorporation of the
option to the Preferred Alternative (excavation of waste
from Waste Area 2 and placing it under the Waste Area 3
cap), since it would reduce the engineering costs by
$700,000. The representative also suggested that the use
of qualified volunteer workers at the site be considered as
another means of lowering the cost of construction.
EPA Response:
f.
The selected remedy allows for the consideration and
possible implementation of the excavation option as more
information is evaluated during design. The use of
qualified volunteers would be a decision for the company
performing the work. EPA cannot assume the use of
volunteers in a cost estimate. Typically, only individuals
who have passed the applicable OSHA health and safety
training will be allowed to work on a Superfund site.
Comment: One citizen suggested that the in-situ
vitrification alternative be modified to include power
generated from the Black River. The commenter stated that
this modified remedial alternative could be completed for
the same cost as the preferred alternative and would prevent
potential future needs for remediation.
EPA Response:
In-situ vitrification was evaluated in the 1988 FS as a
potential technology for the site. EPA relied upon already
existing power supplies for its cost evaluation. EPA did
not select in-situ vitrification for the source control
remedy because EPA determined that the selected remedy
represents the best balance of the nine selection criteria.
Among these, the short-term risks and potential
implementability problems associated wIth the in-situ
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vitrification alte~native were greater than those associated
with the selected remedy. EPA agrees that permanent
remedies should be considered to the extent practicable and
EPA has a preference for treatment. section XI of the ROD
provides more detail relating to the rationale for selecting
the remedy.
g.
Comment: One citizen commented that the cost of EPA's
preferred alternative could be reduced substantially by
having the PRPs (excluding the Town of Springfield) hire
management personnel and purchase necessary material, and
Lhe Town pay for equipment and fuel costs.
"
EPA ReSDonse:
EPA intends to give the PRPs an opportunity to perform the
work described in the ROD. It is up to the PRPs to allocate
costs among themselves. EPA encourages the PRPs to develop
approaches to implementing the remedy that are efficient as
long as the work is performed in accordance with the 1990
ROD.
2.
1988 Comments (Deferred from 1988 ROD)
a.
Comment: A resident asked if continued horizontal or
vertical migration of contaminants could occur if the
proposed alternative (capping) is implemented.
BPA Response:
EPA has considered the potential for the horizontal and
vertical migration of contaminants. The selected remedy was
designed to reduce any future ~igration of contaminants to
the extent practicable. Unfortunately, there will be some
movement of contaminants due to the time which has expired
since disposal. The management of migration system will
target contaminants which have crossed or will cross the
boundary of the waste management unit.
b.
Comment: A group of residents expressed their preference
for a permanent cleanup remedy rather than containment,
collection of leachate and monitoring.
EPA ReSDonse:
EPA considered several alternatives which would have
resulted in a more permanent clean-up. EPA determined that
the selected remedy represents the best balance of the nine
selection criteria. All of the more permanent waste
treatment alternatives were orders of magnitude more costly
than the selected alternative. The remedy selected ?y EPA
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c.
provides greater dhort~term effectiveness, implement~bility,
and cost-effectiveness than the more permanent remed1es.
comment:. A group of residents asked EPA to consider
planting trees and other vegetation around the cap to
provide aesthetic and air quality improvements to the
proposed cap design.
EPA ReSDonse:
EPA's authority for cleaning up a site is restricted to
thcsa ~ctions necessary to protect human health and the
environment. Certain restric~ions will exist for the type
of vegetation that may be placed over the cap. However, the
site owner and other responsible parties will not be
restricted by EPA from any attempts to improve the aesthetic
nature of the site provided such activity does not interfere
with the cleanup.
d.
Comment: Residents requested that EPA design the cap to
maintain the current ground level rather than creating a
higher elevation at the site. The residents also asked that
well-heads be capped at ground-level to reduce maintenance
and risk of injuries.
EPA ReSDonse:
The thickness of the cap and the elevation of well-heads
will be determined during design. The cap must meet the
requirements established in the guidance so that its
effectiveness will not be compromised. The ROD allows for
site specific factors to be considered as part of the
design. Please see comment A.2.c regarding EPA's authority
to spend money for aesthetic issues.
e.
Comment: Residents asked that the proposed fence around the
site enclose the capped area only and not excavated areas
north of the cap. Residents also requested that warning
signs be posted along the fence at access points only.
EPA ReSDonse:
EPA has included a fence around only the capped area, as
requested in the comment. Warning signs will posted be as
necessary to prevent unauthorized entry. Since the fence no
longer extends to Will Dean Road, the warning signs should
not be visible from the road.
f.
Comment: A resident suggested that excavation of outlying
areas and capping of the site be deferred until EPA can
evaluate the effectiveness of the leachate collection and
treatment system alone. The commenter suggested that EPA
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.
should allow rainfall to flow through the site to "fiush"
contaminants into the leachate collection system for a more
cost-effective remedy than constructing a cap.
EPA ReSDonse:
EPA considered natural flushing during the alternative
evaluation process. Natural flushing has several problems.
First, it allows for the continued migration of
contamination from the waste into the water table. Second,
it assumes that there is complete knowledge as to where all
of the contamination is migrating and that there will be
methods of collecting all of tbe contaminated water. Third,
it does not consider the RCRA closure requirements. Fourth,
it would not provide for protection from the inhalation of
landfill gases containing hazardous substances. Finally,
the flushing system would place the burden of the cleanup on
the management of migration system which requires a great
deal of operation and maintenance. EPA prefers to use
management of migration to supplement source control, not to
replace it.
g.
Comment: A resident asked when the cap construction would
begin if EPA selects a cap as part of the site remedy.
EPA ReSDonse:
h.
EPA estimates that construction of the cap should begin
within two years of the selection of the remedy. The
standard EPA process following the signing of a ROD involves
the following: (1) EPA will prepare for and enter into
negotiations with the PRPs; (2) at the conclusion of
negotiations either EPA or the settling parties will
initiate remedial design; and (3) once the design has been
accepted, the construction of the cap will begin.
Comment: Residents were concerned about the aesthetic
impact of-the cap, i.e., what kind of fence and vegetation
would be used and whether trees could be planted on or
around the cap.
EPA Response:
The 1990 SFS and ROD describe the basic .components of the
selected remedy. The final cap design may be somewhat
different. Trees cannot be planted on top of a cap. Only
vegetation with a shallow root structure (grass) will be
planted on top of the cap. Vegetation with a deep root
structure could damage the low permeability layer of the
cap. As explained previously, (see EPA Response to comment
A.2.c) EPA cannot spend money for activities that do not
relate to protecting human health and .the environment, but
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i.
other parties would no~ he restricted from improving.,the
aesthetic nature of the site provided such activities do not
comprom;se the integrity of the remedy.
Comment: Residents
cleanup innovations
used as the current
site.
asked whether EPA could implement
perfected in the future, if a cap is
remedy for the Old Springfield Landfill
,
\
j
EPA Response:
~~ d~~cribed in the ROD, the site will be reviewed every
five years after the initiatidn of remedial action. Under
existing Agency procedures, new information submitted to or
generated by EPA is analyzed to determine if a change in the
remedy or a component of the remedy is warranted.
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B.
Summary of Potentially ResDonsible Parties' Comments
This section contains comments submitted by the PRPs. There are
two sets of comments. Comments were submitted by attorneys
representing Emhart Industries, Inc. and Textron Inc. (Emhart and
Textron) and by the Town of Springfield on the 1990 Proposed Plan
(the 1990 Comments). Emhart and Textron and the Town of
Springfield also submitted comments on the 1988 Proposed Plan.
Following issuance of that Proposed Plan, EPA divided the
remedial action into two operable units. Comments on the first
op-=Lcti.Jl~ UJ1.iL (management of migration) were answered in the 1988
Responsiveness Summary. Responses to comments relating to the
second operable unit (source control) were deferred until
issuance of this source control ROD (the 1988 Comments). The
comments are organized into the following categories:
1.
2.
1990 Comments
1988 Comments (Deferred from 1988 ROD)
1. 1990 Comments
a.
Comment: The PRPs contend that the risk of ingestion of
bedrock groundwater is non-existent. They refer to the lack
of an exposure endpoint due to the undevelopable nature of
the topography between the site and the Black River, the
presence of institutional controls and the discharge of
bedrock groundwater to the Black River as reasons why there
is no potential for exposure.
EPA ReSDonse:
'----
EPA disagrees with the PRPs' contention that the risk of
ingestion of bedrock is non-existent. In the 1988 Comments,
the PRPs denied the potential for the existence of
groundwater contamination in the bedrock east of the site.
Results of the 1990 FFS have shown that there is indeed
bedrock contamination east of the site. The land along
Route 11 is capable of being developed. In addition, EPA
considers the institutional controls described in the first
ROD less reliable and less preferable to active measures.
For example, according to the Town, the Town of Springfield
Article 88-2, has not been implemented. Institutional
controls may not replace active measures. Ingestion of
groundwater must be considered a potential risk at the site
and any alternative selected must address such risk.
Comment: The PRPs allege that Waste Area 4 is not a source
of contaminants of concern (i.e., chlorlnated ethenes) in
b.
13
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groundwater becaue;l'e thc!Se - contaminants are not found. ,~n
Waste Area 4 and water within Waste Area 4, itself, does not
exceed any Safe Drinking Water Act maximum contaminated
levels (HCLs) for contaminants of concern identified in the
EA.
EPA Response:
EPA does not agree that chlorinated ethenes are the only
contaminants of concern for groundwater. The 1988 EA and
Tables 1 and 2 in Appendix A of the ROD list the
contaminants of concern for groundwater. Groundwater in
Waste Area 4 exceeds the Vermont Groundwater Protection Act
enforcement standard for xylenes, which is a contaminant of
concern in groundwater. Benzene, another contaminant of
concern, has also been detected within Waste Area 4 and in
the groundwater below Waste Area 4. The presence of these
compounds above standards indicates that Waste Area 4 does
represent a potential threat to groundwater. Also, due to
the uncertainties associated with contaminant distribution
in landfills, which have both municipal and industrial waste
co-disposed, it is possible that additional contamination
exists which has not been detected. The selected remedy
considered the uncertainty associated with cO-disposed
landfills.
c.
Comment: The PRPs argue that Waste Area 2 does not
contribute contamination to, or require source control
action to mitigate contamination of, bedrock groundwater
because the majority of infiltrating surface water and
groundwater flowing through Waste Area 2 discharges at an
eastern seep (LSE04) which will be collected and treated in
operable unit 1, and groundwater beneath and in the vicinity
of Waste Area 2 does not exceed HCLs (as evidenced by
monitoring wells MW-46S, 48T, 48B, 42S, and 42T).
EPA Response:
Uncertainties in determining the characteristics of any
mixed stream of municipal and industrial waste require that
care be taken when evaluating data from randomly collected
samples. It is highly likely that concentrations greater
than the those detected during the investigation of the site
are present in Waste Area 2. REMCOR, the consultant for
Emhart and Textron, and the PRPs recognize this problem when
they claim that there would be enormous environmental
consequences resulting from the excavation of Waste Area 2.
There is a contradiction in the comments being made by the
PRPs. REM COR alleges that Waste Area 2 is cleaning itself
rapidly and, therefore, does not represent a threat to
groundwater. However, REMCOR also maintains that the degree
of uncertainty in characterization of the waste in Waste
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Area 2 leaves the possibility that significant contamination
may be undiscovered. EPA also is not completely satisfied
with the delineation of the groundwater exiting Waste Area
2. There is still the potential that the downgradient flow
of water from Waste Area 2 has not been intercepted. See
Attachment D for comments regarding the contaminant
desorption model.
Comment: The PRPs commented that risk of inhalation of
contaminants from landfill gases is non-existent.
d.
~FA R~5Donse:
,
It is unfortunate that both EPA and REMCOR were not able to
obtain valid air monitoring samples to use as indicators of
the potential air emission risk. EPA used a model with
conservative, yet acceptable, assumptions to determine the
potential risk from the inhalation of landfill gas. The
result of this assessment showed a potential carcinogenic
risk greater than the 10.6 point of departure. EPA has also
considered other factors to evaluate its concern regarding
landfill gas emissions. The well installation program
encountered concentrations of landfill gases at location 39
sufficient to stop the progress of drilling. The REMCOR
recalculation of the model shows a risk greater than the
point of departure under the maximum concentrations
detected. Further, the heterogeneous nature of mixed
municipal and industrial waste makes it impossible to be
certain of the exact waste composition. Even REMCOR and the
PRPs acknowledge the potential for significant air impacts
from the waste in their comments concerning excavation. The
air monitoring data collected during the FFS was invalidated
and may not be used for risk assessment purposes, but the
data is a qualitative indicator that hazardous substances
are being emitted in the landfill gas. EPA is concerned
about the protection of human health. At this site,
residential development could re-occur in the area around
the remedy. EPA must ensure that any future residents are
protected from exposure to hazardous substances from the
inhalation of landfill gases. EPA believes that there is a
potential risk greater than the point of departure and that
EPA's risk calculations are appropriate. Therefore, the
risk from inhalation of landfill gas must be addressed for
any remedial action to be protective.
e.
Comment: The PRPs allege that EPA has not demonstrated any
site risks beyond dermal contact risks and, thus, proposed
source control actions aimed at mitigating landfill gas
inhalation risks and bedrock groundwater ingestion risks are
arbitrary and capricious.
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.
EPA ReSDonse:
Selection of the source control actions in the ROD is not
arbitrary and capricious. EPA has identified the presence
of several potential risks at the Old Springfield Landfill
in addition to the risk from dermal contact and ingestion of
contaminated soil. Table 1 of the ROD presents those risks
identified by EPA which exceed the 10-6 point of departure.
Table I from the ROD shows that risks were identified from
the inhalation of landfill gas and volatilized gases from
leachate seeps, and from the ingestion of groundwater from
both the eastern and western s1des of the site. EPA has
responded to the PRPs contentions regarding the inhalation
risk in the comment B.1.d. Regarding potential groundwater
ingestion, there is potential for the development of the
areas under which the contaminated groundwater is found on
both the eastern and western sides of the sites. Data
collected during the RIfFS and FFS confirm the presence of
contaminants above maximum contaminants levels in the
groundwater off-site. EPA believes that there are risks
other than dermal contact and that the source control remedy
was required to consider such risks. In addition, EPA is
required to consider ARARs in developing the appropriate
remedy for the site.
f.
Comment: The PRPs commented that EPA may not rely on the
1988 EA to support source control actions aimed at
mitigating alleged inhalation and ingestion risks. They
cite procedural flaws resulting from EPA's failure to
respond to the 1988 comments regarding the 1988 EA. The
PRPs also claim that the 1988 EA does not demonstrate any
unacceptable risks associated with inhalation of landfill
gases or ingestion of bedrock groundwater. In addition,
they reference their 1988 comments which claimed that the
1988 EA was based upon erroneous assumptions, incorrect
calculations, and highly unrealistic exposure scenarios.
EPA Response:
~AS discussed in the responses B.1.a and B.1.d and in many of
\ the other responses, EPA believes that there are
I demonstrated risks associated with inhalation of landfill
gases and ingestion of bedrock. EPA has relied upon and
considers it appropriate to continue to rely upon the 1988
EA. The 1988 EA was developed according to acceptable
Region I practices. EPA is not aware of any data, nor has
it been presented with any rationale, which justifies the
development of a new endangerment assessment. Responses to
the allegation that the EA contained erroneous assumptions,
incorrect calculations, and highly unrealistic exposure
scenarios may be found in comments B.2.b and B.2.c.
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g.
. .
Comment: The PRP's contend that REHCOR's revised risk
assessment shows the absence of ingestion and inhalation
risks and was improperly rejected by EPA.
EPA ReSDonse:
The Detailed Evaluation Memo provides EPA's review of the
risk assessment contained in the 1990 FFS. EPA does not
agree with all of the conclusions referenced on pages 21 and
23 of the comments. In particular, EPA disagrees with the
fOllowing conclusions: (2) the inference that the water in
Waste Area 4 does not exceed enforcement standards, when in
fact the water exceeds the Vermont standard for xylene; (3)
that the wells identified absolutely intercept the
contamination exiting Waste Area 2; (10) that groundwater to
the east of the site is not capable of development; and (11)
the inference that all of the water moving east is
discharging to the Black River.
Comment: There is no public health risk rationale for
placement of a low permeability cap on Waste Areas 2, 3 and
('- 4 or for gas collection systems or covering of the
I outslopes.
I
I
h.
EPA ResDonse:
.--.<
EPA reiterates its determination that the risks identified
in Table I of the ROD are appropriate. The selection of a
low permeability cap was based upon an interpretation of the
RCRA closure ARAR and the need to reduce the infiltration of
water into the waste so that the contamination in the
unsaturated waste will no longer contaminate the
groundwater. In addition, a low permeability cap offers the
ability to control the emission of landfill gases. EPA
believes that the outslopes, as they exist today, are
unstable. This belief was also expressed by REM COR in their
1988 comments.
L
Comment: The management of migration remedy selected in
first operable unit ROD has been determined to protect
public health and the environment. RCRA capping of Waste
Areas 2, 3 and 4 is not required to achieve any chemical-
specific ARAR.
BPA ReSDonse:
Implementation of the first operable unit remedy will
protect public health and the environment with respect to
the risks addressed in that operable unit. The first
operable remedy only partially addresses the risks
associated with the ingestion of groundwater and will not
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j.
address the risks ~ssociated with the inhalation of landfill
gases or the risk associated with the dermal contact with
and ingestion of contaminated soil. The management of
migration remedy was not intended to, nor could it, address
all of the risks posed by the source of contamination. The
ARARs for this operable unit promotes the protectiveness of
the remedy.
Comment: EPA has misinterpreted the CERCLA statute,
regulations and Agency guidance by requiring a RCRA-
compliant cap. RCRA is an action-specific ARAR and such
~~~p~ ~~ ~ot apply unless they are necessary to protect
public health or the environment or to achieve a chemical-
specific ARAR. In the absence of risk, the construction of
a mUlti-layer RCRA-compliant cap cannot be justified as an
"applicable or relevant and appropriate requirement" under
CERCLA.
EPA Response:
k.
EPA's determination of ARARs for the site is in accordance
with CERCLA, the NCP and the EPA guidance "CERCLA Compliance
with other Laws Manual" (August 8, 1988). Moreover, as
pointed out in this responsiveness summary, EPA disagrees
with the PRPs' contention regarding site risks. Also, the
PRPs mischaracterize EPA's differentiation of ARARs into
chemical-specific, location-specific and action-specific.
EPA has divided ARARS into these categories to facilitate
their identification. Each ARAR need not necessarily
achieve all location, chemical or action specific ARAR. The
capping ARAR is required because it is relevant and
appropriate to the remedial action.
Comment: The PRPs comment that even if action-specific
ARARs apply at the site, a RCRA cap is not appropriate under
the circumstances of the release of hazardous substances at
the site.
EPA Response:
EPA is required to evaluate site-specific conditions in
determining if an ARAR is relevant at a site and appropriate
in the particular circumstances. EPA engaged in exactly
this analysis in determining that a RCRA-compliant cap was
relevant and appropriate for Waste Areas 2, 3 and 4, but
that such a cap was not appropriate for the side slopes of
Waste Areas 2 and 3. Among the reasons that the Agency
determined that RCRA was relevant and appropriate is not
just the fact substances similar to RCRA wastes were found
at the site, but that RCRA listed wastes were found at the
site. The RCRA ARAR is discussed in Section XI of the ROD.
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1.
. .
Comment: To the extent " that RCRA requirements are
considered ARARs, soil covers on Waste Areas 2 and
be consistent with "Hybrid Closure" under RCRA.
4 would
EPA ReSDonse:
Based on the circumstances at the site, EPA has determined
that RCRA hazardous waste closure requirements, including
landfill closure, are relevant and appropriate, and the
circumstances under which hybrid closure would be
appropriate are not present at the site. EPA does not find
!:HylJL,i\l Closure" to be appropriate for Waste Areas 2, 3 or
4. The CERCLA ComDliance witn Other Laws Manual: EPA/540/G-
89/006 (the manual) explains the concept of Hybrid Closure.
In the manual, two scenarios are presented to describe the
situations under which Hybrid Closure would be acceptable.
The two scenarios are:
(1) Although residual contamination is above health-
based levels (i.e., clean closure levels) contamination
does not pose a direct contact threat or i~pact
groundwater. Residual leachate levels exceed health-
based lev~ls. A type of alternate closure, which may
be termed "alternate-clean closure" could be used. No
covers or long-term management would be required.
However, fate and transport modeling and model
verification is necessary to ensure that the
groundwater is usable. In this situation, a notice in
the property deed may be necessary indicating the
presence of hazardous substances.
(2) Removal of waste material results in residuals that
potentially pose a direct contact threat but do not
pose a threat to groundwater. Residual leachate
contamination does not exceed health-based levels.
This type of alternate closure, which may be termed
"alternate-landfill" closure, consists of a cover to
address the direct contact threat. The cover, however,
may be permeable. Limited long-term management would
include site and cover maintenance and minimal ground-
water monitoring. For this scenario, institutional
controls, including land-use restrictions, would be
necessary, based on site-specific considerations.
jg. at 2-20 - 2-21.
The first scenario under which Hybrid Closure may be used is
clearly not appropriate for the Old Springfield Landfill
site due to the presence of contamination in the soils which
represent a potential direct contact threat. In addition,
the contaminated groundwater at the Old Springfield Landfill
is not usable.
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. .
The second scenario under-which Hybrid Closure may b~ used
is also not appropriate because the leachate of all of the
identified waste areas does exceed health-based levels. In
addition, there would be no initial waste removal activity
as described in the second scenario nor will the site be
subject to only limited long-term management. The
management of migration system operable unit will ensure
that the site is subject to a great deal of long-term
management. Neither of the scenarios described in the
manual occur at the Old Springfield site.
~. /)cu~~~nt: The PRPs asked that the following material be
~ included in the Administrative Record: (i) the comments that
.' they submitted to EPA on August 23, 1988, (ii) the comments
submitted on the July 9, 1990 Proposed Plan, (iii) the draft
Final Focused Feasibility Study Report (FFS) prepared in
June 1990, (iv) the "Petition for Reconsideration of ROD
Issued 9/22/88 and for Supplementation of Administrative
RecordU (Petition for Reconsideration), (v) all previous
. correspondence regarding the Site, and (vi) transcripts and
videos of all public hearings and meetings.
EPA Response:
Pursuant to the National Contingency Plan (NCP), EPA must
establish an administrative record "that contains the
documents that form the basis for the selection of a
response action." 40 CFR 300.800(a). In accordance with
the NCP, the Administrative Record for the site includes
those documents that form the basis for the selection of the
remedy for both operable units. The 1988 comments which
pertain to the second operable unit, the 1990 comments,
transcripts of public hearings, videotapes of public
hearings or meetings which were made by EPA personnel and
correspondence that was part of the Agency's decision-
making in selection of the remedy will be included in the
Administrative Record. The Petition for Reconsideration
will not be included in the Administrative Record. This
document does not pertain to the second operable unit and
the materials contained therein were not part of the basis
for selection of either of the operable unit remedies.
Moreover, the Petition for Reconsideration does not contain
new information and so does not rise to the level of
information to which the Agency is required to give
consideration under Section 117 of CERCLA or EPA policy and
procedures. EPA notes that many of the arguments and
statements made in the Petition for Reconsideration are also
comments that the PRPs have submitted on the 1990 Proposed
Plan. To the extent that is the case, those comments are
being addressed in this Responsiveness Summary and so will
be included in the Administrative Record.
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n.
.
Comment: EPA refused to respond to comments on risks
associated with inhalation of landfill gases and ingestion
of bedrock groundwater that the PRPs submitted for the 1988
ROD and took the position that responses were not warranted.
EPA ReSDonse:
In reviewing the comments received in response to the 1988
Proposed Plan, the Agency decided to divide the remedial
action into two operable units. The ROD issued in 1988 is
for the first operable unit, which is a management of
:i;r~ticn remedy. Source control action was deferred to the
second operable unit. All comments pertaining to issues
that would be addressed by source control are now being
responded to in this second operable unit ROD.
o.
Comment: EPA violated CERCLA sections 113{k) and 117{b) by
not responding to the PRPs' comments on risk assessments in
the responsiveness summary to the first operable unit ROD.
EPA Response:
p.
In 1988, EPA responded to those comments submitted by the
PRPs which related to the remedy being selected for the
first operable unit. Neither section 113{k) nor section
117{b) requires the Agency to incorporate into the
Administrative Record materials which it has Dot relied on
in selecting the remedy.
Comment: CERCLA public participation requirements impose
greater obligations on EPA than those imposed by ru1emaking
procedures in section 553 of the Administrative Procedure
Act (APA), 5 U.S.C. section 553.
EPA Resnonse:
q.
EPA followed the public participation requirements set forth
in CERCLA in issuance of the 1988 ROD and in issuance of
this ROD. The NCP requires that the public, which includes
PRPs, be given the opportunity to comment on the proposed
remedy. 40 CFR 300.430(f) (3). In accordance with the NCP
requirements on public participation, the Agency responded
in the 1988 Responsiveness Summary to all significant
comments that were received which pertained to the remedy
being selected pursuant to that ROD. This Responsiveness
Summary responds to significant comments which were received
in both 1988 and presently which pertain to the source
control operable unit.
Comment: EPA's use of the 1988 risk assessment without
responding to PRPs' comments violates their procedural
rights.
-------
.
EPA ResDonse:
r.
The comments that PRPs submitted in 1988 which pertain to
EPA's risk assessments and the consequences of those
assessments on the source control action are being responded
to in this Responsiveness Summary. Those comments did not
pertain to the first operable unit ROD and so were not
appropriate for response at that time.
/Comment: EPA has not supplemented the Administrative Record
~o in~lude all of the documents requested by PRPs and has
thus deprived them of the opportunity to participate in
development of the Administrative Record.
EPA ResDonse:
The Administrative Record is the Agency's compilation of
documents that it relied on in selecting a remedy.
Materials are included in the record, from any source, to
the extent that such materials are pertinent to the Agency's
decision-making- The PRPs had the opportunity to
participate in development of the Administrative Record
through submission of oral comments at the Agency's public
hearings on the Proposed Plan for both operable unit RODs as
well as in the submission of written comments- All of the
comments and criticisms of the PRPs are included in the
Administrative Record to the extent that they were submitted
pursuant to the public comment period or otherwise relied on
by the Agency.
s.
(
Comment: EPA officials met with persons interested in the
Proposed Plan and gave them copies of it before the public
meeting, but did not advise the PRPs of such a meeting-
There are no minutes of the meeting and PRPs do not know
what was discussed. EPA also met with officials of the Town
of Springfield and the Proposed Plan was discussed at that
meeting. EPA declined to meet with the PRPs.
EPA Response:
The first meeting referenced above was held on June 28, 1990
in a resident's home near the site. In attendance were the
EPA project manager, EPA community relations coordinator,
twelve residents from the site area, and a town selectman.
EPA had met with this group in the past and had promised to
meet periodically to discuss citizens concerns related to
their proximity to the site (e.g- field work, residential
well sampling results). EPA representatives distributed a
copy of the June 28, 1990 press release announcing the July
12, 1990 public information meeting and briefly describing
the preferred alternative. This same release was mailed to
22
-------
u.
. -
the entire site mailing list on June 28, 1990.
distribute copies of the 1990 Proposed Plan at
or at any other meeting prior to July 12, 1990
the PRPs.
EPA did not
this meeting
as alleged by
The second meeting referenced by the PRPs was held on July
12, 1990 at 4:00 PM with representatives from the Town of
Springfield, EPA, VTDEC, the Vermont Attorney General's
Office, and the Vermont congressional delegation. The
meeting was requested by the Vermont congressional
delegation to discuss communication between EPA and the Town
of Springfield. The meeting was hosted by the Town of
Springfield, and EPA had no role in determining who could or
could not attend. Discussion focussed on how to promote
better communication between the Town of Springfield, VTDEC
and EPA. It is not EPA policy to notify PRPs of meetings
with citizen groups or meetings called by a third party or
to keep minutes of such meetings.
EPA did afford the PRPs, however, with the opportunity for
public participation required by CERCLA, including
participation at an informal public meeting on July 12, 1990
and at an August 2, 1990 public hearing in Springfield. In
addition, pursuant to the request of PRPs, the public
comment period was extended from 30 to 60 days.
t.
Comment: The PRPs advised EPA that they would be
a revised risk assessment in the FFS and the only
contention was whether the risk assessment should
separate document.
EPA ReSDonse: This is incorrect. EPA continuously
maintained that a revised risk assessment was not required
or requested. When EPA became aware of the PRPs intentions
to submit a revised risk assessment along with the FFS
Report, EPA advised the PRPs that Region I required all risk
assessments to be performed according to the Region I
Supplemental Risk Assessment Guidance. A copy of the
guidance was sent to the PRPs.
submitting
issue of
be a
Comment: The PRPs commented that the reasons EPA put forth
in the Detailed Evaluation Memo for rejection of the risk
assessment in the FFS are arbitrary and capricious.
EPA ReSDonse:
The PRPs comments assume that any party has the ability to
formulate a risk assessment based on factors of their own
choosing. EPA has been delegated the authority and the
responsibility for ensuring that the statutory mandates of
CERCLA are met. It is EPA's responsibility to ensure that
remedial actions are protective of human health, welfare and
-------
v.
w.
the environment. ~t i5. EPA's responsibility to defi~~ the
risk factors, in accordance with regulatory requirements.
In addition, the EPA Office of Solid Waste and Emergency
Response Directive No.9835.15 states that PRPs will no
longer be allowed to perform risk assessments for superfund
sites.
Comment: The PRPs state that they included a revised risk
assessment in the FFS because EPA refused to consider their
comments on the 1988 EA and EPA has issued new risk
assessment guidance documents which undermine reliance on
~h- ~,
~.~ ~n.
~
EPA ReSDonse:
The PRPs' comments on the EA which related to the source
control action are responded to in this Responsiveness
Summary. Neither the Region I risk assessment guidance
issued in 1989 nor EPA Headquarters guidance undermine the
1988 EA.
Comment: EPA's source control actions attempt to mitigate
risks that do not exist, are inconsistent with the NCP and
are arbitrary and capricious.
EPA ReSDonse:
EPA has responded to the PRPs' comments on the risks
identified at the site in numerous other responses in this
Responsiveness Summary. See, e.g., responses to comments
B.1.a and B.1.d. EPA's actions are not inconsistent with
the NCP. EPA has engaged in remedial investigation of the
site, has conducted appropriate feasibility studies and has
developed and analyzed remedial alternatives in accordance
with the nine criteria set forth in the NCP. See
300.430{e) (9) (iii). EPA has not been arbitrary and
capricious in selection of the remedy.
x.
Comment: The PRPs have stated that the impermeable cap
described in EPA's preferred alternative is excessive in
both cost and complexity; is likely to be ineffective; and
does not take into account site specific conditions. The
PRPs have stated that: 1) because native clay potentially
may not be available for the 24-inch compacted clay layer,
alternative materials should be evaluated; 2) due to the
existing sandy soil cover in Waste Areas 2 and 3, the 12-
inch gravel gas venting layer is unnecessary; 3) based on
the potential for significant differential settlement, a
flexible membrane layer (FML) is inappropriate for Waste
Area 4; and 4) where an FML is used, the clean fill layer
may be reduced.
-------
.
EPA ResDonse:
EPA has included flexibility in the ROD to enable additional
site specific factors in the cap design. The ROD requires
the cap to be designed to meet or exceed the performance
requirements set forth in 40 CFR 264.310, 40 CFR 264.110 and
the Technical Guidance Document Final Covers on Hazardous
Waste Landfills and Surface ImDoundments, July 1989
(EPA/530-SW-89-047) (Technical Guidance) or in a manner to
achieve performance equivalent to the requirements of 40 CFR
~o4.1~~, 264.310 and the Technical Guidance.
,
With respect to REMCOR's criticism of the proposed design,
it should be recognized that the configurations and cap
dimensions indicated in the SFS and in the 1990 Proposed
Plan are based upon specifications presented in the
Technical Guidance. It should also be noted that the cap
dimensions contained therein are considered to be minimum
requirements and that actual dimensions may be greater where
appropriate to take into accoun~ site specific conditions
(frost protection, settlement, gas venting, etc.). The cap
described in the 1990 SFS report used the minimum cap
dimensions to fulfill all recommendations proposed in the
guidance document except for the thickness of the flexible
membrane liner (FML).
During the remedial design, EPA anticipates reviewing the
feasibility of substituting low permeability naturally
occurring soil or alternative soil and clay mineral mixes
that meet or surpass the intended functions of the 24-inch
low permeability soil layer (1 x 10-7 cm/sec or less)
recommended in the Technical Guidance. However, EPA remains
concerned that potential alternative cap designs may
ultimately prove to be less reliable than those which adhere
to its current guidance. In this regard, the Agency is
concerned that a reduction in the overall cap thickness
(e.g., replacement of the 2-foot compacted low permeability
soil with bentonite panels, reduction of 2-foot of clean
fill to 1-foot, elimination o~ the FML etc.) would reduce
the frost protection given to the low permeability compacted
soil layer and to the gas vent layer. Since landfill gases
contain relatively high moisture contents (up to 80% on a
wet weight basis) and since water is typically used to
compact the low permeability soil layer (e.g., water added
to clay after emplacement to aid in compactability and
obtaining desired hydraulic conductivity), protection from
frost must be given key consideration. Successive
freeze/thaw cycles may cause damage to the low permeability
soil layer, thereby voiding its integrity.
-------
t
With respect to the cap gas vent ~ayer, the cap design,
presented in the 1990 SFS was aga~n based on the Techn~ca1
Guidance. This document indicates that the gas vent layer
should have specifications similar to the gran~lar material
indicated for use for the drainage layer (Sect~on 5.1.2).
The Technical Guidance specifically indicat7s that th7 ,
drainage layer design should have a hydrau1~c conduct~v1ty
of at least 1 x 10.2 cm/sec (or hydraulic transmissivity of
at least 3 x 10.5 m2/sec), should consist of granular
material no coarser than 3/8-inch which is classified as
"~P" (iUore than fifty percent smaller than No.4 sieve (4.76
mm), poorly graded sand, gravel, with little or no fines),
the material selected should be smooth and rounded, and
should not contain fines that might lessen the permeability
(Section 3.1). In addition, the Agency is currently
considering the appropriateness of increasing the hydraulic
conductivity requirement for the drainage layer from 1 x 10.
2 cm/sec to 1 cm/sec (two order of magnitude increase) (EPA
625-4-89-022). This change essentially eliminates the use
of sand and necessitates the use of gravel. Gravel size
should be between \ to ~-inch with no fines to comply with
the new proposed guidance.
Remcor's comment that the existing sandy soils meet the
USEPA requirements for hydraulic conductivity cannot be
evaluated by EPA without additional data. The Remcor boring
10g information from MW-39S (0 to 4 foot interval) indicates
the presence of "brown coarse sand, little silt, some peat,
trace gravel". The presence of the silt and peat would
reduce the hydraulic conductivity of the predominant coarse
sand. No data is presented to confirm that these soils meet
the current USEPA minimum technology guidance (MTG)
requirement of 1 x 10.2 em/sec or other MTG requirements.
Literature information would tend towards suggesting a
hydraulic conductivity of 10-4 cm/sec to 10-3 cm/sec for the
upper four feet, which is one to two orders of magnitude
less than the MTGs, and three to four orders of magnitude
less than the proposed MTGs.
With respect to gas vent layers in Waste Areas 2 and 3, EPA
would consider reviewing alternative approaches to the gas
vent layer during remedial design that provide equivalent
performance. However, the Agency antic~pates that any such
consideration of alternative approaches may include
requirements that technical studies gradation testing be
performed to ensure that header and collection piping would
not be plugged from siltation effects (i.e., soil particles
smaller than the pipe openings reduce the effectiveness of
the collection system by entering into/plugging the pipe) .
The need for filter materials (fabric, geonet, or
intermediate sized soils) may also have" to be addressed.
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.
with respect to Waste Area 4, EPA acknowledges the fact that
there is likely to be some settlement due to the presence of
municipal waste. The Technical Guidance points out that the
compacted soil (which is in contact with the FML) should
have a minimum slope of 3 percent after allowance for
settlement. The Technical Guidance also points out that
where there is a concern about subsidence and settlement,
the design and construction of the cap should take measures
to minimize the settlement and its effect on the cap. It
also points out some of the preventative measures which may
be t~]~cn, including consolidation and compaction of the
waste, adjusting the initial Jlope of the caps, use of a
thicker FML layer and performance of special construction
procedures to compact the cap layers. Overall, while the
Agency will further evaluate the potential impact of
differential settling on the FML layer during remedial
design, it currently believes that appropriate engineering
approaches can be utilized in Waste Area 4 to overcome this
concern.
EPA also points out that, as discussed in its Technical
Guidance, the FML and the low permeability clay or soil
layer together are intended to form the low permeability cap
layer and they are considered to function as one system. In
addition, these layers tend to back each other up in the
event of a failure of either component.
The EPA Technical Guidance also indicates the low
permeability layer should be constructed so that it will be
entirely below the maximum depth of frost penetration upon
completion of the cover system. In northern areas of the
United States, such as the Old Springfield Landfill site,
this recommendation would necessitate a top layer thicker
than the 24-inch minimum (the top layer includes all
successive layers above the drainage layer). As previously
indicated, protection from frost needs to be given close
consideration in the capping system design as successive
freeze/thaw cycles may cause damage to the low permeability
soil layer, thereby voiding its integrity.
In summary, EPA has incorporated flexibility into the ROD to
allow for an evaluation of designs other than those
presented in the Proposed Plan, but any alternate design
must achieve equivalent performance to the standards listed
in 40 CFR 264.110, 40 CFR 264.310, and the Technical
Guidance.
y.
Comment: The PRPs have suggested that the proposed french
drain design can be modified. Remcor has proposed a design
(refer to Attachment B) that provides a separate shallow
surface water drain along the western and southern sides of
-------
Waste Area 4 whicR does not include a hydraulic barrier on
the downgradient face of the french drain; eliminates the
combini~g of surface and groundwater flow and reduces the
hydrau11c system size. The PRPs have also proposed
elimination of wells for dewatering Waste Area 4.
EPA ReSDonse:
EPA has provided flexibility with respect to the methods of
intercepting groundwater entering Waste Areas 3 and 4. The
ROD requires that the french drains or some equivalent
method of water collection be designed, constructed, and
maintained to achieve the objectives and specifications
established in the ROD.
EPA initially proposed a single french drain capture system
incorporating both surface water flow and groundwater
interception in the belief that this system offers certain
advantages of simplicity in design and engineering. While
EPA does not necessarily concur with all of the technical
data furnished in the PRPs' comments (such as the peak flow
estimates), the Agency acknowledges the potential viability
of the PRPs' conceptual design for separate surface water
drainage ditch and groundwater french drain systems as
depicted in Figure 2, Alternate Design Illustrations (PRP
Comments; september 10, 1990) under certain conditions. EPA
is in agreement with the PRPs that surface water intercepted
upgradient of Waste Areas 3 and 4 could possibly be diverted
away from the waste areas and discharged without further
treatment assuming this water has not passed through
potentially contaminated areas. The Agency has also
reviewed Detail C, french drain in Figure 4, Alternative
Design Details (PRP Comments; September 10, 1990) relating
to the removal of the flexible membrane liner (FML). The
Agency points out that the FML was included in its proposed
french drain system, in part, to prevent possible seepage
into Waste Area 4 from the drain should high flow levels in
the drain result in temporary flow back-ups in the system.
However, EPA would consider a separate drainage system
concept which did not include an FML during remedial design.
In evaluating the removal of the FML EPA would consider if
the proposed separate system:
1) allows the surface runoff from ~he cap to be
diverted towards the surface water drainage ditch and
this runoff will not infiltrate into the waste areas;
2) insures that the cap runoff will not be introduced
to the french drain system as a means to dilute
groundwater collected by the french drain; and
-------
.
3) insures tnat the water collected from the french
drain system (groundwater intercepted from upgradient
of the drain as well as backflow from the waste area)
will be treated to the appropriate levels and
standards.
If these design objectives are maintained, EPA recognizes
that a downsizing of the overall hydraulic system size may
be appropriate. System sizing will be determined during the
remedial design.
z.
~ith r~spect to dewatering Waste Area 4, additional measures
to dewater the waste area (e.g. pumping) will be considered,
and, if found appropriate by EPA during remedial design,
implemented. EPA feels that inclusion of the use of pumping
as proposed in the SFS is an appropriate component in the
dewatering of the waste area. The use of wellpoints or
borings with appropriately sized sand packs or screens and
pumps is anticipated to provide a shorter time frame for
dewatering than sole reliance on the passive collection of
backflow into the french drain system, as proposed by the
PRPs, because of the measured contrasts in hydraulic
conductivity between the till and the waste. The injection
test in Waste Area 4 at MW-32S yielded a hydraulic
conductivity of 9.4x10.3 cm/s and slug tests in waste area
borings RTB-19 and RTB-20 yielded hydraulic conductivities
of 2. 50X10'S cm/s and 1. 55x10.S cm/s, respectively (FFS;
April 1990). Measured hydraulic conductivities in the till
ranged from 1.3x10's cm/s to 5. 8x10.7 cm/s (FFS; April 1990).
Thus, values of hydraulic conductivity in the waste area are
equal to or greater by almost four orders of magnitude than
the values in the till through which the backflow from the
waste area must flow to be intercepted by the french drains.
In addition, some degree of interconnection observed between
the trenches themselves in Waste Area 4 has been observed
(FFS; April 1990, p. 2-56). Such interconnection could
reduce the number of wellpoint placements or borings in the
early stages of dewatering.
Comment: The PRPs have stated that if slope stabilization
is required in Waste Areas 2 and 3 then methods other than
those proposed by EPA should be considered on the basis of
effectiveness, implementability and cost. Remcor has
specifically proposed a "buttress/fill" _stabilization
approach to both Waste Areas 2 and 3.
EPA Response:
EPA agrees the the best method of slope stabilization should
be determined during design. The ROD requires that the
slopes be stabilized to prevent any slope failure which can
seriously damage the cover system, which could allo~
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releases of waste and leachate into surrounding soils and
groundwater. Eac~ slop~ must be designed to withsta~~ t~e
loading and hydraulic conditions to which it will be subJect
during the cap's construction and post-closure periods. In
addition, the slopes of Waste Areas 2 and 3 will be
stabilized so that a greater than 1.25 long-term factor of
safety is achieved. Each slope will be stabilized,to
prevent or minimize, to the degree practicable, sh1fts,
cracks or slumpage in the slope in excess of those expected
by waste settlement and to prevent a decrease in the
integrity, permeability or effectiveness of the cap. The
':'~'.'':'~ '~~,:::1 on these eastern slopes will minimize
infiltration of water through'~he cover and will, to the
degree possible, attain the performance standards in 40 CFR
264.310.
EPA indicated in the 1990 Proposed Plan and in the SFS that
the extent of slope stabilization necessary for Waste Areas
2 and 3 requires further investigations which will be
conducted during the remedial design. EPA also recognizes
and has indicated that multiple approaches to slope
stabilization for Waste Areas 2 and 3 may exist and that
these approaches may also differ for each waste area.
EPA acknowledges that Waste Area 3 might ultimately
represent less of a problem with respect to slope
stabilization than Waste Area 2. However, EPA believes that
the PRPs' assertion that slope stabilization is not needed
in Waste Area 3 is premature and inaccurate. As noted in
Appendix F of the 1990 SFS (page F-1), limited available
information indicates that the SPT blow counts are very low
for the waste material. Since the existing outslopes of
Waste Area 3 are steeper than 1 vertical to 2 horizontal,
the additional weight of the cap quite possibly may cause
instability on the side slopes.
EPA also disagrees with certain input data assumptions made
by the PRPs in their computer assessment of slope stability.
In particular, an internal friction angle of 358 corresponds
to a blow count of 25 (according to Peck. Hanson and
Thornburn's Foundation Enaineering, page 310). This is a
high number for the existing waste. According to borings
MW40S (Waste Area 3), MW48S and MW49P (Waste Area 2), the
blow counts in the waste material are around 10, some are
even as low as 2 or 3. Moreover, at the hypothetical
internal friction angle of 35., the factor of safety
obtained by Remcor is marginal, at approximately 1.2 to 1.3.
Also, the short term stability of the slopes should be
determined. Judging from the low blow counts of the
existing fill, the cohesion or undrained shear strength is
likely be low.
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. . .
F1nally, EPA notes that- Remcor' s comment on the need- "for
slope stabilization appears to directly contradict earlier
comments made by Remcor on the 1988 FS. At that time,
Remcor indicated that it considered the outslope areas to be
prone to instability due to the past methods of waste
placement.
EPA bas conducted a preliminary review of the alternative
slope stabilization approaches for Waste Areas 2 and 3 and
considers them to be potentially feasible. Additional
detailed evaluation would be required during remedial design
prior to a determination of the acceptability of the
approach by the Agency. In addition, the Agency maintains
that any proposed approach should have a factor of safety of
a minimum 1.25 for the long term, and 1.2 for the short term
(construction stage) against shallow and deep seated
failures. In addition, the Agency notes that the existing
heavy vegetation on the slopes, which presently serves as a
stabilizing measure, would probably have to be removed to
accommodate the backfill. This may create stability
problems during construction.
aa.
In summary, the Agency believes that slope stabilization
measures will ultimately be required in Waste Areas 2 and 3.
During the remedial design, following pre-design
investigations of slope stability EPA will consider
alternative approaches to slope stabilization for Waste
Areas 2 and 3 such as the "buttress/fill" approach suggested
by Remcor.
Comment: The PRPs requested that EPA not implement the
option to excavate Waste Area 2 and place the excavated
material under the Waste Area 3 cap. They stated that EPA
underestimated the excavation risk, did not fully address
regulatory issues (LDRs), and overestimated technical
difficulties and costs associated with side slope
stabilization in Waste Area 2.
EPA Response:
EPA believes that it is advantageous to retain the option
for excavation in the selected remedy. Once more details
about the other components of the remedy are finalized, a
better determination of the feasibility of the complete
excavation can be performed. EPA has established cleanup
goals for the complete excavation of Waste Area 2 in section
X.A.3 of the ROD.
In its detailed evaluation of the feasibility of excavating
waste material from Waste Area 2, EPA has indicated in its
evaluation that during actual excavation environmental and
health impacts are a possible concern. The Agency.
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recognizes that s¥ch i~pacts could include possible on-site
worker exposure to contamInants in the waste material
through dermal contact and/or inhalation. It is also
recognized that some off-site migration of contaminants
might conceivably occur or that some previously undetected
contaminants might be identified. The Agency does not,
however, agree with the PRPs' comment that the environmental
and health risks associated with excavation of waste from
Waste Area 2 were "enormous". On this issue, the Agency
notes that this comment appears to contradict the FFS
prepared by the PRPs wherein it is asserted that under a no
action alternative, "maximum risks would, however, be within
the acceptable risk range even assuming the breakdown of
institutional controls and residential development of the
site". FFS at 4-10. The Agency disagrees that excavation
of waste material in Waste Area 2 by qualified and trained
personnel represents a far greater risk than is posed by
unsupervised residential development at the site.
In evaluating the feasibility of excavation, the Agency has
reviewed available information contained in the 1988 RI/FS
and 1990 FFS concerning specific contaminants identified to
date in Waste Area 2 and routes of exposure to workers
during excavation of Waste Area 2. In addition, the Agency
recognizes that certain of the contaminants which have been
identified in Waste Area 2 (including PCBs) do pose a
concern to on-site workers with respect to dermal exposure
during excavation. However, excavation is a remediation
method which has been widely used in remediation of soils
containing PCBs and other contaminants identified in Waste
Area 2.
Overall, the Agency believes that any potential on- or off-
site risks associated with excavation can be effectively
minimized through the implementation of appropriate health
and safety practices and associated monitoring programs.
With respect to the cost of excavation of Waste Area 2, EPA
acknowledges that if the cost of slope stabilization in
Waste Area 2 is substantially less than initial projections,
then excavation of Waste Area 2 could ultimately prove to be
more expensive than capping the waste area. However, in the
absence of any supporting cost documentation, the Agency is
not prepared to accept the PRPs' estimate that excavation
would be "at least $600,000 more expensive" than capping.
As previously indicated, the actual difference in cost
between capping and excavation will depend, in part, on the
actual method of slope stabilization which is chosen.
The excavation of material from within the area of
contamination and subsequent consolidation of such material
-------
.
under the cap would not' trigger the RCRA land disposal
restrictions.
bb.
Comment: The PRPs stated that an active gas collection
system in Waste Area 3 is not necessary because there is no
unacceptable risk from gas inhalation and the low rate of
landfill gas emissions does not warrant an active system.
EPA ResDonse:
As described in previous comments, EPA has determined that
t~er~ is an unacceptable risk ,from inhalation of landfill
gas emissions in Waste Area 3: EPA believes that active gas
collection offers an effective means of addressing the
problem of landfill gas emissions while simultaneously
offering a potentially valuable means of significantly
reducing the total concentration of volatile organics in
Waste Area 3, thereby reducing the ti~e required for
remediation of groundwater frem this waste area. EPA
believes that for these combined objectives, active gas
collection is likely to be significantly more effective than
passive gas collection.
Waste Area 3 is believed to contain significantly more waste
(estimated by Remcor to be 72,000 cubic yards) than either
Waste Areas 4 and 2 (estimated by Remcor to be 42,500 and
6400 cubic yards, respectively). Therefore, the volumes of
landfill gas generated in Waste Area 3 may be significantly
greater than in either of the other waste areas. In
addition, the total masses and concentrations of volatile
and potentially hazardous organic contaminants, particularly
chlorinated ethenes in Waste Area 3, are greater than in
either of the other two waste areas. Some chlorinated
ethenes which have been detected are potential health
hazards if inhaled. EPA notes that Remcor was required to
temporarily suspend field operations during drilling in
Waste Area 3 due to high gaseous vinyl chloride
concentrations. Finally, based upon the results of the FFS,
EPA believes that the total mass of chlorinated ethenes
currently remaining within Waste Area 3 and the underlying
till is large and will continue to contaminate groundwater
passing through the waste area for many years. As
previously indicated, EPA believes that active gas
collection is a technology which offers-a potentially
effective means of addressing all three concerns: landfill
gas pressure buildup, hazardous gas release and accelerated
groundwater remediation.
In the active gas collection system as identified in the
SFS, Waste Area 3 is considered to be a significant source
of VOC groundwater contamination at the site. In
conjunction with this, the location of the proposed-
-------
telescoping landf~ll gas extraction wells have been placed
within areas of h1ghest. VOC contamination (up to >100 mg/kg
total VOCs) in the unsaturated zone which extends to depths
of over ~o feet below grade. Since the VOC compounds
detected have Henry's Law constants which are amenable to
compound removal via stripping (vapor extraction), active
gas extraction in this area is seen as a beneficial means to
reduce the levels of VOCs remaining in the unsaturated soil
after emplacement of the capping system, thereby combining
source control as a portion of the gas collection system.
Additional VOCs may be removed from the upper water bearing
zone beneath Waste Area 3 if the zone of influence exerted
by the extraction well intercspts the water table and if the
vacuum head is high enough to remove VOCs.
As previously indicated, the active gas system should also:
o
Reduce the theoretical timeframe required for
groundwater and leachate collection and
treatment by reducing and treating the source
area.
o
Ensure the effective treatment of potentially
high levels of VOCs in the landfill gas, which
might be released from Waste Area 3 should
passive activated carbon treatment systems break
through. (Alternatively, flaring of the off-
gas may be proposed, but supplemental energy
costs might make this very expensive).
EPA has reviewed the calculations presented by Remcor, and
while it does not necessarily agree with the quantitative
assumptions and results presented therein, the Agency does
acknowledge that a passive gas collection may be capable of
preventing excessive gas pressure buildup. The Agency does,
however, remain concerned that landfill gas generation
usually occurs over a 70 to 90 year period, but may not be
seen for up to 40 years after a capping system is in place
at hazardous waste landfills. In addition, the long-term
logistics and effects of gas generation/release are not
known for hazardous waste landfills, and as such,
conservative approaches to gas collection are potentially
appropriate.
with respect to the PRPs' gas flux calculations, the Agency
notes that while a geometric mean landfill gas velocity of 1
x 10.10 em/see was used to estimate the gas flux, velocities
up to almost two orders of magnitude greater than this value
were estimated in the upper soil zones. Paired with the
uncertainties in landfill gas generation at hazardous waste
landfills after capping, the significant variations in gas
-------
.
velocities introduce some uncertainties with respect' 'to the
pressure buildup estimation approach presented.
cc.
In summary, EPA points out that the proposed use of active
gas collection is not solely for the purpose of preventing
excessive gas pressure buildup. The Agency also notes that,
with respect to long-term operation, the proposed active
system could be easily converted to a passive system, if
data indicate that active extraction is no longer removing
large quantities of VOCs from the soils. This would reduce
operation and maintenance costs for the active system.
Finally, EPA points out that t,he ROD incorporates language
which allows for the use of a passive venting system if it
can be shown to achieve a level of performance equivalent
with the active gas collection system.
Comment: Tbe PRPs stated that a single source control well
is sufficient to intercept the groundwater discharging from
the till beneath Waste Area 3.
EPA ReSDonse:
EPA acknowledges that pumping from a single extraction well
might be feasible for source control efforts. Nonetheless,
the Agency maintains its original position that a
remediation approach, including more than one extraction
well in Waste Area 3, should be more efficient and flexible
in capturing contaminated groundwater than a system
including only one well. Similarly, the Agency believes
that multiple extraction wells are likely to prove more
effective than a system relying only on extraction wells
utilized in the management of migration (Operable Unit 1)
system. Installation of a multiple well system offers the
flexibility through variable and pulsed pumping rates to
maximize and optimize the groundwater capture zone in
response to changing hydraulic conditions arising from both
source control and management of migration efforts. Such
flexibility is often unavailable in a single well system
that is limited, by definition, to just one location.
Furthermore, should a single well extraction system be
selected and then found to be deficient for the intended
purpose after installation, subsequent well installations
may be difficult to implement due to issues relating to:
potential compromise of an already emplaced cap; the
additional costs of a second well installation mobilization;
lost remediation time; and either the associated costs of
treating excess clean water pumped by or the loss of
contaminant mass missed by the inefficient single well
system.
EPA acknowledges that specific extraction well locations and
configurations are being deferred to the remedial design
-------
dd.
phase and that adQitional hydrogeologic information obtained
during the intervening" -time period can be used to re.fine the
configuration. The Agency believes that a decision
regarding the adoption of the concept of multiple extraction
wells need not conflict with ongoing management of migration
remedies. Multiple source control extraction well
placements offer the flexibility to enhance selected
management of migration groundwater extraction design
approaches and should accelerate remediation times.
Comment: The PRPs stated that the remedial activity
schec~l~~ for the source control and management of migration
remedial components should be-integrated so that
inconsistencies can be avoided.
EPA Response:
EPA is aware that there are some components of the two
operable units which overlap. In particular, the eastern
leachate collection system cannot be installed until the
side slope stabilization system is designed. EPA intends to
phase the first operable unit so that the groundwater
extraction wells and western leachate collection systems can
be designed and constructed without further delay.
ee.
Comment: The Town of Springfield requested that Alternative
7 be chosen as the selected alternative as it was an order
of magnitude less expensive than the selected alternative.
They supported this statement with a claim that there
appears to be no evidence of any health risk such as
inhalation of landfill gases or ingestion of bedrock
groundwater.
EPA Response:
ff.
EPA has responded to the questions pertaining to risk in the
previous comments. Alternative 7 was not selected and was
not eligible for selection because it did not satisfy either
of the two threshold criteria. EPA cannot select remedies
which are not protective of human health and the environment
nor can it select remedies which would not comply with
ARARs. The selected remedy was the most cost efficient of
the alternatives which satisfied the two threshold criteria.
The selected remedy contains sufficient flexibility to allow
for more cost effective components if they achieve
equivalent performance to the components described in the
remedy.
Comment: The Town of Springfield commented on the design of
the cap, gas collection system, french drains, source
control extraction wells, side slope stabilization, and the
-------
.
integration of operable units one and two. The Town' 'also
adopts the comments submitted by the Companies.
EPA Response:
The selected remedy includes flexibility to allow for
additional site specific factors to be considered during
design. The multi-layer cap must meet the performance
standards established in RCRA and the RCRA Technical
Guidance. other concerns listed in the above comment are
addressed in response to comments submitted by the
:-, \!""~ II -~.;...C'
- _..-~.- -...- --.
.0
2.
1988 Comments (Deferred from 1988 ROD)
Comment: The selection of the 10.7 incremental cancer risk
as the target risk level does not appropriately reflect site
characteristics and is not consistent with recent EPA Region
I policy at other sites.
a.
EPA Response:
EPA points out that the 10.7 incremental cancer risk was not
selected as the target risk level for site cleanup. The
10-7 incremental cancer risk due to direct contact hazards
and ground water ingestion were only two of the six
scenarios developed and evaluated (FS, 3-46 and 3-52).
b.
Comment: The RI does not support the need for the capping
of the landfilled wastes to protect against future ingestion
of bedrock groundwater to the east of the former landfill.
EPA's calculations regarding contaminant migration into the
bedrock aquifer are erroneous. EPA's calculations
concerning exposure to contaminants through consumption of
fish from the Black River are erroneous.
EPA Response:
In response to this comment, EPA emphasizes that the results
of the FFS clearly demonstrate that groundwater
contamination from the site has, in fact, migrated an
extensive distance off-site to the east. Several
chlorinated ethene contaminants including vinyl chloride
have been detected in monitoring wells in both bedrock and
till formations to the east of the site. Vinyl chloride has
been detected in both till and bedrock formations at MW-45
at concentrations significantly in excess of the MCL.
The Agency believes that the field data collected by Remcor
adequately refutes the PRPs' original 1988 objection to the
hydrologic model presented in the RI which postulated the
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off-site migratio~ of contaminated groundwater through
bedrock to the east of' the site. ..,
c.
The Agency acknowledges that the results of the FFS do not
demonstrate observable contamination in the Black River.
However, EPA is concerned that there is limited evidence to
indicate that all of the contaminated groundwater to the
east of the site discharges to the Black River. The Agency
does not believe that sufficient evidence exists to
determine the ultimate fate of all of the contaminated
groundwater in bedrock or till to the east of the site.
Comment: The RI does not support the need for capping
landfilled wastes to protect against off-site exposure to
contaminants via inhalation of chemicals in landfill gas.
EPA ReSDonse:
Remcor stated that the second driving force in originally
proposing cap installation in 1988 was reduction of risks
associated with inhalation of landfill gases. They further
stated that the EPA model of gas emissions from the
landfilled waste is in error. They based their comment on
the following conclusions:
o
Inaccuracy of EPA model of gas emissions (Mass Balance
Model).
o
Unrealistic assumptions relative to soil VOC levels.
o
Area of emission source and frequency of exposure.
Inappropriate fraction organic carbon value used in
mass balance model.
o
Each of these conclusions has been addressed separately
below.
Validitv of EPA's Mass Balance Model: Remcor suggests
that EPA's model of air emissions from the landfill is
not appropriate based on a mass balance analysis.
However, Remcor's mass balance, as presented in 1988,
was considered erroneous on several accounts. First,
it looked only at surface soils (0 - 2.5 feet), whereas
waste materials were detected as deep as 43 feet.
Further, it ignored the mass of" contaminants in the
vapor phase in the fill. This resulted in an
underestimation of the mass of contaminants potentially
present by at least five orders of magnitude (a factor
of 100,000). Thus, there was in fact considered to be
adequate material to be released over a long exposure
period.
-------
.
Use of Maximum Soil VOC Levels as ReDresentative of
Site Conditions: Remcor further objected to the use of
maximum soil concentrations as representative of the
site. However, this was a standard risk assessment
practice that has been used by EPA at many other sites.
The maximum represented a plausible upper-bound case.
It was noted in the EA that this maximum case probably
overestimated actual risk and for that reason an
average case was presented as well.
U~e of 70-Year Lifetime EXDosure:. Remcor noted that
the assumption of a 70 y~ar lifetime exposure also
overestimated risk. However, this was again a standard
EPA assumption used for most risk assessments. In
addition, use of a 40 or 50 year lifetime exposure
would not significantly reduce the total risk
estiThates. Remcor appeared to erroneously assume that
residents must remain outside to be exposed; however,
indoor air concentrations would be expected to reach
equilibrium with outdoor concentrations over time.
Relocation of current residents would not affect the
risk assessment since the future use scenario, in
keeping with EPA risk asses~ent practice, assumed no
remediation or other corrective actions and allowed for
unlimited redevelopment of the site.
Use of InaDproDriate Fraction of Orqanic Carbon (foc)
Value: The commenters suggested that a value of 5% for
the fraction of organic carbon (foc) would be more
realistic than the 0.0023% used by EPA in its model to
predict potential future leaching of contaminants from
the waste. In general, EPA prefers to use site-
specific data where available, rather than relying on
literature values. For this reason, the value
developed from on-site data was used. During the waste
delineation investigation, five soil samples were
collected for total organic carbon analysis. Sample
numbers, depth sampled, material sampled, and the TOC
results are summarized in Table 1. Locations for test
borings and monitoring well borings from which these
samples were obtained are shown in the RI Report,
Figure 3-3. Samples were selected to represent a range
of depths from 0.5 to 2.5 and 27 to 29 feet below the
ground surface. EPA Method 9060 was used for the
analysis.
Samples MW-28-001, MW-25-003 and MW-27-007 are from the
deltaic sands and their results were considered
indicative of the TOC content encountered by lpndfill
gas as it moved through soil cover, or by leachate as
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TABLE 1
TOTAL ORGANIC CARBON RESULTS
Sample
No.
Depth Interval
( ft. )
0.5 - 2.5
4.5 - 6.5
13 - 15
25 - 27
27 - 29
Material
SamDled
TOC
(ma/ka)
MW-28-001
MW-25-003
MW-27-007
72-010
78-009
Medium Sand
Coarse-Medium Sand
Fine Sand
Clay
Fill Material
82
14
5
16
69
'.
it moved laterally through the sand unit. Sample 72-
010 was considered representative of the clayey till
found beneath Waste Area 3. Sample 78-009 was
considered representative of mixed waste and soil fill
found in Waste Area 3.
It was noted in the EA that this procedure probably
overestimated leaching since additional organic carbon
may be present in the waste to further retard leaching.
However, using a 5% foc as the commentors suggest would
not significantly affect the results of the risk
assessment or the need for a cap to prevent
infiltration. Using Remcor's estimates of retardation
factors with 5% organic carbon still resulted in
calculated excess lifetime cancer risks from ingestion
and inhalation greater than 10.4 for plausible maximum
concentrations of benzene and methylene chloride, and
greater than 10-5 for chloroform, tetrachloroethylene,
and trichloroethylene. The total risk would therefore
not be significantly changed. The Remcor comments also
ignored the levels of contamination in shallow
groundwater which represented risks ranging from 1 x
10.3 to 7 X 10-2.
Summary: Remcor concluded that EPA used "...erroneous
assumptions and unrealistic exposure scenarios..." based on
the above comments. The Agency believes that the
assumptions that were made and the exposure scenarios that
were developed were basically valid and. in accordance with
standard practices used by those in the field of risk
assessment. Therefore, the Agency disagrees with Remcor's
conclusion.
d.
Comment:
capped.
The outslopes of the former landfill should not be
40
-------
I
EPA ResDonse:
The PRPs' presented the above conclusion relating to the
1988 FS based on the following concerns:
o
Lack of empirical data to characterize contamination.
Limited benefit due to reduction of infiltration on
outslopes.
Questionable stability of cap on slopes due to internal
friction between layers.
Difficulty in handling of heterogeneous materials.
CUrrent problems with sl~pe instability.
o
o
o
o
Lack of Empirical Data to Characterize outsloDe
contamination: The outs 1 opes of the former landfill area
were (and are) believed to be underlain by waste materials
that, in all likelihood, contain contaminants similar to
those found in the rest of the landfill. Although no
empirical data was obtained because of difficulties in
performing subsurface explorations on the steep slopes, EPA
considered it reasonable to assume that contaminants of
concern are present below the outslopes in potentially
significant quantities.
Limited Benefit Due to Reduction of Infiltration: Remcor
calculated the proportion of inflow through the slopes as a
percentage of total bedrock ground water flow, and also as a
percentage of bedrock ground water flow towards the east.
They concluded, at that time, that as the proportion of
slope infiltration was very small (0.024 percent and 3
percent for total and eastern bedrock flows, respectively),
only a very limited benefit could be obtained by capping the
outslopes and thereby eliminating infiltration in those
areas. They were also of the opinion that the steep slopes
possessed higher runoff potential, and would cause
infiltration to emerge quickly as seep flow.
EPA considers this viewpoint to be misleading. The
outslopes (2 acres) represent approximately 25 percent of
the total surface area of the 8 acre landfill. As such, the
outslopes could be expected to contribute 15 to 25 percent
of the total contaminant loading caused by infiltration.
Furthermore, the heavy vegetative cove present on the
outslopes retains precipitation and pro~otes infiltration
into the outslopes and retards runoff. Installation of the
cap was anticipated to decrease infiltration over the
outslopes, reducing contaminant migration to the seeps.
Ouestionable Stability of CaD on OutsloDes:
indicated that the factor of safety for the
sand on HDPE liner) was less than 1.0 for a
further indicated that the slope would have
Remcor
cap (sliding of
3:1 slope. They
to be regraded
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to a 4:1 slope to.provlde-an adequate factor of safety
against sliding.
Remcor assumed that the drainage layer of the cap would
consist of sand, which would be placed on the HDPE liner,
and therefore appeared to analyze a condition that would not
occur. A typical cap section was shown on Figure 4-1 in the
Feasibility study report. The frictional resistance of soil
materials overlying the synthetic membrane was not
evaluated, as the material directly over the membrane
consisted of a synthetic drainage net similar to Gund1e
C~D~r.~t. Overlying the Gundnet would be a geotexti1e
covered by 2 feet of earthen dover (final cover).
Where soil material was to be placed on the geotexti1e, an
angle of frictional resistance of 26 degrees was
conservatively selected for analytical purposes. When
evaluated with an overall slope of 3 horizonta1:1 vertical
(18 degrees), a factor of safety of 1.5 was estimated for
resistance to sliding.
EPA points out that the selected remedy does not include a
RCRA cap on the outs10pes.
Difficu1tv in Hand1inq Heteroqeneous Waste: The handling of
the heterogeneous materials encountered below the outslopes,
and the compaction of such materials could be satisfactorily
performed using available equipment and technology. In the
FS, it was anticipated that municipal solid waste would be
compacted by repeated passes with an appropriate piece of
compaction equipment prior to cap placement. Any bulk
debris encountered during excavation activities would likely
be contaminated, and was not expected to be removed from the
site.
The potential for encountering infectious wastes during
Municipal Solid Waste (MSW) handling was to be addressed by
the Health and Safety Plan developed to cover construction
operations. It was not considered necessary to address this
issue during the FS process.
CUrrent Problems with Slope Instability: Remcor indicated
that the current outs1ope areas were prone to instability
problems due to the method of waste placement, and that
"disturbing the outslopes would be likely to exacerbate this
unstable condition". In order to construct the cap on the
outslopes, it was estimated that a reduction in slope to
3H:l would be necessary. This slope reduction could only
serve to increase the stability of the outs1opes due to a
reduction in the forces driving the slope downhill.
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.
e.
. ."
In summary, EPA agrees with the PRPs that the outslopes are
too unstable to support a cap designed according to the
Technical Guidance. EPA also agrees with the PRPs that the
outslopes are unstable as they exists. The selected remedy
will address the instability of the outslopes.
Comment: The potential risk associated with contact with
contaminated surface soils suggests covering and fencing
approximately 1.5 acres of the former landfill to address a
target risk level of 10-6, rather than constructing the
eight-acre cap described in EPA's 1988 Proposed Plan.
EPA ResDonse:
~
The estimated areas that exhibited a direct contact risk in
excess of 10-6 due to contaminated soils are shown on FS
Figure 3-2. A1though these areas do not total 8 acres,
there were other reasons for proposing an 8 acre cap
included in the FS and other comment responses.
EPA also notes that resident relocation or other
institutional controls would not affect the risk assessment
for the future use scenario. In accordance with EPA risk
assessment practice, the future use scenario assumed no
remediation or other corrective action, and allowed for
unlimited redevelopment of the site.
f.
Comment: The data does not support the need for the cap
proposed by EPA. The ROD should specify performance
objectives rather than a detailed cap configuration.
EPA ReSDonse:
Remcor appeared to object to the fact that the original FS
and Proposed Plan proposed a specific multi-layer cap
design, including a soil liner and synthetic membrane. They
appeared to take exception to the following issues:
o
Differential settlement was potentially ongoing at the
site, and may adversely affect a synthetic membrane.
Cap design in FS was supposedly taken from EPA guidance
documents for new hazardous waste landfills, rather
than guidance for site remediations.
o
o
Inappropriate specification of a particular cap design
in ROD.
Specific responses to these opinions are as follows:
CaD Resistance to Differential Settlement: High Density
polyethylene (HPDE) membranes are capable of elongating up
-------
to 700 percent before tearing (Gundle Lining Systems...Inc.
product specifications). It was and is considered highly
unlikely that differential settlements caused by the
degradation of MSW could result in such large elongations in
the membrane liner. Therefore, settlement of the MSW should
not affect the liner to the extent that Remcor feels may
occur.
Furthermore, specific steps may be taken during design and
construction to minimize the tensile forces exerted on the
liner by differential settlement of the MSW. They would
i~cl~de preloading of the MSW to reduce the total amount of
settlement that could occur, and a liner design that would
allow some "slack" in the liner which could then be taken up
to accommodate some of the elongation caused by differential
settlement.
Guidance Documents for CaD Desiqn: The use of a synthetic
membrane as a component of a mUlti-layer cap was and is
consistent with EPA guidance. Various EPA guidance
documents recommend the use of a synthetic membrane to
minimize the volume of liquid infiltrating the cap. Two of
the utilized references were:
1.
RCRA Guidance Document - Surface ImDoundments. Liner
Systems. Final Cover and Freeboard Control, July, 1982.
EPA Handbook - Remedial Action at Waste DisDosal Sites.
EPA 625/6-85/006, October 1985.
2.
3.
EPA Handbook - Covers for Uncontrolled Hazardous Waste
Sites. EPA/540/2-85/002, September 1985.
4.
Technical Guidance Document: Final Covers on Hazardous
Waste Landfills and Surface ImDoundments. EPA/530-SW-
89-047, July 1989.
These documents recommend the use of a mUlti-layer
including a synthetic membrane underlain by 2 feet
soil (X <10.7 em/sec.) to reduce infiltration into
contaminated material.
cap,
of clayey
Remcor appeared to recognize the need for a cap to "provide
long-term minimization of liquids through the closed
landfill" (Remcor, Page 25) by citing RCRA performance
standards for landfill closure, 40 CFR 264.310. That
argument may also be used to support the inclusion of a
membrane liner. It cannot be argued that a soil liner alone
can be equal in effectiveness to a soil liner/membrane liner
combination in minimizing infiltration through a closed
landfill.
-------
. .
Specification of CaD Desian in ROD: The Agency disagrees
with Remcor's conclusion and feels that it is appropriate to
specify a cap design in the ROD. A cap constructed of
multiple layers, incorporating both a synthetic membrane and
natural soils of low permeability, was an integral part of
the originally proposed remedy. Furthermore, the proposed
cap would satisfy appropriate regulations and performance
standards more satisfactorily than a single layer cap
constructed only of soil. However, the exact configuration
of the constructed cap could differ somewhat from that shown
in the 1988 FS (FS, Figure 4-1). The new configuration
~~ould be equivalent to that specified in the ROD, and
developed during the remedial "design.
Summary: The Agency disagrees with Remcor's conclusion and
feels that it was and is appropriate to specify a multi-
layer cap.
g.
Comment:
need for
landfill
proposed
The data developed in the
excavation of areas beyond
and consolidation of these
cap.
RI does not support the
the limits of the former
materials under the
EPA ReSDonse:
Based in part on the results of the 1990 FFS, which was
performed following receipt of this comment, EPA's current
Proposed Plan does not call for excavation of Waste Area 1
or other satellite waste areas or placement of materials
from these areas under the cap.
h.
Comment: The slurry wall proposed by EPA as an option
within the preferred alternative would have limited
effectiveness.
EPA Res90nse:
EPA has not included a slurry wall in its current Proposed
Plan.
-------
b.
C.
. '-
Summary of state of Vermont Comments
This set of comments was generated by the state of Vermont.
are organized into the following categories:
They
1.
2.
1990 Comments
1988 Comments (Deferred from 1988 ROD)
1.
1990 Comments
~
~n~~~~t: The state commented that they agreed with the EPA's
preferred clean-up alternative and that they were currently
considering the proposed option to consolidate the waste
from Waste Area 2 under the Waste Area 3 cap.
EPA ReSDonse:
EPA is pleased that the State of Vermont concurs with the
selected remedy- EPA has incorporated the excavation option
as a design consideration.
2.
1988 Comments (Deferred from 1988 ROD)
a.
Comment: EPA should provide a clearer explanation of how it
determined the depths to which EPA would excavate
contaminated soil from outlying areas of the site. EPA also
should specify the depths to which contaminants from sloped
sections of Waste Areas 2 and 3 would be excavated, and how
EPA would resolve the potential problem of continued
leaching from contaminants left beneath the excavated areas.
EPA ReSDonse:
The selected remedy does not include the excavation of
outlying areas as described in the 1988 Proposed Plan. The
slope stabilization method will be determined during
remedial design. There will be continued leaching from
those contaminants which have already migrated below the
waste. The management of migration system and source
control extraction wells will target the contamination that
will continue to migrate beyond the waste management unit.
Comment: The proposed remedy relies he~vily on future
operation and maintenance activities that could place a
large burden on the resources of the State of Vermont and
the Town of Springfield. Because operation and maintenance
activities may have to be continued indefinitely into the
future, the proposed remedy may not meet the requirement for
a permanent remedy.
-------
.
EPA Response:
EPA has performed an evaluation of the selected remedy and
several other alternatives based upon the nine criteria
listed in the NCP. The ROD provided the rationale for
selection of the remedy. EPA realizes that the selected
remedy is not as permanent as other alternatives nor does it
involve treatment as a principle element, but the selected
remedy did provide for the best balance among the five
balancing criteria. The selected remedy was designed to
avoid reliance on long-term management to the extent
practicable.
~
IV.
REMAINING CONCERNS
Issues raised during the public comment period that will continue
to be of concern as the site moves into the remedial design and
remedial action phase are described briefly below. EPA will
continue to address these issues as more information becomes
available during the RD/RA.
1. Cost of the remedy and its potential financial impact on
the Town of Springfield
2. Site appearance
3. Future potential use of the site
4. Timing of the start of remediation
-------
.
ATTACHMENT A
COMHUNTTY ~IONS ACTIVITIES CONDUCTED
AT THE OLD SPRINGPIELD LANDPILL SITE
SPRINGPIELD, VERMONT
EPA conducted the following community relations activities at the
Ol~ Springfield Landfill site.
August 1983 - EPA conducted a public meeting to describe the
remedial studies and procedures that would be conducted at the
site.
.-
July 1984 - EPA conducted interviews with local residents to
prepare a Community Relations Plan (CRP).
February 1985 - EPA released the CRP.
September 1985 - EPA conducted a public meeting to present the RI
results.
October 1986 - EPA held a public meeting to present the results
of the Supplemental RI and discuss future site activities. EPA
also released a fact sheet on the Supplemental RI.
June 1987 - EPA met with the residents of the Springfield Mobile
Home Estates to discuss plans to temporarily relocate residents
during remedial investigations. EPA conducted a" public meeting,
held a press conference, and mailed a brief update to the people
in attendance and those on the site mailing list.
July 1987 - A representative from Federal Emergency Management
Assistance (FEMA) was available during the 12-day temporary
relocation of site residents. EPA officials met with residents
during the temporary relocation to answer questions.
July 1987 - EPA established an information hot line for
to call for updates and leave messages. EPA officials
periodically check and respond to any messages that are
the hot line.
residents
left on
March 1988 - EPA released a fact sheet to explain the results of
the Supplemental RI.
June 1988 - Prior to the public announcement, EPA officials hand-
delivered announcements to and met with the individual mobile
home residents to discuss EPA's recommendation for permanent
relocation as part of the Proposed Plan for site cleanup. EPA
also held a press conference to announce its recommendation.
-------
. .
June 1988 - EPA published the Proposed Plan which includes' an
announcement of EPA's public comment period on the Proposed Plan
and RIfFS.
July 1988 - EPA held a public meeting to present the Proposed
Plan and describe the public comment period.
July 1988 - EPA conducted a public hearing to summarize the
Proposed Plan and accept public comment on it. In conjunction
with the public hearing, EPA released a fact sheet and held a
public meeting to discuss the results of the EA. Approximately
40 p~~pl~ ~~~;nded the hearing.
August 1988 - EPA conducted an informal meeting with concerned
citizens and area residents to discuss their comments and future
site activity.
September 1988 - EPA completed a Responsiveness Summary of the
public's comments and EPA's responses to them.
October 1988 - EPA published a fact sheet that included an
announcement of the ROD and described the method for controlling
the spread of contamination from the site.
November 1988 - EPA held a public meeting to explain the ROD.
August 1989 - EPA held a formal public meeting to describe the
FFS work plan.
December 1989 - EPA conducted interviews with local residents and
town officials to prepare a revised CRP.
May 1990 - EPA completed the revised CRP.
May 1990 - EPA released an Old Springfield Landfill Superfund
site activity update fact sheet.
July 1990 - EPA released the Proposed Plan for Source Control.
July 1990 - A public informational meeting was held and a 30-day
public comment period began.
July 1990 - PRPs requested and EPA extended the public comment
period from 30 days to 60 days.
August 1990 - An informal public hearing was held to accept
public comments on the Proposed Plan that EPA released in July,
1990. Approximately 35 people attended.
September 1990 - The public comment period on the Proposed Plan
was closed.
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ATTACHMENT B
DETAILED SUMMARY OF POTENTIALLY
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SEP 1'7 REC'D -
TOWN OF SPRINGFIELD
SPRINGFIELD. VERMONT 05156 f 18021 885.2104
Office of rhe M.".ger
September 10, 1990
Mr. Edward Hathaway (HPS-CAN1)
~~~~d~al Project Manager
united states Environmental
Protection Agency
Hazardous Waste Division
Region I
John F. Kennedy Pederal sui Iding
Boston, Massachusetts 02203-2Z~1
~ Qld Springfield Landfill ~
Dear Mr. Hathaway:
On behalf of the Town of Springfield, I would ask that
the administrative record show the following comments in
relation to the proposed Source Control Clean-Up Plan for the
Old Springfield Landfill site in Springfield, Vermont which
has been proposed by the Environmental Protection Agency. I
submit the following:
1. Based upon the studies referred to by E.P.A. in
it's July 19, 1990 proposal, there appears to be no evidence
of any health risk such as inhalation of landfill gases or
ingestion of bedrock ground water at the site, and because of
the fact that ambiguity exists as to whether or not there is
any danger at all, it would seem that reconsideration should
be given to the proposed clean-up Alternative. None of the
alternatives presented by E.P.A. are 100\ guaranteed to
accomplish any purposes of clean-up or health protection.
Given the bealth risk assessment ambiguity, the public health
protection that will result from Operable Unit No.1 and the
order of aaqnitude of cost of the Preferred Alternative as
compared to Alternative '7 (Focused Feasibility Study
Alternative '3), it would make sense to implement Alternative
'7. This Alternative includes fencing, installation of a
source control well and covering contaminated soils. The
remedial remedies under Operable Unit No.1 should be given
consideration and the Alternative would be subject to five
year review as well as constant monitoring which would
provide a level of assurance to the public that potential
health concerns were being addressed and remedied. In any
-------
Mr. Edward Hathaway
2
September 10, 1990
.
case, if because of monitoring or if
during five year reviews should show
inadequacy in the remedy, additional
required.
It is inconceivable that absent the specific health
risks and ambiguity as to certain health risks that it would
be economically appropriate to select a remedy at ten times
the cost of the remedy proposed in Alternative 17.
information obtained
that there was
remedial action could be
2. The proposed cap design of the Preferred Alternative
is based upon an ultra-conservative assumption and is very
costly. If E.P.A. insists on capping an effective and less
costly design would be appropriate. Six inches of top soil
is acceptable in Vermont for root zones and grass mixes,
therefore, six inches rather than twelve inches is suggested.
Twelve inches of clean fill rather than twenty-four inches is
adequate and the twenty-four inch compacted clay layer could
be eliminated by using local material which meets the
permeability criteria.
3. Remcor points out the ambiguities of the risks
associated with gas released and in the absence of any risk
it would make sense to require a passive gas collection
system, rather than a significantly more costly active gas
collection system. If, during the process of ongoing
monitoring and evaluation it should be determined that an
active gas collection system is necessary, then it would be
appropriate to do that at that time.
4. The effectiveness of deep french drains as proposed
in the Preferred Alternative is questionable. These are very
costly and their long-term effectiveness is uncertain. It
would be more prudent to install shallow french drains and a
swale upgraded to divert surface water. This alternative
will be equally as effective and reduce surface water from
entering the french drain.
s. Having in mind the ongoing ground water monitoring
and the five year reviews, it would be practical to require
only one source control well which would be more cost
effective then that which is proposed presently by E.P.A.
6. The Town of Springfield believes that there should
be a reevaluation of the side slope stabilization proposals.
7. The Town of Springfield adopts by reference those
comments which will be filed simultaneously by Emhart and
-------
Mr. Edward Hathaway
t
3
September 10, 1990
desires to not only include the substantive matters contained
therein but 81so the legal and due process arguments.
8. There is considerable amount of concern about the
integration of Operable Unit No.1 with the implementation of
the proposed source control remedy. The areas of overlap
snou~ci be very clearly defined before E.P.A. makes a final
decision on its Preferred Alternative.
I appreciate your giving the comments of the Town of
Springfield attention and would ask that if there is any
question, that you conta~t me immediately.
A@=~~
Wiff~teele
Town Manager
pc:
John Parker, Esq.
Barry Malter, Esq.
Daniel squire, Esq.
Tim Conway
-------
COMMENTS OF EMHART INDUSTRIES, INC., AND TEXTRON INC.
ON EPA'S PROPOSED SOURCE CONTROL PLAN FOR THE OLD
SPRINGFIELD LANDFILL SITE, SPRINGFIELD, VERMONT
Barry L Malter, Esq.
Swidler & Berlin Chartered
3000 K Street, N.W., Suite 300
Washington, D.C. 20007-3851
202-944-4946
Counsel for Emhart Industries, Ine.
September 10, 1990
Daniel H. Squire, Esq.
Skadden, Arps, Slate,
Meagher & Flom
1440 New York Avenue, N.W.
Washington, D.C. 20005-2107
202-371-7060
-------
COMMENTS OF E~T INDUSTRIES, INC., AND TEXTRON INC.
ON EPA'S PROPOSED SOURCE CONTROL PLAN FOR THE OLD
SPRINGFIELD LANDFILL SITE. SPRINGFIELD. VERMONT
This document, prepared with the assistance of Remcor,
Inc. ("Remcor"), constitutes the comments of Emhart Industries,
Inc. and Textron Inc. (the "Companies.) on the Proposed Source
Control Cleanup Plan ("Proposed PlanW) for the Old Springfield
Landfill Site (the WSiteW), issued by the Environmental
Protection Agency ("EPA") on July 9, 1990.1/
This document also
constitutes the comments of Emhart and Textron on the EPA and
Agency contractor documents supporting the Proposed Plan.!/
.
Incorporated by reference as part of the Companies' comments are
the draft Final Focused Feasibility Study Report ("FFS") prepared
by Remcor (June 7, 1990), the comments submitted to EPA by
Emhart, Textron, and Remcor on August 23, 1988, and the WPetition
for Reconsideration of ROD Issued 9/22/88 and for Supplementation
of Administrative Record," filed by the Companies on May 19,
1989.
We ask that these comments, together with our prior
submissions referenced herein, all of our previous correspondence
1/ The resumes of the Remcor scientists and engineers who
assisted in preparing these comments are attached hereto as
Exhibit I.
1/ These documents include: Hathaway, Edward M., July, 1990,
"Memorandum to site File re: Detailed Evaluation and Comparative
Analysis of Alternatives" (.Detailed Evaluation Memo"), EPA
Region I, Boston, Massachusetts; and Ebasco Services, Inc., July,
1990, "Draft Final Supplemental FS Evaluation, Old Springfield
Landfill, Operable Unit No.2. (.SFS"), prepared for EPA Region I
-------
.
-2-
regarding the Site, and transcripts and videotapes of all public
hearings and meetings be included in the Administrative Record.
I.
BACKGROUND
After studying the Old Springfield Landfill site for a
period of more than four years at a" cost approaching $3 million,
on June 23, 1988, EPA proposed a preferred remedial alternative
for the Site, pursuant to the Comprehensive Environmental
Response, Compensation, and Liability Act ("CERCLA").
This
.
preferred alternative would have required, inter alia, the
installation of a low permeability cap, compliant with the
Resource Conservation and Recovery Act ("RCRA"), over
approximately eight acres of the site, the excavation of
approximately 25,000 cubic yards of materials from elsewhere on
the Site for placement under the cap, the collection and
treatment of contaminated seeps emanating on the eastern and
western outslopes of the Site, and the extraction of groundwater
from a sand and gravel aquifer underlying the site for treatment
with the collected contaminated seeps.
The stated rationale for
that preferred alternative, allegedly supported by a draft final
endangerment assessment ("EA") (ICF, June 1988a), a draft final
supplemental remedial investigation report ("RI") (ICF, June
-------
-3-
June 1988b), was that site conditions presented unacceptable
risks to public health through dermal contact with and/or
incidental ingestion of surficial soils, inhalation of volatile
organic compounds (WVOCSW) emanating from the seeps, inhalation
.
of landfill gases (VOCs) from the entire Site, ingestion of
bedrock groundwater, and consumption of fish in the Black River.
On August 23, 1988, the Companies filed extensive
comments on the Agency's June 23, 1988 preferred alternative,
which comments included a thorough scientific evaluation of the
RI, FS, and EA.
The Companies were assisted in the preparation
of those comments by Remcor, an experienced hazardous waste
consulting and remediation firm.
In those comments, Emhart and
Textron agreed with the necessity of collecting and treating
contaminated seeps and also agreed with the necessity to cover
areas of the Site that presented an unacceptable risk of dermal
contact.
However, the Companies vigorously contested EPA's
proposal to construct an eight-acre RCRA cap and to excavate
materials for emplacement under the cap.
The Companies argued in
their August 23, 1988 comments that the capping and associated
excavation, allegedly intended to protect against risks of
ingestion of bedrock groundwater, consumption of fish from the
-------
-4-
because the risks identified by EPA were, in fact, non-existent.
The Companies pointed out that the risk assessments in the
Agency's EA were based on erroneous assumptions, incorrect
calculations, and highly unrealistic exposure scenarios.
On september 22, 1988, EPA Region I issued a Record of
Decision ("ROD I") for the Site.
The 1988 ROD divided the
remedial actions at the Site into two "operable units"
("management of migration" and "source control"), and specified a
.
management of migration (operable unit 1) remedy.
That remedy
consisted of collection and treatment of contaminated leachate
seeps, extraction and treatment of contaminated groundwater from
the sand and gravel aquifer above bedrock, monitoring, and
establishment of institutional controls in the form of
implementation and enforcement of Town of Springfield Ordinance
88-2 to prohibit groundwater use at, and restrict access to, the
Site.
The Agency declared that the remedy selected in ROD I was
"protective of human health and the environment [and] attains
Federal and State requirements that are applicable or relevant
and appropriate.
"
. ..
EPA explained in ROD I that it had refrained from
specifying source control action (~, the capping proposed
-------
-5-
the proposed cap did not adequately address lateral groundwater
flow through buried waste or the potential for bedrock
groundwater contamination.
ROD I at 11.
EPA and the state
agreed, therefore, that source control action would be deferred
pending additional studies of the feasibility of isolating waste
materials from groundwater "in order to determine if such
diversion would decrease the time needed to attain groundwater
cleanup levels and eliminate the risks associated with the
.
contamination of bedrock."
ROD I at 25.
In the responsiveness summary accompanying the 1988
ROD, EPA refused to respond to the Companies' comments
challenging the alleged risks of inhalation of landfill gases and
ingestion of bedrock groundwater.
The Agency took the position
that those comments were aimed at the necessity for source
control action and, thus, responses were not warranted.
Nonetheless, the 1988 ROD incorporated as official Agency
findings the existence of the inhalation and ingestion risks
which the Companies had challenged.!1
V On May 19, 1989, Emhart and Textron filed a Petition for
Reconsideration of the 1988 ROD, asking inter alia, that the
Agency delete from the ROD references to the inhalation and
ingestion risks and respond to the comments concerning those
risks. Approximately eight months following the filing of the
2S-page Petition for Reconsideration, EPA responded with a one-
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-6-
Pursuant to an Administrative Consent Order ("ACO")
executed by the Regional Administrator on March 10, 1989, Emhart
and Textron retained Remcor to perform the studies required by
the 1988 ROD.
Those studies, which cost approximately $2
million, culwinated in the submission of a draft final Focused
Feasibility study Report ("FFS") on June 7, 1990.
That report
described the site as consisting of three areas of major waste
disposal activity that had occurred during the 1947-1968 time
frame: an area in the southwest portion of the site, referred to
as Waste Area 4, in which solid waste and oily wastes had
apparently been disposed in trenches dug into native till soil:
an area known as Waste Area 3, consisting of approximately 3.0
acres on the eastern side of the Site, in which approximately
72,000 cubic yards of solid and oily wastes had been disposed of
in a~former ravine: and an area further to the north on the
eastern side of the Site, known as Waste Area 2, in which wastes
had also apparently been disposed in a former ravine.
Based on its evaluation of the contaminants found in
each of these areas and other site conditions, Remcor confirmed
its earlier conclusion that the site does not pose an
AI (. . . continued)
page letter stating that it was not obligated to respond to a
-------
-7-
unacceptable risk of inhalation of landfill gases or an
unacceptable risk of ingestion of bedrock groundwater.
with
respect to inhalation risks, Remcor determined that the plausible
maximum inhalation risk (95th percentile) is within EPA's
acceptable risk range and, in fact; below the point of departure
specified in the National contingency Plan (WNCpW).
with respect.
to alleged bedrock groundwater ingestion risks, Remcor concluded
that: (1) Waste Area 4 is not a source of contaminants of concern
(i.e., chlorinated ethenes) in bedrock groundwater because those
contaminants are not found in Waste Area 4 and water within Waste
Area 4, itself, does not exceed any Safe Drinking Water Act
maximum contaminant levels (WMCLsW) for contaminants of concern
identified in the EAi (2) Waste Area 2 does not contribute
contamination to, or require source control action to mitigate
contamination of, bedrock groundwater because the majority of
infiltrating surface water and groundwater flowing through Waste
Area 2 discharges at an eastern leachate seep (LSE04) which will
be collected and treated in Operable Unit 1, and groundwater
beneath and in the vicinity of Waste Area 2 does not exceed MCLs
(as evidenced by monitoring wells MW-46S, 48T, 48B, 42S, and
42T): and (3) Waste Area 3, which is a source of chlorinated
-------
.-8-
groundwater because (i) the majority of water flowing through and
from Waste Area 3 is either discharging at an eastern leachate
seep (LSE03) (78 percent) or into till that flows into a sand and
gravel unit (six percent) which discharges to western leachate
.
seeps that will be collected and treated during Operable Unit 1,
(ii) a minor component (16 percent) of ~ater flowing from Waste
Area 3 is disCharging into till and thence to weathered bedrock
beneath the eastern outslopes; and tha~ groundwater cannot be
.
developed because of topographical constraints and institutional
controls, and (iii) the bedrock groundwater to the east of the
former landfill is discharging into the Black River, with no
detectable levels of VOCs measured in water samples from the
river.
Remcor concluded in the FFS that, after implementation
of the management of migration operable unit, the only risk posed
by the Old Springfield Landfill Site is a risk of dermal contact
with surficial soils in certain areas of the Site.
Accordingly,
Remcor concluded that all site risks to public health and the
environment, remaining after implementation of ROD I, could be
eliminated by covering (as opposed to capping) surficial
contaminated soils presenting an incremental lifetime cancer risk
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-9-
used by EPA.
In accordance with the requirements of the ACO, the
FFS prepared by Remcor set forth a number of alternative remedial
action plans, including fencing the Site, covering surficial
contaminated soils, and installing a source control well within
Waste Area 3.Y
On July 9, 1990, EPA Region I released its Proposed
Plan for the source control operable unit for the Old Springfield
Landfill Site.
In the document announcing the Proposed Plan, the
.
Agency explained that it had rejected the risk assessment (and
other conclusions) set forth in Remcor's FFS, and was relying,
instead, on the 1988 Endangerment Assessment which the Companies
had challenged in extensive comments, responses to which were
never provided by EPA.
Thus, the Agency continues to maintain
that the Site presents an unacceptable risk of inhalation of
landfill gases and an unacceptable risk of ingestion of bedrock
groundwater.
On this basis, EPA has now proposed a source
control remedial action consisting of installation of a multi-
layer RCRA cap over Waste Areas 2, 3 and 4: construction of
Y In a draft FFS submitted to EPA on April 12, 1990, Remcor
recommended source control remedial action consisting of fencing
the site, installation of a source control well, and covering
contaminated soil areas. EPA instructed Remcor to delete the
recommendation from the draft final FFS submitted on June 7,
1990, and that recommendation-does not appear in the final
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-10-
active and passive gas collection systems; installation of french
drains; stabilization of the eastern outslopes of Wastes Areas 2
and 3; installation of source control wells; institutional
controls to restrict future site use; and five-year reviews of
the effectiveness of the remedy.
EPA announced further that it
is considering the complete excavation and disposal of Waste Area
2 rather than capping and sideslope stabilization in this area,
because excavation, in the opinion of the Agency, may prove to be
less expensive than stabilizing and capping the area.
In these comments, the Companies reiterate their
position that the site poses no unacceptable risk of inhalation
of landfill gases or ingestion of bedrock groundwater, and that,
after implementation of Operable Unit 1, the only risk posed by
the Site is a risk of dermal contact with surficial soils in
certain areas.
On this basis, the Companies believe that source
control actions, including RCRA capping, aimed at preventing the
non-existent inhalation and ingestion risks are unwarranted.
Furthermore, the Companies maintain that, in the absence of
inhalation and ingestion risks, there is no requirement under
CERCLA for installation of a RCRA-compliant cap.
Finally, in the
event that the Agency insists on the installation of a RCRA-
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-11-
Companies believe that the Proposed Plan requires refinements
which would be equally protective and more cost-effective and,
therefore, consistent with CERCLA and the NCP.
II.
EPA'S ISSUANCE OF THE PROPOSED PLAN AND ANY SUBSEQUENT ROD
VIOLATES THE COMPANIES' PROCEDURAL RIGHTS UNDER CERCLA, THE
ADMINISTRATIVE PROCEDURE ACT. AND DICTATES OF DUE PROCESS
On May 19, 1989, Emhart and Textron filed with the
Regional Administrator, EPA Region I, a "Petition for
Reconsideration of ROD Issued 9/22/86 and for Supplementation of
Administrative Record."
In that document, which is incorporated
herein by reference as part of these comments, the Companies
sought: (1) amendment of ROD I to strike therefrom the Agency
findings regarding the alleged inhalation and ingestion risks
with respect to which the Companies filed comments not addressed
by EPA; (2) a response to the comments filed by the Companies on
August 23, 1988; and (3) supplementation of the Administrative
Record for the site.
The Companies argued that, in adopting ROD I without
responding to the Companies' comments on the risk assessments,
EPA violated CERCLA S 113(k) which requires that EPA "provide for
the participation of interested persons, including potentially
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-12-
Record," and which further provides, inter alia, that public
participation must include "a response [by EPA] to each of the
significant comments, criticisms, and new data submitted in
written and oral presentations."
Moreover, the Companies argued
that EPA's adoption of ROD I without responding to the Companies'
comments on the risk assessments violated CERCLA ~ 117(b) which
provides that a final remedial plan .shall be accompanied by a
discussion of any significant changes (and the reasons for such
changes) in the proposed plan and a response to each of the
significant comments, criticisms, and new data submitted in
111111
written and oral presentations. . .."
The Companies further pointed out in their Petition for
Reconsideration of ROD I that ~he CERCLA public participation
requirements impose on EPA obligations greater than those imposed
by the rulemaking procedures in section 553 of the Administrative
Procedure Act ("APA"), 5 U.S.C. ~ 553; and that courts construing
the APA have held that the notice and comment procedures therein
require that "there must be an exchanae of views, information and
criticism between interested persons and the Agency," and that "a
dialogue is a two-way street: the opportunity to comment is
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- -13-
raised by the public."
Home Box Office. Inc. v. Federal
communications Commission, 567 F.2d 9, 35-36 (D.C. Cir. 1977).
Additionally, in their Petition for Reconsideration of
ROD I, the Companies argued that EPA's failure to respond to
their criticisms of the ROD I risk assessments violated the
dictates of due process.
As the court stated in United states v.
Rohm & Haas Co., 669 F. Supp. 672 (D.N.J. 1987), the
Administrative Record under CERCLA must be built on "an exchange
of opinions and comments by experts and informed citizens. .."
Id. at 681.
Because the EPA now bases its proposed source control
plan and the forthcoming ROD II operable unit on the very same
1988 risk assessment challenged by the Companies, the Agency has
compounded its violations of the companies' procedural rights
and, indeed, has committed additional violations of those rights.
As set forth above, EPA responded to the Companies' Petition for
Reconsideration of ROD I with a terse letter to the effect that
it had no obligation to respond to a Petition for Reconsideration
of a ROD.
But, because the Agency adopted the risk assessments
challenged by the Companies, it obviously disagreed with the
Companies' comments.
By not providing the bases for its
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-14-
exchanqe of views, information and criticism" and the exchanqe of
opinions and comments by experts" which the courts have required.
In their Petition for Reconsideration of ROD I, the
Companies also pointed out that numerous documents were withheld
from the Administrative Record on RbD I, and requested that the
Administrative Record be supplemented to include "all items
developed and receiv~d" by the Agency on ROD I, including
documents specifically listed in the Petition for Reconsideration
of ROD I.
.
EPA failed to supplement the Administrative Record, as
requested, and has thus deprived the Companies of the opportunity
to fully participate in the development of the Administrative
Record for ROD II.
The Companies reiterate their request for
supplementation of the Administrative Record and contend that
adoption of ROD II with an incomplete administrative record would
violate the Companies' procedural rights.
Finally, with respect to procedural violations by the
Agency, the Companies have recently learned that EPA officials
and/or officials of the state of Vermont met with persons
interested in the proposed Plan for ROD II and distributed copies
of or described the Proposed Plan to those persons prior to the
distribution of the plan to the Companies and other members of
the public.
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-15-
no idea of the content of the discussions at the meeting, and can
find no minutes of the meeting in the Administrative Record.
The
Companies have also learned that EPA and Vermont officials met
with officials of the Town of Springfield and that elements of
the Proposed Plan were discussed at that meeting.
Again, the
Companies were not advised of that meeting, have no idea of the
substance of the discussions at that meeting, and can find in the
Administrative Record no minutes of that meeting.
The Agency
.
engaged in this course of conduct despite the fact that it had
declined to meet with the Companies, even after the Companies had
suggested that members of the public be advised of and invited to
attend such a meeting and further suggested that minutes of such
a meeting be included in the Administrative Record.
By
proceeding in this fashion, EPA has further violated the
Companies' procedural rights and has tainted the adoption of
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~16-
III. EPA HAS NOT DEMONSTRATED ANY SITE RISKS BEYOND DERMAL
CONTACT RISKS AND, THUS, PROPOSED SOURCE CONTROL ACTIONS
AIMED AT MITIGATING LANDFILL GAS INHALATION RISKS AND
BEDROCK GROUNDWATER INGESTION RISKS ARE ARBITRARY AND
CAPRICIOUS
A.
EPA May Not Rely on the 1988 Endangerment Assessment to
Support Source Control Actions Aimed at Mitigating Alleged
Inhalation and Ingestion Risks
As set forth above, despite the Companies' unrebutted
comments to the June, 1988 Endangerment Assessment and despite a
.
revised risk assessment presented by Remcor in the June, 1990
FFS, EPA has concluded in the Detailed Evaluation Memo that *the
1988 EA is the only appropriate baseline risk assessment
acceptable for use in evaluating source control alternatives for
the Old Springfield site.*
Thus, EPA has once again stated that
risks which must be addressed by the Source Control Operable Unit
include *ingestion of contaminated groundwater* and *inhalation
of contaminants in landfill gas..
The preceding discussion and the Companies' Petition
for Reconsideration of ROD I, incorporated herein by reference,
demonstrate that EPA has violated the Companies' procedural
rights by incorporating contested risk assessment findings in ROD
I and by now relying on those same findings to support the source
control ROD II.
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- -17-
participation requirements of CERCLA and the dictates of due
process, rely on the contested 1988 EA to support any source
control action aimed at mitigating or eliminating the alleged
risks of inhalation of landfill gases and ingestion of bedrock
groundwa ter . ~I
Equally important as the procedural flaws in EPA's
reliance on the 1988 EA is the fact that the 1988 EA does not
demonstrate any unacceptable risks associated with inhalation of
.
landfill gases or ingestion of bedrock groundwater.
As the
Companies explained in detail in their August 23, 1988 comments,
the 1988 EA was based on erroneous assumptions, incorrect
calculations, and highly unrealistic exposure scenarios.
with respect to the alleged risk of inhalation of
landfill gases, the 1988 EA failed to consider the
characteristics of the municipal solid waste/soil mixtures on the
Site (by using an unrealistic low fraction of organic carbon or
.FOC. value), overstated the emission source area (by using
maximum contaminant concentrations found anywhere in the soil on
~I The proposed source control actions aimed at eliminating or
mitigating those alleged risks include, according to EPA's
documents: impermeable capping of Waste Areas 2, 3, and 4~
installation of passive and active gas collection systems in
Waste Areas 2, 3, and 4~ and covering of the eastern outslopes of
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.-18-
the site as representative of the entire Site), exaggerated the
rate of landfill gas emissions (by assuming an emission rate
which, if accurate, would have resulted in the depletion of the
co~t~m~"ants of concern on the site within a matter of hours or
days), and overstated exposure possibilities (by using an
exposure assumption based on Site residents remaining outside and
breathing every breath from birth to age 70 in the vicinity of
the highest contaminant levels found anywhere at the site).
A
.
detailed discussion of these issues is found at page 5 and pages
14-17 of the August 23, 1988 comments and on page 5 and pages 19-
21 and Attachment 1 of the August 23, 1988 Remcor report filed
with and incorporated by reference into those comments.
With respect to the alleged risk of ingestion of
bedrock groundwater, the 1988 EA used flawed models which
overstated the amount of contaminants predicted to leach from
wastes into shallow groundwater, overstated the amount of
contaminants predicted to reach bedrock groundwater, ignored
fundamental environmental transport and fate processes (including
dilution, dispersion and adsorption), and ignored the fact that
Site data showed upward vertical gradients indicating that the
bedrock groundwater allegedly threatened was actually flowing
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-19-
those areas by contamination in overlying aquifers).
A detailed
discussion of these issues is set forth on pages 4-5 and pages 7-
13 of the companies' August 23, 1988 comments, as well as pages
3-5 and pages 11-19 of the August 23, 1988 Remcor report
transmitted with and incorporated by reference into those
Comments.
Field studies conducted by Remcor and reported in the
FFS demonstrate that a number of the assumptions and conclusions
in the 1988 EA and RI were unquestionably erroneous.
For
example, Remcor had predicted that the FOC value used in the 1988
EA (2.3 X 10-5 grams per gram [gig]) was unrealistically low, and
confirmed during its field studies a much higher actual FOC value
(at least 9.37 X 10-3 gig) .!f
Because FOC value influences both
the rate of VOC emissions to ambient air and the degree of
leaching of contaminants into bedrock groundwater, Remcor has
confirmed that the 1988 EA overstated both inhalation and
ingestion exposure point concentrations and risks.
Additionally,
through extensive groundwater monitoring and hydrogeologic
modeling, Remcor confirmed the presence of the upward vertical
gradients and otherwise confirmed that the 1988 EA overstated by
if FOC data developed by Remcor are presented in Tables 10 and
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-20-
a significant degree the amount of contamination in bedrock
groundwater east of the former landfill.
For this additional
reason -- the acquisition of new data (in studies required by
EPA) which contradict assumptions in the 1988 EA and findings in
the 1988 RI -- .~e 1988 EA may not" be relied on to support
proposed source control actions aimed at mitigating alleged
inhalation and ingestion risks.
B.
Remcor's Revised Risk Assessment Shows the Absence of
Ingestion and Inhalation Risks and Was Improperly Rejected.
by EPA
since the 1988 EA was published, a number of conditions
relating to the site and to risk assessments, in general, have
changed dramatically.
For example, all residents of the mobile
home park have been relocated; and the Companies (and the Town of
Springfield) have agreed to implement ROD I (including collection
and treatment of contaminated leachate and contaminated
groundwater and implementation of institutional controls
restricting site access and water use).
In addition, through
extensive sampling and modeling, Remcor has gained a thorough
understanding of site conditions and has obtained data which
contradict data and assumptions underlying the 1988 EA.
Finally,
EPA has issued several new risk assessment gUidance documents
which undermine continued reliance on the 1988 EA.
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-21-
the foregoing and the fact that EPA refused to respond to the
Companies' comments on the 1988 EA, Remcor included in the FFS a
revised risk assessment.
The Companies acknowledge that certain data obtained by
Remcor during the FFS field studies do not support portions of
the Companies' 1988 comments concerning contamination of bedrock
groundwater.
However, Remcor's risk assessment shows that the
site does not present unacceptable risks of inhalation of
landfill gases or unacceptable risks of ingestion of bedrock
groundwater.
with respect to the ingestion of bedrock
groundwater, Remcor monitored contaminant concentrations and
groundwater levels in Waste Areas 2, 3, and 4 and in other areas
of the Site, conducted aquifer pumping tests and other tests
aimed at understanding groundwater flows at the Site, and
employed modeling to arrive at a hydrogeologic budget, conceptual
groundwater flow model, and mass balance for chlorinated ethenes
(i.e., the principal threat identified in the EA).
Remcor's 1990 FFS contains, inter alia, the following
significant conclusions: (1) a highly permeable sand and gravel
unit which underlies much of the Site acts as a -drain- conveying
contaminated shallow groundwater to the western leachate seeps
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-22-
management of migration operable unit; (2) the majority of the
water flowing through and from Waste Area 4 (which does not
exceed MCLs) is collected and conveyed by this natural "drain" to
the western leachate seeps; (3) the remaining water flowing from
Waste Area 4 as well as some of the water percolating into till
from Waste Area 3 also is collected and conveyed by the sand and
gravel "drain" to the western leachate seeps; (4) the
groundwater, including bedrock groundwater, beneath the sand and
gravel "drain" lies within formations less permeable than the
sand and gravel formation and, thus, flows upward into the sand
and gravel "drain" and is conveyed to the western leachate seeps;
(5) as a result of the foregoing factors, the bedrock groundwater
underlying much of the site is uncontaminated and will not become
contaminated; (6) to the extent that water flowing from Waste
Area 4 and from Waste Area 3 is not collected by the underlying
sand and gravel "drain,. a majority of that flow emanates at
eastern leachate seep LSE03, which will be collected and treated
during implementation of the ROD I management of migration
operable unit; (7) the vast majority of the water flowing through
and from Waste Area 2 emanates at eastern seep LSE04 which will
be collected and treated during implementation of the ROD I
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-23-
water from Waste Area 2 flows downward toward bedrock, such flow
has been found to be uncontaminated as is evidenced by Well 49S
screened immediately below Waste Area 2 and Wells 42S and 42T
installed downslope of Waste Area 2 and screened at the
lacustrine silt/deltaic sand interface and within the till,
respectivelYi (9) to the extent that any waters from Waste Area 3
or Waste Area 2 are not collected by the sand and gravel #drain"
or do not emanate at the eastern seeps, that water flows into
.
bedrock groundwater underlying the steep eastern outslopes of the
sitei (10) the bedrock groundwater underlying the steep eastern
outslopes of the Site, which does contain chlorinated ethenes in
excess of MCLs, is not capable of development for groundwater
usage because of topographical constraints (and, in any event,
usage of that water is restricted by institutional controls
required by EPA in ROD I)i (11) the bedrock groundwater
underlying the steep eastern outslopes of the Site is discharging
into the Black River, which is not used as a water SUPplYi and
(12) no detectable levels of VOCs have been found in sampling of
water from the Black River.
EPA apparently has accepted each of
these conclusions (Ebasco, July 1990).
In view of the foregoing, Remcor concluded that the
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-24-
The only bedrock groundwater threatened by the site lies
underneath the steep eastern outslopes which is undevelopable
because of topographical constraints and institutional controls
and discharges into the Black River.
There is no completed
exposure pathway and no potential receptors of the contamination
in the only contaminated bedrock groundwater on Site.
And, in
the absence of a completed exposure pathway and receptors, there
can be no unacceptable risk of ingestion.ll
.
with respect to the risks of inhalation of landfill
gases, Remcor's revised risk assessment followed essentially the
same procedure and model used in the 1988 EA, making corrections
consistent with Site data obtained during the field studies and
consistent with EPA guidance documents published following the
1988 EA.
First, Remcor determined VOC concentrations
representative of the Site by using the 95th percentile of the
arithmetic mean of all VOCs found in the upper 4 1/2 feet of the
11 Indeed, EPA itself has recognized that, in such a situation,
there is an absence of ingestion risk and MCLs are not applicable
or relevant and appropriate requirements under CERCLA. In EPA's
'CERCLA Compliance with other Laws Manual,' issued in August of
1988 (EPA/540/G-89/006), the Agency stated, 'MCLs are generally
not appropriate for site-specific circumstances where a well
would never be placed and groundwater would thus never be
consumed (e.g., a twenty-foot strip of land between the toe of a
landfill and a river, if there is no surface water contamination
resulting from man-made ground-water contamination at the Site).-
~ at 1-68, -69.
-------
-25-
Site (utilizing over 100 data points).!1
Second, Remcor
calculated the voe emission rate employing the same Thibodeaux
model used in the 1988 EA, but using a conservative Foe value of
9.37 X 10-3 (.937%), based on actual Foe data of the soil/waste
.
matrix within Waste Area 3 at the Site.!1
Third, Remcor
employed the Near Field Box Model, the same model used by EPA in
the 1988 EA, to estimate concentrations of voes in the air at the
nearest receptor.
Fourth, despite the fact that there are no
.
residents remaining on-site, Remcor used a worst-case scenario of
residential exposure and assumed that the nearest receptor would
be residing o~-site.
Fifth, Remcor assumed an exposure duration
of 30 years in predicting the Reasonable Maximum Exposure
!I Use of the 95th percentile of the arithmetic mean, as
opposed to the maximum voe concentrations used in the 1988 EA, is
consistent with EPA's Reasonable Maximum Exposure ("RMEtt)
Scenario as defined in the Agency's Risk Assessment Guidance for
Superfund ("RAGS"), published in December of 1989.
!I As Remcor had postulated in comments on the 1988 EA, the Foe
value used therein (2.3 X 10-5 or .0023%) was, indeed,
unrealistically low. Moreover, the actual Foe used in Remcor's
recalculation of voe emissions is also conservative. Had Remcor
used Foe values assumed by EPA Region I at other sites, such as
the 5% FOe value used at the Keefe Environmental Services Site in
Epping, New Hampshire, the resulting inhalation risk wouid have
-------
C,i > .:':.
( I/j/!/)/
-26-
inhalation risks.~1
Sixth, Remcor established an appropriate
inhalation dose using ventilation assumptions from the EPA
Exposure Factors Handbook (Versar, July 1989).
Seventh, Remcor
utilized inhalation carcinogenic potency factors for all VOCs,
deriving such factors from EPA's Integrated Risk Information
System ("IRIS") database.
Eighth, Remcor evaluated potential
carcinogenic effects, consistent with the RAGS published by EPA
in 1989, by averaging over a 70-year lifetime the dose received
.
by an individual during a 30-year exposure period.
The result of
Remcor's revised risk assessment is that the plausible worst case
or RME risk of inhalation of landfill gases is 8.89 X 10-7, which
is within the acceptable risk range and, in fact, below the point
of departure specified in the NCP under CERCLA.
Thus, Remcor's
revised risk assessment demonstrates that the site does not pose
an unacceptable risk of inhalation of landfill gases.
Notwithstanding the foregoing, EPA Region I has
rejected Remcor's revised risk assessment, stating in the
~ The 30-year exposure is consistent with the RAGS published
by EPA in December of 1989 and the Exposure Factors Handbook
published by EPA in July of 1989. The 30-year value set forth in
the Exposure Factors Handbook is based on a 1983 Bureau of the
Census survey which included a sample of 18,825 households. The
1988 EA assumed residential exposure to an individual for a
period of 70 years, which is no longer consistent with EPA's RME
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-27-
Detailed Evaluation Memo that "the 1988 EA is the only
appropriate baseline risk assessment acceptable for use in
evaluating source control alternatives for the Old Springfield
Landfill."
EPA set forth three reasons for its rejection of
Remcor's revised FFS.
First, according to the Agency, "there was
no requirement for (the Companies] to perform and submit a new
baseline risk assessment as part of the FFS."
Detailed
Evaluation Memo at 2.
Second, the Agency stated that it had
advised the Companies that any revised risk assessment "must be
based on validated results" and "there were no validated results
of the FFS which suggested a need to revise the Risk Assessment."
Id.
Third, the Agency stated that Remcor's revised risk
assessment "was not prepared according to the E;PA Region I
Supplemental Guidance for Risk Assessment."
l5L.
EPA's rejection of Remcor's revised risk assessment on
these grounds is arbitrary and capricious.
Whether or not the
Companies were required to submit a revised risk assessment is
wholly irrelevant, given the facts that the Agency refused to
respond to the Companies' comments on the 1988 EA, that Remcor
obtained data during the field investigations (such as FOC data)
which shows the 1988 EA to have been based on faulty assumptions,
-------
-- 28-
assessment guidance documents published by EPA Headquarters
following issuance of the 1988 EA.lil
EPA's claim that "there were no validated results of
the FFS which suggested a need to revise the risk assessment" is
similarly irrational.
.
If EPA is referring to the fact that air
monitoring data collected by Remcor were not validated by
Contract Laboratory Program ("CLP") protocols, the Agency appears
to be forgetting that previous EPA air monitoring data were
invalidated because of significant contamination in blank
samples.
As a result, the 1988 EA was not based on actual air
monitoring data validated by CLP protocols.
Rather, the 1988 EA
was based on modeling as described above: and in the FFS Remcor
merely corrected the model using the same CLP validated soil data
used in the 1988 EA, and following EPA Headquarters' guidance
documents published since issuance of the 1988 EA.
The issue
properly before the Agency at this time is not whether the Site
I
presented risks requiring source control remedial action in 1988,
/
but whether the site at this time requires source control
/
~ Furthermore, the companies~nsistentlY advised EPA that
they would be submitting a revi$ed risk assessment and the only
issue of contention between the' Companies and EPA was whether
that revised risk assessment wduld be included in the FFS
document, itself, or in a sepa~ate document filed with public
comments. I
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-29-
remedial action at an estimated net present value cost of as much
as $9.6 million (Ebasco, July 1990, at 41).
Finally, the fact that Remcor's revised FFS may be
inconsistent with an EPA Region I Supplemental Guidance for risk
assessment is not a reasoned basis for rejecting the Remcor risk
assessment.
The EPA Region I Supplemental Guidance was not
promulgated in accordance with notice and comment rulemaking
proceedings, and the Agency may not rely on the mere existence of
.
that document to reject Remcor's risk assessment.
Moreover, as
discussed above and in greater detail below, the Remcor revised
risk assessment is consistent with EPA Headquarters guidance
documents published after the Region I Supplemental Guidance for
Risk Assessment.
The arbitrary nature of the Region's rejection of the
Remcor revised risk assessment is shown by examination of the
alleged "critical deviations from EPA Guidance" discussed in the
Detailed Evaluation Memo.
First, it is stated that Remcor
changed the current use scenario from residential, which was the
assumption in the 1988 EA, to casual trespasser.
In fact, the
current use of the Site is not residential.nl
More
~ All residents of the mobile home park have been relocated
and, contrary to EPA's assertion, the owner of the property does
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-30-
importantly, this issue is a -red herring- because the worst-case
inhalation risk calculated by Remcor assumes a residential
scenario, and that risk is within the acceptable range and below
the point of departure specified in the NCPa
The second alleged deviation from EPA Region I Guidance
mentioned in the Detailed Evaluation Memo is that Remcor's risk
assessment assumes implementation of Operable unit 1, includin~
successful implementation of institutional controls.
Detailed
Evaluation Memo at 2-3.
EPA stated that the role of the baseline
risk assessment is to address the risk associated with a site in
the absence of any remedial action or control, including
institutional controls, and cited in support thereof a statement
in the preamble to the NCPa
In the first place, Remcor's revised
risk assessment relating to inhalation of landfill gases does not
take into account successful implementation of institutional
controls or any other aspect of Operable Unit 1.
Similarly,
Remcor's conclusion about the absence of bedrock groundwater
u'(...continued)
not reside on-site, as is evidenced by the fact that his
residence is outside the fence line described by EPA in the
Proposed Plan. EPA's statement in the Detailed Evaluation Memo
that -present use scenarios include those that have a present
potential of occurring as well as those known to occur- is
inconsistent with the RAGS discussion of current use versus
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-31-
ingestion risks is based on the fact that the bedrock groundwater
exceeding MCLs on the eastern outslopes of the Site is
undevelopable because of topographic constraints, as well as
institutional controls.
Moreover, the NCP Preamble language
cited in the Detailed Evaluation Memo refers to the impropriety
of assuming institutional controls in a risk assessment at a site
where no such controls are in place.
At the Old Springfield
.
Landfill Site, however, EPA already has ordered implementation of
institutional controls as well as a number of other remedial
measures (including collection of contaminated leachate seeps and
VOC emissions associated therewith).
As stated previously, the
issue now before the Agency is whether additional remedial action
and the expenditure of millions of dollars is warranted to
alleviate Site risks not addressed by the management of migration
operable unit; and it would be arbitrary and capricious to make
that decision in disregard of the implementation of Operable
Unit 1.
The third alleged .critical deviation from EPA
Guidance. mentioned in the Detailed Evaluation Memo is that, in
calculating the risk of inhalation of landfill gases, Remcor used
a trichloroethylene C.TCE.) inha~ation cancer potency factor that
-------
-32-
(WIRISW) pending further review.
At the time of submission of
the FFS, however, the TCE potency factor had not been withdrawn
from the IRIS database.
More importantly, according to EPA's
Risk Assessment Guidance for Superfund (nRAGsn) published in
December, 1989, in the absence of IRIS data, the next hierarchial
source to be used as a basis for a carcinogenic potency factor is
the Health Effects Assessment (nHEAn) Summary for the contaminant
of concern.
The TCE carcinogenic potency factor incorporated in
Remcor's inhalation risk assessment is identical to that reported
in the most recent Health Effects Assessment Summary Tables for
TCE (EPA, January/April 1990).
The fourth alleged Wcritical deviation from EPA
Guidancen asserted by EPA Region I concerns the appropriate
exposure duration to assess carcinogenic effects.
Detailed
Evaluation Memo at 3.
As EPA correctly noted, Remcor used 30
years and 9 years as the plausible maximum and average exposure
durations under the residential scenario, consistent with the
current RAGS and the EPA Exposure Factors Handbook published in
July, 1989.
EPA apparently believes, howeve~, that Remcor failed
to average doses over a 70-year lifetime for carcinogenic
effects.
-------
-33-
assessment.
Remcor did, in fact, average doses over a 70-year
lifetime, as is shown in Appendix E-2 to the FFS.
The final alleged devia~ion from EPA Region I Risk
Assessment Guidance concerns Remcor's use of the 95% upper
confidence limit to derive exposure point concentrations in the
inhalation risk assessment.
The use of the 95% upper confidence
limit is entirely consistent with the RAGS, published in December
of 1989.
Region I, however, suggests that Remcor should have
used the 95% confidence limit as well as the maximum levels of
contaminants in its inhalation risk assessment.
This is
inconsistent with the EPA Headquarters RAGS.
That document
states that decisions regarding the need for remedial action to
adequately protect public health are to be based on reasonable
maximum exposures (RMEs), not on maximum exposures as suggested
in the Detailed Evaluation Memo.
The RAGS further states that
W[b]ecause of the uncertainty associated with any estimate of
exposure concentration, the upper confidence limit (~, the 95%
upper confidence limit) on the arithmetic average [contaminant
concentration] will be usedw as wa reasonable estimate of the
concentration likely to be contacted over time.w
RAGS at 6-19
and 6-20.
Additionally, the RAGS states that, although a risk
-------
-34-
medium as the exposure concentration for a given pathway as a
screening approach to place an upper bound on exposure.
. . , if
a screening level approach suggest~ a potential health concern,
the estimates of exposure should be modified to reflect more
probable exposure conditions..
RAGS at 6-25.
Not only was
Remcor's use of the 95% upper confidence limit entirely
consistent with the EPA RAGS, but also it was entirely rational-
based on the fact that over 100 soil data points were averaged in
the analysis.
It would be unreasonable to assume that the
maximum contaminant levels found anywhere on the Site are
representative of the entire site in the face of such a
significant amount of data to the contrary.
In summary, EPA Region I's rejection of Remcor's
revised risk assessment is arbitrary and capricious.
Remcor's
revised risk assessment, performed consistent with Site data and
EPA Headquarters guidance documents, shows that the Site poses no
unacceptable risk of inhalation of landfill gases and that there
is no unacceptable risk of ingestion of bedrock groundwater due
to the lack of a completed exposure pathway.
Moreover, it is not
the Companies' burden to demonstrate the absence of risk, but
EPA's burden to demonstrate the presence of risk sufficient to
justify the proposed remedial action.
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-35-
demonstrate the existence of inhalation or bedrock groundwater
ingestion risks and, in any event, EPA may not rely on that
document in light of its failure t? respond to the Companies'
comments thereon, changed site circumstances, new data, and
recent EPA guidance documents.
C.
There is No Public Health Risk Rationale for Placement of a
Low Permeability Cap on Waste Areas 2, 3, and 4 or for Gas
Collection Systems or for Covering the outslopes
A number of the source control measures proposed by EPA
are premised on the necessity of mitigating unacceptable risks of
inhalation of landfill gases and unacceptable risks of ingestion
of bedrock groundwater.
For example, EPA apparently is taking
the position that placement of a RCRA-compliant cap on Waste
Areas 2, 3, and 4 is necessary to mitigate the risks of ingestion
of bedrock groundwater as well as the risks of inhalation of
landfill gases.
Additionally, the Agency has stated that passive
and active gas collection systems are necessary to mitigate the
risks of inhalation of landfill gases.
SFS at 17, 28, and
Appendix C.
Also, according to the Agency, the placement of a
soil cover on the outslopes of Waste Areas 2 and 3 is necessary
to mitigate risks of inhalation of landfill gases.
(Appendix C).
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-36-
As set forth above, however, EPA has not demonstrated
that the site poses unacceptable risks of bedrock groundwater
ingestion or landfill gas inhalation.
Accordingly, to the extent
that these source control remedial measures are premised on the
existence of non-existent risks, their selection in the ROD would
be arbitrary and capricious.
.
IV.
IN THE ABSENCE OF RISK, THE CONSTRUCTION OF A MULTI-LAYER
RCRA-COMPLIANT CAP CANNOT BE JUSTIFIED AS AN "APPLICABLE OR
RELEVANT AND APPROPRIATE REOUIREMENT" UNDER CERCLA
A.
At Most, Capping is an Action-Specific ARAR Which is not
Triggered Unless Necessary to Alleviate Risk or to Achieve a
Chemical-Specific ARAR
In the Detailed Evaluation Memo, EPA has stated that
placement of a low permeability cap over Waste Areas 2, 3, and 4
is required under CERCLA because RCRA hazardous waste landfill
closure requirements are "applicable or relevant and appropriate
requirements" ("ARARs") under CERCLA.
EPA has misinterpreted the
statute as well as its own regulations and guidance documents.
Section 121(d) of CERCLA, entitled "Degree of Cleanup,"
provides that "remedial actions
. . .
shall attain a degree of
cleanup of hazardous substances. . . which assures protection of
human health and the environment."
In addition, CERCLA
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-37-
that will remain on-site at the completion of the remedial
action, that the cleanup must comply with standards,
requirements, criteria, etc. that are Wlegally applicable to the
hazardous substance. . . or relevant and appropriate under the
circumstances of the release or threatened release of such
hazardous substance. . ..-
(Emphasis added.)
As discussed above, EPA has declared that the remedia!
measures required by Operable Unit 1 protect public health and
the environment.
After implementation of Operable Unit 1,
moreover, no remedial action other than prevention of dermal
contact with surficially contaminated soils has been demonstrated
to be necessary to protect human health and the environment. ill
The question remaining, therefore, is whether, in the absence of
a risk to public health and the environment, a RCRA-compliant cap
is required as an ARAR.
The NCP and EPA guidance documents establish three
categories of ARARs: (1) chemical-specific ARARs which are
usually health or risk-based numerical values or methodologies
which, when applied to site-specific conditions, result in the
UI A RCRA-compliant cap is not required to mitigate the risks
of dermal contact with surficially contaminated soils. Rather,
as stated in the Companies' 1988 comments and in the Remcor FFS,
and as has often been recognized by EPA, a soil cover is
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-38-
establishment of numerical values representing acceptable amounts
of a chemical that may be found in or discharged to the
environment~ (2) location-specific.ARARs which are restrictions
placed on the concentrations of hazardous substances or the
conduct of activities solely because they are in specific
locations~ and (3) action-specific ARARs which are usually
technology or activity-based requirements or limitations on
actions triggered by particular remedial activities selected to
accomplish a remedy.
See NCP at ~ 300.400(g) and EPA's WCERCLA
Compliance with other Laws ManualW (WThe 1988 ManualW) at 1-13
through 1-56.
The procedure for identifying ARARs, succinctly
illustrated in Exhibit 1-4 of the 1988 Manual, shows that the
necessity, if any, and type of remedial action to be undertaken
at a CERCLA site is dictated in the first instance by chemical-
specific ARARs.
Under the statute and EPA guidelines, chemical-
. specific ARARs must be met, unless there exist statutory grounds
for a waiver.
Once chemical-specific ARARs (and location-
specific ARARs are identified), remedial alt~rnatives are
evaluated for compliance with those ARARs.
1988 Manual at 1-56.
'It is only at that point in the process that action-specific
ARARs are identified.
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-39-
specific requirements do not in themselves determine the remedial
alternatives; rather, they indicate how a selected alternative
must be achieved.-
Id. at 1-29.
Thus, action-specific ARARs are
not triggered unless remedial action is necessary to protect
public health and the environment or to achieve a chemical-
specific ARAR.
Because RCRA capping, if it is an ARAR, can only be an
action-specific ARAR, RCRA capping cannot be required unless
necessary to protect public health and the environment or
necessary for achievement of a chemical-specific ARAR.
As we
have shown above, EPA has found in ROD I that the management of
migration remedies specified therein protect public health and
the environment and will ensure achievement of all ARARs.
Furthermore, as we have shown above, after implementation of
Operable Unit 1, the Site presents no risks other than dermal
contact risks; and RCRA capping is not required to mitigate
dermal contact risks.
Additionally, RCRA capping of Waste Area 4 is not
required for achievement of any chemical-specific ARAR, because
the contaminants in Waste Area 4 are not the chlorinated ethenes
with respect to which MCLs are exceeded in the eastern bedrock
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chemical-specific ARARS for contaminants of concern identified in
the EA.
Also, RCRA capping of Waste Area 2 is not required to
achieve chemical-specific ARARs, b~cause the majority of flow
from Waste Area 2 emanates at eastern leachate seep LSE04 which
will be collected and treated in implementation of Operable Unit
l:lil and the portion of the flow from Waste Area 2 not
emanating at seep LSE04 already meets MCLs, as is evidenced by .
the lack of contamination in wells 49S, 42S and 42T, screened
immediately below Waste Area 2 or downslope of Waste Area 2.
Finally, capping of Waste Area 3 is not necessary for achievement
of chemical-specific ARARs, because the chlorinated ethenes in
the vicinity of Waste Area 3 have migrated into till groundwater
beneath the waste and, in any event, the MCLs for chlorinated
ethenes in eastern bedrock groundwater are not appropriately
considered ARARs at this site .UI
UI As discussed in section IV.B. below, the quality of leachate
currently emanating from seep LSE04 has improved dramatically
since the time of initial sampling in January of 1985 and is
nearly in compliance with MCLs in the absence of any remedial
actions. Remcor's regression analysis and desorption model
predict that seep LSE04 will meet all MCLs within the next few
years, even in the absence of any remedial action. See
Exhibit II (attached).
UI As previously stated, in the 1988 Manual, EPA has taken the
position that 'MCLs are generally not appropriate for site-
specific circumstances where a well would never be placed and
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In view of the foregoing, EPA may not justify low
permeability capping on the ground that it is an ARAR required to
be met under CERCLA.
At most, capping is an action-specific
ARAR; and -action specific requirements do not in themselves
determine the remedial alternatives. . . - for a site.
1988
Manual at 1-29.ill
.
B.
Even if Action-Specific ARARs are Triggered at the Site,
RCRA Capping is not -Appropriate Under the Circumstances of
the Release- of Hazardous Substances
Even if action-specific ARARs somehow are triggered at.
the Site, RCRA capping is not an ARAR because it is not
Nappropriate under the circumstances of the release.N
CERCLA
i 121(d)(2)(A).
The NCP and EPA guidance documents make clear
that the determination whether a requirement is relevant and
appropriate is a two-step process: (1) first, it must be
~I ( . . . continued)
groundwater would thus never be consumed (~, a 20-foot strip
of land beneath the toe of a landfill and a river, if there is no
surface water contamination resulting from man-made ground-water
contamination at the site.N ~ at 1-69.
UI Taken to its logical extension, EPA's position seems to be
that CERCLA requires RCRA caps at all sites, including municipal
landfills, where any amount of hazardous substances may have been
disposed, regardless of public health risk demonstrated by risk
assessments or exceedences of environmental criteria. Such an
extreme position has never been espoused by the Agency; and would
be inconsistent with CERCLA and the NCP.
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determined whether a requirement is relevant and, second, it must
be determined whether a requirement is appropriate.
NCP at
9 ~uu.400(g) and 1988 Manual at 1-60 through 1-70.
As stated in
the 1988 Manual:
In general, this involves a comparison of a
number of site-specific factors, including
the characteristics of the remedial action,
the hazardous substances present at the site,
or the physical circumstances of the site,
with those addressed in the statutory or
regulatory requirement. In some cases, a
requirement may be relevant, but not
appropriate, given site-specific
circumstances; such a requirement would not
be ARAR for the site.
Id. at section 1.2.4.3.
Similarly, the 1988 Manual states:
First, the determination focuses on whether a
requirement is relevant based on a comparison
between the action, location, or chemicals
covered by the requirement and related
conditions of the site, the release, or the
potential remedy. This step should be a
screen which will determine the relevance of
the potentially relevant and appropriate
requirement under consideration. The second
step is to determine whether the requirement
is aoorooriate by further refining the
comparison, focusing on the
nature/characteristics of the substances, the
characteristics of the site, the
circumstances of the release, and the
proposed remedial action.
~ at 1-67.
.A requirement may be relevant but not appropriate
for the specific site.
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-43-
determined to be both relevant and appropriate must be complied
with."
Id.
EPA's language in the Detailed Evaluation Memorandum
concludes that a RCRA-compliant cap is relevant at the site.U1
However, except with respect to the steep outslopes of Waste
Areas 2 and 3 (where RCRA capping was determined not to be
"appropriate"), the Agency has failed to make any factual
findings that would show a RCRA-compliant cap to be "appropriate"
under the circumstances of the releases at the Old Springfield
Landfill Site.
In fact, the Agency has ignored the detailed,
site-specific data presented by Remcor which show that capping is
not, in fact, appropriate at the site.
Low permeability capping over a waste disposal area is
appropriate where waste leachates, generated through rainwater
infiltration, pose a threat to groundwater (i.e., potentially
contaminating groundwater to levels that cause a public health or
environmental risk or lead to exceedences of environmental
UI The language in the Detailed Evaluation Memo and in the
Proposed Plan states that there are "substances disposed of and
found at the site similar to RCRA hazardous waste. In addition,
objectives of the remedial action, such as preventing the
leaching of soil contaminants to the groundwater and preventing
public contact with contaminated soil or leachate that may
present a risk, are similar to the purposes of the RCRA hazardous
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-44-
quality standards).
With respect to Waste Area 4, however,
Remcor's FFS shows that the contaminants of concern at the site
(the chlorinated ethenes for which MCLs are exceeded in eastern
bedrock groundwater) are not present in Waste Area 4 and that the
water within the saturated waste in Waste Area 4 already meets
all MCLs for contaminants of concern.nl
Also, the FFS shows
that the majority of the water flowing through and from Waste
Area 4 is drained through the till to a highly permeable sand and
.
gravel unit which underlies much of the Site and which acts as a
"drain- conveying groundwater to the western leachate seeps,
which will be collected and treated as part of the ROD I
management of migration operable unit.
Under these
circumstances, it is not "appropriate- to place a RCRA cap over
an area which clearly does not contribute to any public health
risk or to any exceedence of an MCL.lll
ill The fact that the waste is saturated means that further
leaching of any contaminants in Waste Area 4 will not cause
exceedences of any MCLs.
ill The Companies agree, however, that it is appropriate to
place a soil cover over Waste Area 4 to prevent dermal contact
with surficially contaminated soils. In addition, the Companies
believe that efforts should be made to prevent water leaving
Waste Area 4 from flowing into Waste Area 3. This, however, can
be accomplished by surface drainage improvements and by
installation of french drains upgradient of Waste Area 4 and
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-45-
It is also not -appropriate- to place a RCRA cap over
Waste Area 2.
Remcor's FFS shows that Waste Area 2 is almost
completely unsaturated and that the majority of water that does
flow through and from Waste Area 2 emanates at eastern seep LSE04
which will be collected and treated during implementation of the
ROD I Management of Migration Operable Unit.
Through natural
flushing processes, the quality of seep LSE04 has improved
dramatically since Site sampling began in January, 1985.
Remcor's regression analysis and desorption model (Figure 1
attached hereto) predict that, through natural flushing alone and
even without implementation of Operable unit NO.1, water quality
in seep LSE04 will meet all MCLs within the next few years.
According to the construction schedule announced during the July
12, 1990 public meeting, the start of construction for operable
unit 2 is estimated to be the summer of 1994.
It is expected
that leachate seep LSE04 will already achieve MCLs before capping
could be completed.
Furthermore, according to Remcor's FFS, to
the extent that any water from Waste Area 2 flows downward toward
bedrock (rather than toward seep LSE04) , such flow is
uncontaminated by site-related VOCs as is evidenced by well 49S
screened immediately below Waste Area 2 in the lacustrine silt
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-46-
Waste Area 2.
In these circumstances, it is not 'appropriate' to
place a RCRA cap over Waste Area 2.
Finally, although Waste Area 3 does represent the
principal source contributing chlorinated ethenes to bedrock
groundwater, Remcor has shown that a significant portion of the
water flowing through and from Waste Area 3 either drains to the
permeable sand and gravel unit and is conveyed to the western
leachate seeps for collection and treatment during Operable Unit
.
No.1 or emanates at seep LSE03 for collection and treatment
during Operable Unit No.1.
Furthermore, Remcor has concluded in
the FFS that the contaminants of concern in Waste Area 3 have
migrated to the till below the waste, itself, and that placing a
RCRA cap over Waste Area 3 will not shorten the timeframe for
achievement of MCLs at seep LSE03.
Moreover, bedrock groundwater
east of the former landfill will continue to receive contaminants
from the contaminated till groundwater, regardless of source
control action at Waste Area 3.
Capping of Waste Area 3 will, to
some extent, reduce flushing of till groundwater and actually
extend the time required for bedrock groundwater to achieve MCLs.
Under these circumstances, capping Waste Area 3 is not
'appropriate' because it will retard the natural flushing of
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-47-
implementation of operable unit No.1 or which discharge to the
Black River where no detectable VOCs can be found.
In summary, the studies 7equired by ROD I were intended
to determine if capping or other waste isolation measures .would
decrease the time needed to attain groundwater cleanup levels and
eliminate the risks associated with the contamination of
bedrock..
ROD I at 25.
Remcor has shown, however, that capping
will not decrease the time needed to attain groundwater cleanup
levels or eliminate the risks of concern to EPA, which we
dispute, associated with contaminated bedrock groundwater.
Accordingly, low permeability capping is not .appropriate under
the circumstances of the releases. at the Old Springfield
Landfill Site.
C.
To the Extent that RCRA Requirements are Considered ARARs,
Soil Covers on Waste Areas 2 and 4 would be Consistent with
.Hybrid Closure. Under RCRA
To the extent that EPA insists that RCRA closure
requirements are among the ARARs for the Site, that determination
does not require the construction of a multi-layer, low
permeability cap over Waste Areas 2 and 4.
Rather, as Remcor
suggested in the FFS, covering of the contaminated surface soils
within Waste Areas 2 ~nd 4 would be consistent with the .hybrid
closure. concept frequently utilized by EPA.
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soil cover design that would be consistent with hybrid closure is
included in Figure 4, Detail F (attached).
As stated in the preamble discussion to the proposed
NCP, 'the Superfund program has been using several different
types of hybrid closure (where RCRA closure is not applicable)
that give the decision maker additional choices for the long-term
management of hazardous substances as well as treated residuals~"
53 Fed. Rea. 51394, 51446 (1988).
One type of hybrid closure
'that is used by the Superfund program,' id., is referred to as
the alternative land disposal closure.
As EPA has stated:
This type of closure is identical to RCRA
landfill disposal closure except that the
cover requirements are relaxed because the
wastes being contained do not pose a threat
to groundwater. Direct contact and surface
water threats, as well as other threats, can
be adequately addressed with a soil cover.
This type of closure is usually appropriate
for wastes at low concentrations but still
above 'walk-away' levels. EPA has found this
type of closure to be useful in addressing
wide areas of contaminated soils in a
relatively inexpensive but very reliable
manner.
ML.
A similar discussion of the hybrid closure concept under
CERCLA is set forth in Directive 9234.2-04S (October 1989),
prepared by the EPA Office of Solid Waste and Emergency Response
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-49-
For the reasons set forth in preceding sections of
these comments, the hybrid closure concept is suited to Waste
Area 4 because that area does not ~epresent a threat to
groundwater.
As demonstrated by Remcor's FFS, the contaminants
of concern at the site (the chlorinated ethenes) are not present
in Waste Area 4 and the water within the saturated waste in Waste
Area 4 already meets all MCLs for contaminants of concern.
~~
only threat posed by Waste Area 4 is a threat of direct contact
with surficially contaminated soils, and that threat can be
eliminated with a soil cover.
Similarly, the hybrid closure concept is suited to
Waste Area 2 because groundwater in the vicinity of that waste
area is uncontaminated by site-r~lated VOCs, as is evidenced by
Well 49S screened immediately below Waste Area 2 in the
lacustrine silt and upper till and Wells 42S and 42T screened
downslope of Waste Area 2.
The majority of water flowing through
and from Waste Area 2 emanates at eastern seep LSE04 which will
be collected and treated during implementation of the ROD I
management of migration operable unit.
The only potential public
health risk posed by Waste Area 2 is related to direct contact
with surficial soils: and covering (as opposed to impermeable
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-50-
Remcor's FFS, would be effective in interrupting the dermal
contact pathway-
Notwithstanding the foregoing, in the Detailed
Evaluation Memo EPA has rejected the hybrid closure concept
because it .has never been promulgated as a rule under RCRA," id.
at 6, and because "the wastes clearly present a threat to
groundwater."
Id.
This rejection of the hybrid closure concept
is arbitrary and capricious with respect to Waste Areas 2 and 4.
EPA's belief that wastes in those areas .clearly present a threat
to groundwater" is unsubstantiated and contradicted by the data
in the FFS.
Moreover, the fact that hybrid closure has never
been promulgated as a rule under RCRA is wholly irrelevant, when
EPA has recognized that hybrid closure has frequently been used
under CERCLA and is available to the decision maker when RCRA
closure requirements are considered ARARs.
Accordingly, even if EPA determines that RCRA closure
requirements are "relevant and appropriate. for the Site, that
determination does not necessitate the construction of a multi-
layer, low permeability cap over Waste Areas. 2 and 4.
Rather,
soil covers over those areas would protect against dermal contact
threats and would be consistent with the hybrid closure concept
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*
*
*
In summary, EPA's proposed source control actions are
aimed at mitigating risks that do Dot exist at the Site, are
inconsistent with the NCP, are arbitrary and capricious, and
should be deleted from EPA's chosen remedy.
EPA has estimated
that the net present value for implementation of the source
control remedy described in the Proposed Plan could be as high 8S
$9.6 million.
In marked contrast, the net present value of
Remcor's recommended source control action -- addressing all
identified risks at the Site and consisting of fencing the Site,
installation of a source control well, and covering contaminated
soil areas -- is approximately $750,000.
Remcor's recommended
action is equally protective, more implementable, and much more
cost-effective.
If, however, EPA nevertheless insists on selecting a
source control remedy along the lines described in its Proposed
Plan, alternative design options for several of the elements
included in EPA's plan should be incorporated to achieve similar
objectives at much lower cost, and to enhance both the
implementability and effectiveness of the remedy.
Specific
design modifications and estimated cost savings are included in
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V.
TO THE EXTENT THAT EPA INSISTS ON IMPERMEABLE CAPPING
OF WASTE AREAS 2, 3 OR 4, THE CAP DESIGN SPECIFIED IS
EXCESSIVE AND INEFFECTIVE
If, despite the absence of risk justifying the
installation of an
impermeable cap over Waste Areas 2, 3 or
4, EPA nonetheless requires a cap over one or more of those
areas, the cap design specified in the Agency's Proposed
Plan is excessive in both complexity and cost and, moreover,
is likely to be ineffective.
The specified cap design is
more elaborate than required by RCRA regulations, fails to
reflect site-specific conditions as required by EPA's own
guidance document, deviates from the Agency's own design in
its 1988 preferred alternative for the site, and is likely
to fail as a result of differential settlement.
The cap design specified in the Proposed Plan
(Figure 3) consists of, from the bottom up, a 12-inch gas
vent layer, geotextile filter fabric, a 24-inch compacted
clay layer, a flexible membrane liner ("FML"), a l2-inch
drainage layer, geotextile filter fabric, a 24-inch clean
fill layer, a 12-inch top soil layer, and vegetative cover.
EPA indicates in its Proposed Plan that this cap design is
based on recent EPA guidance (EPA, July 1989) for capping of
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-53-
RCRA.
However, this design is much more elaborate than that
required by the RCRA regulations themselves.
Moreover, even
assuming the validity of EPA's reliance on the guidance
document, the Agency has ignored its own instructions by
applying design recommendations from the guidance document
without consideration of site-specific factors.
In defining
the purpose of the EPA guidance document:
"the [Agency] emphasizes that recommendations are
guidance only and not regulations. The Agency
acknowledges that other final cover designs may be
acceptable, depending upon site-specific condi-
tions and upon a determination that an alternate
design adequately fulfills the regulatory require-
ments. . .." (EPA, July 1989, Section 1.1, at 1)
(emphasis in original)
There are a number of site-specific conditions
that EPA should address, but has not, to develop an effec-
tive and implementable cap design at the Old Springfield
Landfill.
First, a 24-inch compacted clay layer should not
be included in the cap design without consideration of the
likely unavailability of native clay and, therefore, without
consideration of alternative design options for that layer.
Second, the inclusion of a l2-inch gravel layer for gas
venting in the cap design is unnecessary in Waste Areas 2
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-54-
place atop the waste over much of the area proposed to be
capped.
Third, the inclusion of an FML is inappropriate in
Waste Area 4 based on the potential for significant differ-
ential settlement at a landfill ysed for the disposal of
municipal solid waste.
If an FML is to be included, there
is no basis for the 24-inch clean fill layer whose purpose
-- but only in the absence of an FML -- would be to protect
the low-permeability clay or soil layer from freezing and
thawing action.
A.
The Likely Unavailability of Native Clay Requires
Consideration of Alternative Design Options
EPA's inclusion of a 24-inch compacted clay layer
in its cap design for the Old Springfield Landfill simply
ignores the likely unavailability of native clay which,
significantly, led both EPA and its contractor to include a
layer of compacted glacial till rather than clay in their
earlier cap designs for the site.
In connection with Remcor's work on the FFS, Rem-
cor personnel contacted the Vermont Department of Transpor-
tation to identify potential sources of materials for con-
struction of remedial action components.
Remcor then con-
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-55-
and similar materials.
From these contacts, Remcor deter-
mined that an adequate supply of native clay soils in the
area surrounding Springfield, Vermont is not likely to be
available for remedial construct!on at the site.
For this reason presumably, both EPA and its con-
tractor previously specified a layer of compacted glacial
till rather than clay in their earlier cap designs.
The
1988 FS describes this layer as a "2 ft. compacted glacial
till" or a "2 ft. thick glacial till (impermeable soil)
layer."
FS at 5-11, 7-19.
Likewise, EPA's preferred alter-
native issued in June 1988.contains a cross-section of the
proposed multi-layer cap (EPA, June 1988, Exhibit 2) with "2
ft. compacted fill."
Now, without explanation or justifica-
tion, EPA is proposing a compacted clay layer which is not
locally available and presumably would have to be imported
at substantial and unnecessary cost.
Consistent with the
FS, however, locally available glacial till should be al-
lowed for the low-permeability soil layer if the till satis-
fies the established permeability requirements.
A glacial
till layer would be equally as effective as a clay layer and
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-56-
Further, if the till is deemed unsuitable, alter-
native design options also are available, consistent with
EPA guidance documents and practice.
The EPA guidance docu-
ment for cap design "assumes that soil will be available
that can meet the 1 X 10-7 em/see" permeability criterion
for the low-permeability soil layer.
EPA, July 1989. Sec-
tion 4.2.2, at 28.
If soil satisfying that criterion is not
available, however, EPA has indicated at recent seminars
presenting the Agency's design guidance (EPA, July and Au-
gust 1990) that design options incorporating mixtures of
soils and clay minerals (!.g., bentonite) are recommended.~/
At the Old Springfield Landfill, such alternative
design options consistent with EPA guidance would incorpo-
rate (1) bentonite panels and locally available fill soils,
or (2) locally available fill soils mixed with bentonite.
Bentonite panels consist of a relatively thin (0.25-inch)
~ The purpose of these EPA-sponsored seminars, which were
given at 10 locations nationwide, was to provide the technical
community (~, design engineers, state regulatory officials)
with the most recent EPA guidance for the design and construc-
tion of cover systems for RCRA landfills and surface impound-
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layer of clay mineral granules sandwiched between a top
layer of polyester fabric and a bottom layer of water-
permeable polypropylene fabric.
The bentonite panels, whose
permeability is in the range of 1 X 10-10 to 1 X 10-9
em/see, would be covered with 2 feet of clean fill soil.
Alternatively, in lieu of providing a bentonite panel over-
lain with clean soil, the clay mineral granules can be
blended directly into the fill soils to produce a soil-
bentonite mixture of low (1 X 10-7 em/see) permeability.
Either of these designs would provide an equivalent or im-
proved level of effectiveness (i.e., equivalent to 2 feet of
clay at 1 X 10-7 em/see permeability), woul~ be more readily
implemented, and would provide cost savings of an estimated
$150,000 or more.
For these reasons, EPA should specify in its
source control remedy that the cap design may include gla-
cial till or bentonite rather than clay in the low-
permeability soil layer, so long as the permeability stan-
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-58-
B.
The Gas Vent Layer Should be Eliminated from the Cap
Design for Waste Areas 2 and 3 Based on the Presence
of Sandy Soil Cover Already in Place
The inclusion of a l2-inch gas gravel layer for
landfill venting is unnecessary .in Waste Areas 2 and 3 be-
cause of the existing sandy soil cover over much of the area
proposed to be capped.~/
EPA's own cap guidance document indicates that a
gas venting zone is an "optional layer" that could be re-
qui red on a site-specific basis.
EPA, July 1989, Section
5.1, at 3.1.
If a gas venting layer is required, however,
the existing sandy soil cover should suffice in Waste Areas
2 and 3.
EPA's guidance document -- which shows the gas
venting layer directly on top of the waste -- recommends
that, if needed, a gas venting layer should be constructed
of "coarse-grained, porous" materials and be a minimum of 12
inches thick.
EPA, July 1989, Sections 5.1.1 and 5.1.2, at
31-33.
The sandy soil cover at Waste Areas 2 and 3 meets
these criteria.
1lI Furthermore, both the 1988 FS (FS at 5-11) and EPA's
1988 preferred alternative included a 6-inch, rather than 12-
inch, gas collection layer. Neither the Proposed Plan nor the
SFS indicates what new site data caused a design change in-
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-59-
The existence of sandy soil cover overlying the
waste in much of the areas proposed to be capped is docu-
mented in the ICF RI and FS and confirmed in the FFS pre-
pared by Remcor.
The existing s~rface above the waste in
Waste Area 3 is comprised principally of sandy fill soils.
For example, in drilling Wells MW-38S, MW-40S, and MW-5IS
(which provide a cross-section along the centerline of Waste
Area 3), sandy fill soils were found to be at least three
feet thick on top of the waste in Waste Area 3.
FFS, Figure
9 and Appendix B.
These sands are generally permeable.
FFS, Table 25.
Similarly, in Waste Area 2, the waste is
covered with permeable sands.
ICF Borings 47, 53, and 60
and the drillholes for ICF Well MW-16 and Remcor Well MW-49S
all show the presence of at least one foot of sandy material
at the surface.
FFS, Figures 7 and 9 and Appendix B.
Accordingly, the sandy fill soils that overlay the
wastes in Waste Areas 2 and 3 meet EPA's design criteria,
and the importation of a separate layer of gravel to the
site as a gas venting layer for these areas is unnecessary
and should be eliminated.
Rather than importing stone and
building an additional layer into the cap, the preferred
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surface to ensure that the upper landfill zone is comprised
of permeable sands.
Eliminating a separate gas venting
layer from the cap in Waste Areas 2 and 3 would provide the
same degree of environmental prqtection and would result in
a cost savings of an estimated $95,000, based on the pricing
information provided in the SFS.
C.
The Flexible Membrane Liner Should be Eliminated from
the Cap Design for Waste Area 4 Because It is Not
Recommended for a Landfill Containing Municipal Solid
Waste and a High Potential for Differential Settlement
Whatever its advantages at other types of land-
fills, an FML should not be included in the cap design for
Waste Area 4 at this site due to the potential for signifi-
cant differential settlement.
Differential settlement at
the Old Springfield Landfill is likely to undermine the
integrity of the FML and the cap, if not in the short term
then certainly in the long term.
In contrast, a cap com-
prised solely of natural materials would provide improved
performance over an FML and would be less costly to con-
struct and to maintain.
An FML is often ill-suited for use in capping a
municipal solid waste landfill.
As the organic fraction of
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-61-
cal action, the volume of the waste is reduced significantly
which often results in landfill subsidence.
Regrading the
landfill prior to capping and cap placement can add signifi-
cant loading on top of the wast~ and exacerbate landfill
settlement.
Significant differential settlement can produce
sufficient stress to tear FMLs, rendering such membranes
ineffective as hydraulic barriers.
In addition, FMLs are
much more difficult to repair than natural materials, be-
cause tears are likely to be obscured by the cover material
and, when they are located, will require special materials
and expertise to repair.
The suitability of using an FML at a municipal
solid waste landfill has arisen at a number -of Superfund
sites nationwide, including sites in EPA Region I.
For
example, at the Charles George Landfill in Tyngsborough,
Massachusetts, EPA selected a remedial alternative which
included the installation of a cap containing an FML over a
large municipal landfill, despite strong protests from a
group of private parties based on the same concerns we are
expressing here.
Although EPA's contractor at that site
estimated that only about 0.78 foot of settlement would
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-62-
has already observed settlements in excess of 15 feet and
expects settlements of as much as another 18 feet in some
locations.
See Technical Comments on Remedial Actions Se-
lected for the Charles George Reelamation Trust Landfill,
Dunstable and Tyngsborough, Massachusetts, August 1990.~/
At that site, the short-term and long-term viability of the
cap, its consistency with the NCP, and EPA's ability to
recover its costs from responsible parties are all being
hotly contested in pending litigation.
The same factors arguing against the use of an FML
cap at other sites apply to the three waste areas proposed
to be capped at the Old Springfield Landfill -- but are
especially acute in Waste Area 4, where former disposal
trenches containing a high percentage of municipal solid
waste lie between berms of native soils and till.
Because
of the likelihood of significant subsidence within the
trenches and no settlement of the berms, an FML within Waste
Area 4 would be particularly susceptible to failure induced
!lI This document. is already in the possession of EPA Re-
gion I. We ask that it be included in the Administrative Re-
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by subsidence.
Even without the added loading imparted by
cap placement, differential settlements of 3 feet (vertical-
ly) over a (horizontal) distance of 10 to 15 feet have been
observed at Waste Area 4.
See FFS, Section 2.2.3.4 and
Figure 8.
As discussed above in Section IV, a multi-layer,
low-permeability RCRA cap is not required at this site.
To
the extent that EPA requires a low-permeability cap, howev-
er, a cap comprised of low-permeability soils with no FML
would be appropriate in Waste Area 4.
The cap design for
Waste Area 4 should be modified to eliminate the FML compo-
nent, replacing it with low-permeability soils or soils
blended with admixtures to achieve an effective low-
permeability cap.
An example of such a design is included
in Figure 4, Detail E (attached).
This design alternative
would improve long-term effectiveness and reduce cost by an
estimated $175,000 for Waste Area 4, based on the pricing
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D.
Where a Flexible Membrane Liner is Included, A 24-
Inch Clean Fill Layer is Not Needed to Protect the
Low-Permeability Clay or Soil Layer from Freezing
Where an FML is included in the cap design above
the low-permeability soil layer,. the 24-inch thick clean
fill layer above the drainage layer is excessive.
The
thickness of this layer should be reduced to 12 inches.
EPA presumably has included this thickened fill
layer in the design to protect the underlying, low-
permeability clay or soil layer from freezing and thawing
action, based on EPA's guidance document which recommends
that the low-permeability soil layer be entirely below the
depth of frost penetration.
EPA, July 1989, Section 4.2.2,
at 29.
If the FML is retained, however, the additional
protection is not required, because the FML itself provides
adequate protection against water percolating downward into
the low-permeability soil layer and causing freeze-thaw
damage.
Similarly, the underlying sandy soils prevent the
upward movement (by capillary action) of water into the low-
permeability soil layer.
The most significant potential effect of freezing
and thawing on a low-permeability soil layer is an increase
in the soil permeability.
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spaces between the solid soil grains are filled with water.
If the soil is then frozen, the water in the pore spaces
turns to ice, expands, and pushes the soil grains further
apart.
Ice lenses tend to form.as the pore water freezes.
When the soil subsequently thaws, the pore spaces remain
expanded and do not return to their original condition.
This expanded soil matrix has a higher permeability than
before its deformation.
As described in the FFS
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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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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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(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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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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-71-
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,
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-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.
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-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
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-
-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
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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.
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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.
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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
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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.
..
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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
-------
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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5
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1987
1988
TIME
NOTES:
1, REGRESSION EQUATION:
Ct = 3,500 - e -O,98t
WHERE:
Ct = TOTAL VOC CONCENTRATION
AT TIME t, IN YEARS,
MEASURED SINCE JANUARY
1985 ~g/I)
e = BASE OF NATURAL
LOGARITHMS.
2. FOR DESCRIPTION OF
DESORPTION MODEl,
SEE EXHIBIT II.
LEGEND:
. ACTUAL DATA
o REGRESSION ANALYSIS
l::. DESORPTION MODEL
FIGURE 1
VOC CONCENTRATION VERSUS TIME
SEEP LSE-04
OLD SPRINGF1ELD lANDF1LL SITE
SPRINGF1ELD, VERMONT
PREPARED FOR
..
OLD SPRINGFIELD LANDFILL
SITE RESPONDENTS
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-------
ATTACHMENT C
~RANSCRIPT OF ~HE AUGUST 2, 1990
-------
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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2
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
West Lebanon, New ijampshire 03784
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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
West Lebanon, New Hampshire 03784
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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
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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
North Country Court ieporters
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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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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.
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It's trenches, now, on the flat plateau part of the site
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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
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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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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
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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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wouldn't, we could do it definitely without any error at
alJ but I think within an acceptable area, we can do
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that.
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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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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
7
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
2
record to walk away from at this point.
Obviously we
3
don't in our analysis.
We feel that that should be
4
contained in that, either contained or excavated.
But I
5
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
North Countty C~urt Reporters
West Lebanon, New Hampshtre 03784
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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
North Country Court Reporters
West Lebanon, ~ew Hampshire 03784
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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?
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We are and I'm not aware of
DAVID WEBSTER:
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I'm not involved in that.
that.
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I am looking at the process for
WAYNE GOLEC:
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moving the dumpsters."
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I know, you're getting that
DAVID WEBSTER:
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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.
North Count~y C~urt Reporters
West Lebanon, New Hampsbire 03784
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C E R T I F I CAT E
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I, Cynthia Foster Benson, RPR, Notary Public and
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Court Reporter for North Country Court Reporters, West
Lebanon, New Hampshire, on August 2, 1990, do hereby certify
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that the foregoing pages 2-through 101, inclusive, comprise a
full, true and correct transcript to the best of my ability
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of the Public Hearing to Receive Comment on Proposed Plan for
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Second Record of Decision in re:
Old Springfield Landfill
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Superfund Site, as to which a transcript was duly ordered;
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Dated at West Lebanon, New Hampshire, this 15th day
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of August, 1990-
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North Country Court ~eporters
West Lebanon, New Hampshire 03784
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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
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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
-------
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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